Winning a Rural Health Transformation (RHT) subaward is the hard part. Then the clock starts on everything you have to document. The teams that struggle at audit time usually aren’t careless. They were busy delivering care, and they stood the program up without a system for the evidence. This is what to put in place in the first 90 days so the Single Audit is a hand-off later instead of a scramble.

Know early whether the Single Audit applies to you

Under 2 CFR 200 Subpart F (the federal Uniform Guidance), any non-federal entity that expends $1 million or more in federal awards in a fiscal year must have a Single Audit for that year. RHT dollars count toward that threshold along with every other federal source you draw on. The number that matters is expenditures, not the size of the award, so map your draw-down schedule against the threshold up front. If you’re likely to cross it, line up who performs the audit and what they’ll need now, well before year-end.

Build the reporting calendar before the first deadline

Most post-award obligations are date-driven, and most are knowable on day one: quarterly progress and financial reports, the annual report, and whatever state-specific timing your pass-through entity imposes. States vary. Some want quarterly reports within 15 days of period close, others within 30. Pull every due date out of the award and its terms and conditions, put them on one calendar with a countdown, and give each one an owner. A deadline you catch in week two is a task. The same deadline you find in week eleven is a finding.

Set up procurement files the way an auditor reads them

Procurement is the single most common repeat Single-Audit finding, and it’s almost always a documentation gap rather than a bad purchase. The fix is boring, and it works. For every purchase over your micro-purchase threshold, keep the evidence together from the start: price quotes or a written sole-source justification, the approval, and the 2 CFR 200 Appendix II contract clauses. Build the folder when you make the purchase, not when the auditor asks. A purchase you can’t reconstruct a year later is the finding that comes back every year.

A checklist for the first 90 days.
  • Project whether you’ll cross the $1M Single-Audit threshold this fiscal year
  • Build one reporting calendar with every quarterly/annual due date and an owner
  • Stand up a procurement file structure (quotes / justification / approval / clauses)
  • Start the SEFA worksheet now — award, ALN, pass-through ID, amounts
  • If you pass funds down, open a subrecipient-monitoring log
  • Keep a running “what’s still missing” evidence list

Start the SEFA on day one, not at year-end

The Schedule of Expenditures of Federal Awards (SEFA) ties your spending back to each federal award for the audit. Rebuilding it from a year of transactions is painful. Keeping it current as you go is not. Capture the pieces for each award as the money moves: the federal program and its Assistance Listing Number, the pass-through entity’s identifying number, and the amount expended. Keep a simple tie-out to your general ledger, and by the time fieldwork starts the SEFA your CPA needs already exists.

If you pass funds down, you owe subrecipient monitoring

Many RHT recipients act as pass-through entities, re-granting to clinics, behavioral-health providers, or community programs. If you do, you carry the 2 CFR 200.332 obligation to monitor those subrecipients: a risk assessment, the records you collect from them, and a plan for when something looks off. Keep that trail in one place: each subrecipient’s updates, your document requests, and your monitoring notes. It is also exactly the evidence your own auditor will ask to see.

Where the line sits: evidence vs. the audit itself

One boundary keeps everyone honest. Organizing evidence, building the calendar and trackers, and getting your files in order is operational work your team, or a software partner, can own. The audit opinion, the allowability determinations, and the Single Audit itself belong to your CPA or auditor. Good evidence makes their job faster and cheaper. It does not replace it. Be wary of anyone who promises to “make you compliant” or “guarantee a clean audit.” No software tool, and no non-auditor, can make that promise.

How OlenArc fits

OlenArc is a civilian software studio for Native-serving and rural health programs. We build OlenReady, an RHT Program Operations & Reporting Workspace that sets up exactly this: a reporting calendar, procurement evidence, a SEFA workbook, an evidence binder with a CPA-ready export, and a subrecipient-monitoring log, for tribal/Native-serving and rural health subrecipients. It organizes your evidence; it does not replace your CPA, auditor, or legal counsel. We already build software for the Arctic Slope Community Foundation, an Alaska Native community foundation, across all 8 North Slope Iñupiat villages.