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Cross-References: Published documentation hub (audited 2026-04-18): Proposed specs to close named gaps in this tracker (from 2026-04-17 deep review):

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Overview

This document tracks Finance & Accounting (FA) regulatory compliance: IRS tax reporting, GAAP/FASB ASC 958 nonprofit reporting, OMB Uniform Guidance (grant compliance), and financial internal controls. Status and interim procedures are summarized in the main REGULATORY_COMPLIANCE_TRACKER.md; this document provides detailed requirements and authoritative references.

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1. IRS Tax Reporting Compliance

Federal and state tax form generation and filing obligations supported by FA-10 (Tax Reporting & Compliance). FA-10 integrates with HR-07 (Payroll) for W-2 and 941/940 data.

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1.1 Information Returns (1099-MISC / 1099-NEC)

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1.2 Wage and Payroll Tax (W-2, 941, 940)

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1.3 Out of Scope (per FA-10)

  • Form 990 (annual information return for nonprofits) — Handled by external CPA. Filing thresholds: Form 990-N (gross receipts ≤ 50K);Form990−EZ(receipts<50K); Form 990-EZ (receipts < 200K and assets < 500K);Form990(receipts≥500K); Form 990 (receipts ≥ 200K or assets ≥ $500K). FA-23 supports functional expense categorization (Program Services, G&A, Fundraising) for 990 input; return preparation remains external.
  • Form 990-T / Arizona Form 99T (unrelated business income) — If unrelated business income is ≥ $1,000, file 990-T (federal) and Arizona Form 99T; out of scope for FA-10; handle externally.
  • Form 1040 / corporate tax returns — Prepared externally.

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2. GAAP / FASB ASC 958 Compliance

Nonprofit financial reporting standards. Behavioral health and recovery housing organizations typically report under FASB ASC 958 (Not-for-Profit Entities).

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2.1 Financial Statements

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2.2 Fund Accounting

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3. Grant Compliance (OMB Uniform Guidance — 2 CFR 200)

Federal grant recipients must comply with 2 CFR 200 (Uniform Administrative Requirements, Cost Principles, and Audit Requirements). FA-13 (Project Accounting & Grant Tracking) and FA-15 (Cost Allocation & Indirect Cost Rates) provide system support when implemented.

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3.1 Allowable Costs and Cost Principles

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3.2 Single Audit (2 CFR 200 Subpart F)

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3.3 Federal Financial Report (FFR/SF-425)

Federal grant recipients (e.g. SAMHSA, other federal awardees) must submit the Federal Financial Report (FFR, SF-425) via the Payment Management System (PMS). Interim: Prepare FFR from grant/project and GL data manually; submit via PMS. Implement FA-13 (Project Accounting & Grant Tracking) to improve data availability for FFR.

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3.4 Record retention (2 CFR 200.334)

Recipients and subrecipients must retain federal award records for 3 years from the date of submission of the final financial report (2 CFR 200.334). Records must be retained longer if litigation, claims, or audit findings exist until resolution. Alignment: FA-SECURITY-CONSIDERATIONS.md requires audit logs to be retained for 7 years, which satisfies and exceeds 2 CFR 200.334 for financial and compliance records. No additional tracker row required. Reference: eCFR 2 CFR 200.334 — Retention requirements for records.

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3.5 Subrecipient monitoring (pass-through entities)

Under 2 CFR 200.331–200.332, pass-through entities must verify that subrecipients are not excluded (e.g. via SAM.gov), and ensure each subaward is clearly identified and documented (federal award id, subrecipient name/UEI, and other required information). Interim: If the organization passes federal funds to subrecipients: perform SAM.gov exclusion checks and maintain subaward documentation outside the system until a dedicated spec exists (future FA or GR).

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4. Financial Controls & Audit Readiness

Internal controls and audit trail support for external audits and SOX-analogous expectations (segregation of duties, immutable audit trail). State and local — Arizona: Arizona nonprofits must file an Annual Report with the Arizona Corporation Commission by the formation anniversary date (ARS 10-11622). Content includes directors/officers, principal office, activities, certificate of disclosure, and a statement that all corporate income tax returns have been filed. Extension up to 6 months available. No system automation; use org profile/board data. See Authoritative External References: Arizona Corporation Commission, ARS 10-11622.

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4.1 Audit Trail and Reporting

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4.2 Period and Close Controls

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4.3 Access and Security

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5. Authoritative External References

Use these sources for implementation and spec review. Full table also in docs/compliance/AUTHORITATIVE_REFERENCES.md (Finance & Accounting Compliance).

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Version History

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1.1.0 (2026-02-27)

  • Added Federal Financial Report (FFR/SF-425) subsection and tracker row; SAMHSA FFR authoritative reference.
  • Added 2 CFR 200.334 record retention subsection and alignment with 7-year policy.
  • Added subrecipient monitoring (2 CFR 200.331–332) subsection; added pass-through branch to AGENTS.md decision tree.
  • Expanded Arizona ACC annual report in tracker and state/local note; added ARS 10-11622 reference.
  • Expanded Form 990 thresholds (990-N, 990-EZ, 990) and 990-T/AZ 99T in Out of scope.

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1.0.0 (2026-02-27)

  • Initial FA financial compliance tracking document
  • IRS tax reporting (1099, W-2, 941, 940) per FA-10
  • GAAP/FASB ASC 958 and fund accounting per FA-01, FA-02, FA-23, FA-07
  • Grant compliance (OMB 2 CFR 200) and Single Audit per FA-13, FA-15
  • Financial controls and audit readiness per FA-25, FA-19
  • Authoritative external references aligned with AGENTS.md
Last Updated: 2026-04-18 Next Review: 2026-05-27