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In response to numerous questions regarding when reimbursement of expenses from FEMA should be reported on the Schedule of Federal Awards, FEMA has provided specific guidance for auditors and auditees to follow. According to the FEMA Office of Chief Counsel, the recording of expenditures on the Schedule of Federal Awards should be based on when the funds are approved. That approval is evidenced on the Award Worksheet. The approval of the Award Worksheet is the triggering event for FEMA to actually obligate the funds to the recipient. As an example, if the expenditures occurred during the 2012 fiscal year, but the Award Worksheet is not approved until the 2013 fiscal year, those expenditures would be reported on the 2013 Schedule of Federal Awards.
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