CARES Act and M -20-21 - CFO (2) Notwithstanding paragraph (c)(1) of this section, OMB may approve a Federal awarding agency's request that a Type A program may not be considered low risk for a certain recipient. (i) Medicaid. (a) Retention of audit documentation. Section 200.331 sets forth the considerations in determining whether payments constitute a Federal award or a payment for goods or services provided as a contractor. As provided in 200.332(d), the pass-through entity must be responsible for issuing a management decision for audit findings that relate to Federal awards it makes to subrecipients. Prior to commencing such an audit, the Federal agency or pass-through entity must review the FAC for recent audits submitted by the non-Federal entity, and to the extent such audits meet a Federal agency or pass-through entity's needs, the Federal agency or pass-through entity must rely upon and use such audits. (a) An audit conducted in accordance with this part must be in lieu of any financial audit of Federal awards which a non-Federal entity is required to undergo under any other Federal statute or regulation. Programs which do not meet the $750,000 threshold are not required to engage in audit services. The oversight agency for audit: (1) Must provide technical advice to auditees and auditors as requested. SEFA vs. SF-SAC). Does the Single Audit requirement apply to CARES Act funding? 78 FR 78608, Dec. 26, 2013, unless otherwise noted. The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee's financial statements which must include the total Federal awards expended as determined in accordance with 200.502. 2 CFR part 200 Subpart F-Audit Requirements. WebThe single audit requirement applies to: A. > Data Act Program Management Office Washington, D.C. 20201 While not required, the Federal agency or pass-through entity may also issue a management decision on findings relating to the financial statements which are required to be reported in accordance with GAGAS. Single Audit Requirements for Nonprofits Receiving Federal Funds WebSingle Audit Extension 45 CFR Part 75, Subpart F, requires recipients expending $750,000 or more in Federal awards during their Fiscal Years to complete Single Audits and Title 2 was last amended 3/01/2023. learn more about the process here. (iii) Promptly inform other affected Federal agencies and appropriate Federal law enforcement officials of any direct reporting by the auditee or its auditor required by GAGAS or statutes and regulations. Methods to ensure compliance for Federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement, and post-award audits. Free rent received by itself is not considered a Federal award expended under this part. (g) Valuing non-cash assistance. The audit must cover the entire operations of the auditee, or, at the option of the auditee, such audit must include a series of audits that cover departments, agencies, and other organizational units that expended or otherwise administered Federal awards during such audit period, provided that each such audit must encompass the financial statements and schedule of expenditures of Federal awards for each such department, agency, and other organizational unit, which must be considered to be a non-Federal entity. Single Audit, previously known as the OMB Circular A-133 audit, is an organization-wide financial statement and federal awards audit of a non-federal entity See also 200.332. (2) All Type B programs identified as high-risk under step three (paragraph (d) of this section). When the major program determination was performed and documented in accordance with this Subpart, the auditor's judgment in applying the risk-based approach to determine major programs must be presumed correct. (d) Other sections of this part may apply. The following is a listing of the suggested audit procedures for procurement as detailed in Part 3.2: Obtain the entitys procurement policies and verify that the policies comply with the compliance requirements highlighted above. (c) There were no deficiencies in internal control which were identified as material weaknesses under the requirements of GAGAS. (c) A report on compliance for each major program and a report on internal control over compliance. The single audit requirement applies to A All audits of Where there have been changes to the compliance requirements and the changes are not reflected in the compliance supplement, the auditor must determine the current compliance requirements and modify the audit procedures accordingly. Getting the SEFA right is required to determine when a Single Audit is required and, if required, the proper scope of the Single Audit. A statement of the effect or potential effect should provide a clear, logical link to establish the impact or potential impact of the difference between the condition and the criteria. Except for the provisions for biennial audits provided in paragraphs (a) and (b) of this section, audits required by this part must be performed annually. The Single Audit Act of 1984 standardized audits for states, local and tribal The Single Audit test model examines non-federal entity post-award reporting requirements under the Single Audit Act. For specific questions and information concerning the submission process: HHS is committed to making its websites and documents accessible to the widest possible audience, A separate drafting site (3) Such additional programs as may be necessary to comply with the percentage of coverage rule discussed in paragraph (f) of this section. Schedule of Expenditures of Federal Awards (SEFA Background and more details are available in the (1) The audit must be completed and the reporting required by paragraph (c)(2) or (c)(3) of this section submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period, unless a different period is specified in a program-specific audit guide. (a) A state, local government, or Indian tribe that is required by constitution or statute, in effect on January 1, 1987, to undergo its audits less frequently than annually, is permitted to undergo its audits pursuant to this part biennially. As provided in 200.513(c)(3)(i), a Federal awarding agency is responsible for issuing a management decision for findings that relate to Federal awards it makes to non-Federal entities. WebDiscussion of potential single audit implications and other related guidance expected from OMB 3. (b) Federal agency. C. Audits following the Single Audit Act of 1984 (with 1996 Amendments) and the revised OMBCircular A-133. The determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs. (4) When internal control over some or all of the compliance requirements for a major program are likely to be ineffective in preventing or detecting noncompliance, the planning and performing of testing described in paragraph (c)(3) of this section are not required for those compliance requirements. The Federal awarding agency must then promptly confirm to the auditee whether it wants the program audited as a major program. (d) Prior loan and loan guarantees (loans). Single Audit (v) Report any audit findings consistent with the requirements of 200.516. This paragraph does not require the auditor to report publicly information which could compromise investigative or legal proceedings or to make an additional reporting when the auditor confirms that the fraud was reported outside the auditor's reports under the direct reporting requirements of GAGAS. However, Federal agencies and pass-through entities may provide auditors guidance about the risk of a particular Federal program and the auditor must consider this guidance in determining major programs in audits not yet completed. If the auditee has not completed corrective action, a timetable for follow-up should be given. 07/06/2015. [78 FR 78608, Dec. 26, 2013, as amended at 85 FR 49575, Aug. 13, 2020]. developer resources. An auditor who prepares the indirect cost proposal or cost allocation plan may not also be selected to perform the audit required by this part when the indirect costs recovered by the auditee during the prior year exceeded $1 million. This governmentwide audit quality project must be performed once every 6 years (or at such other interval as determined by OMB), and the results must be public. High levels of testing are required to establish that: The financial statements are not only presented fairly and accurately, but that they are in accordance with federal cost principles. When a Federal program providing loans exceeds four times the largest non-loan program it is considered a large loan program, and the auditor must consider this Federal program as a Type A program and exclude its values in determining other Type A programs. [78 FR 78608, Dec. 26, 2013, as amended at 85 FR 49570, Aug. 13, 2020]. Single Audit (f) Free rent. Access to audit documentation includes the right of Federal agencies to obtain copies of audit documentation, as is reasonable and necessary. This web site is designed for the current versions of Where practical, audit findings should be organized by Federal agency or pass-through entity. Choosing an item from Subpart F - Audit Requirements Federal non-cash assistance, such as free rent, food commodities, donated property, or donated surplus property, must be valued at fair market value at the time of receipt or the assessed value provided by the Federal agency. If this option is exercised, the auditee becomes responsible for submitting the reporting package directly to any pass-through entities through which it has received a Federal award and to pass-through entities for which the summary schedule of prior audit findings reported the status of any findings related to Federal awards that the pass-through entity provided. (f) Percentage of coverage rule. (c) Corrective action plan. The reporting package must include the: (1) Financial statements and schedule of expenditures of Federal awards discussed in 200.510(a) and (b), respectively; (2) Summary schedule of prior audit findings discussed in 200.511(b); (3) Auditor's report(s) discussed in 200.515; and. (e) Requests for management letters issued by the auditor. Federal awards expended as a recipient or a subrecipient are subject to audit under this part. [78 FR 78608, Dec. 26, 2013, as amended at 79 FR 75887, Dec. 19, 2014; 85 FR 49572, Aug. 13, 2020]. (d) Inherent risk of the Federal program. If you would like to comment on the current content, please use the 'Content Feedback' button below for instructions on contacting the issuing agency. Enhanced content is provided to the user to provide additional context. A non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single or program-specific audit conducted for that year in accordance with the provisions of this part. (2) To provide for continuity of cognizance, the determination of the predominant amount of direct funding must be based upon direct Federal awards expended in the non-Federal entity's fiscal years ending in 2019, and every fifth year thereafter. As part of audit follow-up, the Federal awarding agency must: (i) Issue a management decision as prescribed in 200.521; (ii) Monitor the recipient taking appropriate and timely corrective action; (iii) Use cooperative audit resolution mechanisms (see the definition of cooperative audit resolution in 200.1 of this part) to improve Federal program outcomes through better audit resolution, follow-up, and corrective action; and. (2) When a program-specific audit guide is available, the auditee must electronically submit to the FAC the data collection form prepared in accordance with 200.512(b), as applicable to a program-specific audit, and the reporting required by the program-specific audit guide. A Federal agency that conducts or arranges for additional audits must, consistent with other applicable Federal statutes and regulations, arrange for funding the full cost of such additional audits. The FAC operates on behalf of the OMB. Single Audit Challenges by Federal agencies and pass-through entities must only be for clearly improper use of the requirements in this part. (a) General. (2) The auditee must prepare the financial statement(s) for the Federal program that includes, at a minimum, a schedule of expenditures of Federal awards for the program and notes that describe the significant accounting policies used in preparing the schedule, a summary schedule of prior audit findings consistent with the requirements of 200.511(b), and a corrective action plan consistent with the requirements of 200.511(c). contact the publishing agency. (10) Views of responsible officials of the auditee. Webprinciples, and single audit requirements contained in the . However, the reporting in one section of the schedule may be in summary form with a reference to a detailed reporting in the other section of the schedule. (e) Step four. (f) Report retention requirements. (c) Program-specific audit (e) Audit follow-up. Audits A cluster of programs is treated as one program and the value of Federal awards expended under a loan program is determined as described in 200.502. Also, significant changes in Federal programs, statutes, regulations, or the terms and conditions of Federal awards may increase risk. citations and headings Auditees and auditors must ensure that their respective parts of the reporting package do not include protected personally identifiable information. (3) Follow-up on audit findings to ensure that the recipient takes appropriate and timely corrective action. is available with paragraph structure matching the official CFR Has your state, local government or NPO expended federal awards over the threshold for a single audit? Audit Requirements Navigate by entering citations or phrases B. (a) Auditor procurement. The data elements and format must be approved by OMB, available from the FAC, and include collections of information from the reporting package described in paragraph (c) of this section. Web(2) When reporting on any single audit, the auditor shall include a summary of the auditor's results regarding the non-Federal entity's financial statements, internal controls, and If you have questions for the Agency that issued the current document please contact the agency directly. COVID-19 Funding: Do I need a Single Audit? | Wipfli The corrective action plan and summary schedule of prior audit findings must include findings relating to the financial statements which are required to be reported in accordance with GAGAS. The Office of the Federal Register publishes documents on behalf of Federal agencies but does not have any authority over their programs. The auditor should report whether the sampling was a statistically valid sample. If the amount of the EIDL loan in combination with other federal funds exceeds $750,000 in their fiscal year, the nonprofit must complete a Single Audit. WebThe Single Audit must be performed by an independent auditor and the reporting package (which includes the audit report) must be submitted to the Federal Audit Clearinghouse (a) Audit findings reported. (4) The auditor's report(s) may be in the form of either combined or separate reports and may be organized differently from the manner presented in this section. (b) Single audit. 31 USC Ch. 75: REQUIREMENTS FOR SINGLE AUDITS (i) A Federal program administered under multiple internal control structures may have higher risk. Although the Single Auditrequirement applies to most of the CARES Act funds and programs, you should review the Assistance Listing, available at
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