Circular A-133 -- Audits of States, Local Governments, and Non-Profit OrganizationsSkip
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Circular No. A-133
Revised to show changes published in the
Federal Register June 27, 2003
Audits of States, Local Governments, and Non-Profit Organizations
Accompanying Federal Register Materials:
-- Audits of States, Local Governments, and Non-Profit
Organizations June 30, 1997
-- Revision published June 27, 2003
TO THE HEADS OF EXECUTIVE DEPARTMENTS AND ESTABLISHMENTS
SUBJECT: Audits of States, Local Governments, and Non-Profit
Organizations
1. Purpose. This Circular is issued pursuant to the Single Audit Act of
1984, P.L. 98-502, and the Single Audit Act Amendments of 1996, P.L.
104-156. It sets forth standards for obtaining consistency and uniformity
among Federal agencies for the audit of States, local governments, and
non-profit organizations expending Federal awards.
2. Authority. Circular A-133 is issued under the authority of sections
503, 1111, and 7501 et seq. of title 31, United States Code, and Executive
Orders 8248 and 11541.
3. Rescission and Supersession. This Circular rescinds Circular A-128,
"Audits of State and Local Governments," issued April 12, 1985, and
supersedes the prior Circular A-133, "Audits of Institutions of Higher
Education and Other Non-Profit Institutions," issued April 22, 1996. For
effective dates, see paragraph 10.
4. Policy. Except as provided herein, the standards set forth in this
Circular shall be applied by all Federal agencies. If any statute
specifically prescribes policies or specific requirements that differ from
the standards provided herein, the provisions of the subsequent statute
shall govern.
Federal agencies shall apply the provisions of the sections of this
Circular to non-Federal entities, whether they are recipients expending
Federal awards received directly from Federal awarding agencies, or are
subrecipients expending Federal awards received from a pass-through entity
(a recipient or another subrecipient).
This Circular does not apply to non-U.S. based entities expending Federal
awards received either directly as a recipient or indirectly as a
subrecipient.
5. Definitions. The definitions of key terms used in this Circular are
contained in ___.105 in the Attachment to this Circular.
6. Required Action. The specific requirements and responsibilities of
Federal agencies and non-Federal entities are set forth in the Attachment
to this Circular. Federal agencies making awards to non-Federal entities,
either directly or indirectly, shall adopt the language in the Circular in
codified regulations as provided in Section 10 (below), unless different
provisions are required by Federal statute or are approved by the Office
of Management and Budget (OMB).
7. OMB Responsibilities. OMB will review Federal agency regulations and
implementation of this Circular, and will provide interpretations of
policy requirements and assistance to ensure uniform, effective and
efficient implementation.
8. Information Contact. Further information concerning Circular A-133 may
be obtained by contacting the Financial Standards and Reporting Branch,
Office of Federal Financial Management, Office of Management and Budget,
Washington, DC 20503, telephone (202) 395-3993.
9. Review Date. This Circular will have a policy review three years from
the date of issuance.
10. Effective Dates. The standards set forth in ___.400 of the Attachment
to this Circular, which apply directly to Federal agencies, shall be
effective July 1, 1996, and shall apply to audits of fiscal years
beginning after June 30, 1996, except as otherwise specified in
___.400(a).
The standards set forth in this Circular that Federal agencies shall apply
to non-Federal entities shall be adopted by Federal agencies in codified
regulations not later than 60 days after publication of this final
revision in the Federal Register, so that they will apply to audits of
fiscal years beginning after June 30, 1996, with the exception that
___.305(b) of the Attachment applies to audits of fiscal years beginning
after June 30, 1998. The requirements of Circular A-128, although the
Circular is rescinded, and the 1990 version of Circular A-133 remain in
effect for audits of fiscal years beginning on or before June 30, 1996.
The revisions published in the Federal Register June 27, 2003, are
effective for fiscal years ending after December 31, 2003, and early
implementation is not permitted with the exception of the definition of
oversight agency for audit, which is effective July 28, 2003.
Augustine T. Smythe
Acting Director
Attachment
PART__ --AUDITS OF STATES, LOCAL GOVERNMENTS, AND NON-PROFIT ORGANIZATIONS
Subpart A--General
Sec.
__.100 Purpose.
__.105 Definitions.
Subpart B--Audits
__.200 Audit requirements.
__.205 Basis for determining Federal awards expended.
__.210 Subrecipient and vendor determinations.
__.215 Relation to other audit requirements.
__.220 Frequency of audits.
__.225 Sanctions.
__.230 Audit costs.
__.235 Program-specific audits.
Subpart C--Auditees
__.300 Auditee responsibilities.
__.305 Auditor selection.
__.310 Financial statements.
__.315 Audit findings follow-up.
__.320 Report submission.
Subpart D--Federal Agencies and Pass-Through Entities
__.400 Responsibilities.
__.405 Management decision.
Subpart E--Auditors
__.500 Scope of audit.
__.505 Audit reporting.
__.510 Audit findings.
__.515 Audit working papers.
__.520 Major program determination.
__.525 Criteria for Federal program risk.
__.530 Criteria for a low-risk auditee.
Appendix A to Part __ - Data Collection Form (Form SF-SAC).
Appendix B to Part __ - Circular A-133 Compliance Supplement.
Table of Contents
Subpart A--General
___.100 Purpose.
This part sets forth standards for obtaining consistency and uniformity
among Federal agencies for the audit of non-Federal entities expending
Federal awards.
___.105 Definitions.
Auditee means any non-Federal entity that expends Federal awards which
must be audited under this part. Auditor means an auditor, that is a
public accountant or a Federal, State or local government audit
organization, which meets the general standards specified in generally
accepted government auditing standards (GAGAS). The term auditor does not
include internal auditors of non-profit organizations.
Audit finding means deficiencies which the auditor is required by
___.510(a) to report in the schedule of findings and questioned costs.
CFDA number means the number assigned to a Federal program in the Catalog
of Federal Domestic Assistance (CFDA).
Cluster of programs means a grouping of closely related programs that
share common compliance requirements. The types of clusters of programs
are research and development (R&D), student financial aid (SFA), and other
clusters. "Other clusters" are as defined by the Office of Management and
Budget (OMB) in the compliance supplement or as designated by a State for
Federal awards the State provides to its subrecipients that meet the
definition of a cluster of programs. When designating an "other cluster,"
a State shall identify the Federal awards included in the cluster and
advise the subrecipients of compliance requirements applicable to the
cluster, consistent with ___.400(d)(1) and ___.400(d)(2), respectively.
A cluster of programs shall be considered as one program for determining
major programs, as described in ___.520, and, with the exception of R&D
as described in ___.200(c), whether a program-specific audit may be
elected.
Cognizant agency for audit means the Federal agency designated to carry
out the responsibilities described in ___.400(a).
Compliance supplement refers to the Circular A-133 Compliance Supplement,
included as Appendix B to Circular A-133, or such documents as OMB or its
designee may issue to replace it. This document is available from the
Government Printing Office, Superintendent of Documents, Washington, DC
20402-9325.
Corrective action means action taken by the auditee that:
(1) Corrects identified deficiencies;
(2) Produces recommended improvements; or
(3) Demonstrates that audit findings are either invalid or do not warrant
auditee action.
Federal agency has the same meaning as the term agency in Section 551(1)
of title 5, United States Code.
Federal award means Federal financial assistance and Federal
cost-reimbursement contracts that non-Federal entities receive directly
from Federal awarding agencies or indirectly from pass-through entities.
It does not include procurement contracts, under grants or contracts, used
to buy goods or services from vendors. Any audits of such vendors shall be
covered by the terms and conditions of the contract. Contracts to operate
Federal Government owned, contractor operated facilities (GOCOs) are
excluded from the requirements of this part.
Federal awarding agency means the Federal agency that provides an award
directly to the recipient.
Federal financial assistance means assistance that non-Federal entities
receive or administer in the form of grants, loans, loan guarantees,
property (including donated surplus property), cooperative agreements,
interest subsidies, insurance, food commodities, direct appropriations,
and other assistance, but does not include amounts received as
reimbursement for services rendered to individuals as described in
___.205(h) and ___.205(i).
Federal program means:
(1) All Federal awards to a non-Federal entity assigned a single number in
the CFDA.
(2) When no CFDA number is assigned, all Federal awards from the same
agency made for the same purpose should be combined and considered one
program.
(3) Notwithstanding paragraphs (1) and (2) of this definition, a cluster
of programs. The types of clusters of programs are:
(i) Research and development (R&D);
(ii) Student financial aid (SFA); and
(iii) "Other clusters," as described in the definition of cluster of
programs in this section.
GAGAS means generally accepted government auditing standards issued by the
Comptroller General of the United States, which are applicable to
financial audits.
Generally accepted accounting principles has the meaning specified in
generally accepted auditing standards issued by the American Institute of
Certified Public Accountants (AICPA).
Indian tribe means any Indian tribe, band, nation, or other organized
group or community, including any Alaskan Native village or regional or
village corporation (as defined in, or established under, the Alaskan
Native Claims Settlement Act) that is recognized by the United States as
eligible for the special programs and services provided by the United
States to Indians because of their status as Indians.
Internal control means a process, effected by an entity's management and
other personnel, designed to provide reasonable assurance regarding the
achievement of objectives in the following categories:
(1) Effectiveness and efficiency of operations;
(2) Reliability of financial reporting; and
(3) Compliance with applicable laws and regulations.
Internal control pertaining to the compliance requirements for Federal
programs (Internal control over Federal programs) means a
process--effected by an entity's management and other personnel--designed
to provide reasonable assurance regarding the achievement of the following
objectives for Federal programs:
(1) Transactions are properly recorded and accounted for to:
(i) Permit the preparation of reliable financial statements and Federal
reports;
(ii) Maintain accountability over assets; and
(iii) Demonstrate compliance with laws, regulations, and other compliance
requirements;
(2) Transactions are executed in compliance with:
(i) Laws, regulations, and the provisions of contracts or grant agreements
that could have a direct and material effect on a Federal program; and
(ii) Any other laws and regulations that are identified in the compliance
supplement; and
(3) Funds, property, and other assets are safeguarded against loss from
unauthorized use or disposition.
Loan means a Federal loan or loan guarantee received or administered by a
non-Federal entity.
Local government means any unit of local government within a State,
including a county, borough, municipality, city, town, township, parish,
local public authority, special district, school district, intrastate
district, council of governments, and any other instrumentality of local
government.
Major program means a Federal program determined by the auditor to be a
major program in accordance with ___.520 or a program identified as a
major program by a Federal agency or pass-through entity in accordance
with ___.215(c).
Management decision means the evaluation by the Federal awarding agency or
pass-through entity of the audit findings and corrective action plan and
the issuance of a written decision as to what corrective action is
necessary.
Non-Federal entity means a State, local government, or non-profit
organization.
Non-profit organization means:
(1) any corporation, trust, association, cooperative, or other
organization that:
(i) Is operated primarily for scientific, educational, service,
charitable, or similar purposes in the public interest;
(ii) Is not organized primarily for profit; and
(iii) Uses its net proceeds to maintain, improve, or expand its
operations; and
(2) The term non-profit organization includes non-profit institutions of
higher education and hospitals.
OMB means the Executive Office of the President, Office of Management and
Budget.
Oversight agency for audit means the Federal awarding agency that provides
the predominant amount of direct funding to a recipient not assigned a
cognizant agency for audit. When there is no direct funding, the Federal
agency with the predominant indirect funding shall assume the oversight
responsibilities. The duties of the oversight agency for audit are
described in ___.400(b).
Effective July 28, 2003, the following is added to this definition:
A Federal agency with oversight for an auditee may reassign oversight to
another Federal agency which provides substantial funding and agrees to be
the oversight agency for audit. Within 30 days after any reassignment,
both the old and the new oversight agency for audit shall notify the
auditee, and, if known, the auditor of the reassignment.
Pass-through entity means a non-Federal entity that provides a Federal
award to a subrecipient to carry out a Federal program.
Program-specific audit means an audit of one Federal program as provided
for in ___.200(c) and ___.235.
Questioned cost means a cost that is questioned by the auditor because of
an audit finding:
(1) Which resulted from a violation or possible violation of a provision
of a law, regulation, contract, grant, cooperative agreement, or other
agreement or document governing the use of Federal funds, including funds
used to match Federal funds;
(2) Where the costs, at the time of the audit, are not supported by
adequate documentation; or
(3) Where the costs incurred appear unreasonable and do not reflect the
actions a prudent person would take in the circumstances.
Recipient means a non-Federal entity that expends Federal awards received
directly from a Federal awarding agency to carry out a Federal program.
Research and development (R&D) means all research activities, both basic
and applied, and all development activities that are performed by a
non-Federal entity. Research is defined as a systematic study directed
toward fuller scientific knowledge or understanding of the subject
studied. The term research also includes activities involving the training
of individuals in research techniques where such activities utilize the
same facilities as other research and development activities and where
such activities are not included in the instruction function. Development
is the systematic use of knowledge and understanding gained from research
directed toward the production of useful materials, devices, systems, or
methods, including design and development of prototypes and processes.
Single audit means an audit which includes both the entity's financial
statements and the Federal awards as described in ___.500.
State means any State of the United States, the District of Columbia, the
Commonwealth of Puerto Rico, the Virgin Islands, Guam, American Samoa, the
Commonwealth of the Northern Mariana Islands, and the Trust Territory of
the Pacific Islands, any instrumentality thereof, any multi-State,
regional, or interstate entity which has governmental functions, and any
Indian tribe as defined in this section.
Student Financial Aid (SFA) includes those programs of general student
assistance, such as those authorized by Title IV of the Higher Education
Act of 1965, as amended, (20 U.S.C. 1070 et seq.) which is administered by
the U.S. Department of Education, and similar programs provided by other
Federal agencies. It does not include programs which provide fellowships
or similar Federal awards to students on a competitive basis, or for
specified studies or research.
Subrecipient means a non-Federal entity that expends Federal awards
received from a pass-through entity to carry out a Federal program, but
does not include an individual that is a beneficiary of such a program. A
subrecipient may also be a recipient of other Federal awards directly from
a Federal awarding agency. Guidance on distinguishing between a
subrecipient and a vendor is provided in ___.210.
Types of compliance requirements refers to the types of compliance
requirements listed in the compliance supplement. Examples include:
activities allowed or unallowed; allowable costs/cost principles; cash
management; eligibility; matching, level of effort, earmarking; and,
reporting.
Vendor means a dealer, distributor, merchant, or other seller providing
goods or services that are required for the conduct of a Federal program.
These goods or services may be for an organization's own use or for the
use of beneficiaries of the Federal program. Additional guidance on
distinguishing between a subrecipient and a vendor is provided in
___.210.
Subpart B--Audits
___.200 Audit requirements.
(a) Audit required. Non-Federal entities that expend $300,000 ($500,000
for fiscal years ending after December 31, 2003) or more in a year in
Federal awards shall have a single or program-specific audit conducted for
that year in accordance with the provisions of this part. Guidance on
determining Federal awards expended is provided in ___.205.
(b) Single audit. Non-Federal entities that expend $300,000 ($500,000 for
fiscal years ending after December 31, 2003) or more in a year in Federal
awards shall have a single audit conducted in accordance with ___.500
except when they elect to have a program-specific audit conducted in
accordance with paragraph (c) of this section.
(c) Program-specific audit election. When an auditee expends Federal
awards under only one Federal program (excluding R&D) and the Federal
program's laws, regulations, or grant agreements do not require a
financial statement audit of the auditee, the auditee may elect to have a
program-specific audit conducted in accordance with ___.235. A
program-specific audit may not be elected for R&D unless all of the
Federal awards expended were received from the same Federal agency, or the
same Federal agency and the same pass-through entity, and that Federal
agency, or pass-through entity in the case of a subrecipient, approves in
advance a program-specific audit.
(d) Exemption when Federal awards expended are less than $300,000
($500,000 for fiscal years ending after December 31, 2003). Non-Federal
entities that expend less than $300,000 ($500,000 for fiscal years ending
after December 31, 2003) a year in Federal awards are exempt from Federal
audit requirements for that year, except as noted in ___.215(a), but
records must be available for review or audit by appropriate officials of
the Federal agency, pass-through entity, and General Accounting Office
(GAO).
(e) Federally Funded Research and Development Centers (FFRDC). Management
of an auditee that owns or operates a FFRDC may elect to treat the FFRDC
as a separate entity for purposes of this part.
___.205 Basis for determining Federal awards expended.
(a) Determining Federal awards expended. The determination of when an
award is expended should be based on when the activity related to the
award occurs. Generally, the activity pertains to events that require the
non-Federal entity to comply with laws, regulations, and the provisions of
contracts or grant agreements, such as: expenditure/expense transactions
associated with grants, cost-reimbursement contracts, cooperative
agreements, and direct appropriations; the disbursement of funds passed
through to subrecipients; the use of loan proceeds under loan and loan
guarantee programs; the receipt of property; the receipt of surplus
property; the receipt or use of program income; the distribution or
consumption of food commodities; the disbursement of amounts entitling the
non-Federal entity to an interest subsidy; and, the period when insurance
is in force.
(b) Loan and loan guarantees (loans). Since the Federal Government is at
risk for loans until the debt is repaid, the following guidelines shall be
used to calculate the value of Federal awards expended under loan
programs, except as noted in paragraphs (c) and (d) of this section:
(1) Value of new loans made or received during the fiscal year; plus
(2) Balance of loans from previous years for which the Federal Government
imposes continuing compliance requirements; plus
(3) Any interest subsidy, cash, or administrative cost allowance received.
(c) Loan and loan guarantees (loans) at institutions of higher education.
When loans are made to students of an institution of higher education but
the institution does not make the loans, then only the value of loans made
during the year shall be considered Federal awards expended in that year.
The balance of loans for previous years is not included as Federal awards
expended because the lender accounts for the prior balances.
(d) Prior loan and loan guarantees (loans). Loans, the proceeds of which
were received and expended in prior-years, are not considered Federal
awards expended under this part when the laws, regulations, and the
provisions of contracts or grant agreements pertaining to such loans
impose no continuing compliance requirements other than to repay the
loans.
(e) Endowment funds. The cumulative balance of Federal awards for
endowment funds which are federally restricted are considered awards
expended in each year in which the funds are still restricted.
(f) Free rent. Free rent received by itself is not considered a Federal
award expended under this part. However, free rent received as part of an
award to carry out a Federal program shall be included in determining
Federal awards expended and subject to audit under this part.
(g) Valuing non-cash assistance. Federal non-cash assistance, such as free
rent, food stamps, food commodities, donated property, or donated surplus
property, shall be valued at fair market value at the time of receipt or
the assessed value provided by the Federal agency.
(h) Medicare. Medicare payments to a non-Federal entity for providing
patient care services to Medicare eligible individuals are not considered
Federal awards expended under this part.
(i) Medicaid. Medicaid payments to a subrecipient for providing patient
care services to Medicaid eligible individuals are not considered Federal
awards expended under this part unless a State requires the funds to be
treated as Federal awards expended because reimbursement is on a
cost-reimbursement basis.
(j) Certain loans provided by the National Credit Union Administration.
For purposes of this part, loans made from the National Credit Union Share
Insurance Fund and the Central Liquidity Facility that are funded by
contributions from insured institutions are not considered Federal awards
expended.
___.210 Subrecipient and vendor determinations.
(a) General. An auditee may be a recipient, a subrecipient, and a vendor.
Federal awards expended as a recipient or a subrecipient would be subject
to audit under this part. The payments received for goods or services
provided as a vendor would not be considered Federal awards. The guidance
in paragraphs (b) and (c) of this section should be considered in
determining whether payments constitute a Federal award or a payment for
goods and services.
(b) Federal award. Characteristics indicative of a Federal award received
by a subrecipient are when the organization:
(1) Determines who is eligible to receive what Federal financial
assistance;
(2) Has its performance measured against whether the objectives of the
Federal program are met;
(3) Has responsibility for programmatic decision making;
(4) Has responsibility for adherence to applicable Federal program
compliance requirements; and
(5) Uses the Federal funds to carry out a program of the organization as
compared to providing goods or services for a program of the pass-through
entity.
(c) Payment for goods and services. Characteristics indicative of a
payment for goods and services received by a vendor are when the
organization:
(1) Provides the goods and services within normal business operations;
(2) Provides similar goods or services to many different purchasers;
(3) Operates in a competitive environment;
(4) Provides goods or services that are ancillary to the operation of the
Federal program; and
(5) Is not subject to compliance requirements of the Federal program.
(d) Use of judgment in making determination. There may be unusual
circumstances or exceptions to the listed characteristics. In making the
determination of whether a subrecipient or vendor relationship exists, the
substance of the relationship is more important than the form of the
agreement. It is not expected that all of the characteristics will be
present and judgment should be used in determining whether an entity is a
subrecipient or vendor.
(e) For-profit subrecipient. Since this part does not apply to for-profit
subrecipients, the pass-through entity is responsible for establishing
requirements, as necessary, to ensure compliance by for-profit
subrecipients. The contract with the for-profit subrecipient should
describe applicable compliance requirements and the for-profit
subrecipient's compliance responsibility. Methods to ensure compliance for
Federal awards made to for-profit subrecipients may include pre-award
audits, monitoring during the contract, and post-award audits.
(f) Compliance responsibility for vendors. In most cases, the auditee's
compliance responsibility for vendors is only to ensure that the
procurement, receipt, and payment for goods and services comply with laws,
regulations, and the provisions of contracts or grant agreements. Program
compliance requirements normally do not pass through to vendors. However,
the auditee is responsible for ensuring compliance for vendor transactions
which are structured such that the vendor is responsible for program
compliance or the vendor's records must be reviewed to determine program
compliance. Also, when these vendor transactions relate to a major
program, the scope of the audit shall include determining whether these
transactions are in compliance with laws, regulations, and the provisions
of contracts or grant agreements.
___.215 Relation to other audit requirements.
(a) Audit under this part in lieu of other audits. An audit made in
accordance with this part shall be in lieu of any financial audit required
under individual Federal awards. To the extent this audit meets a Federal
agency's needs, it shall rely upon and use such audits. The provisions of
this part neither limit the authority of Federal agencies, including their
Inspectors General, or GAO to conduct or arrange for additional audits
(e.g., financial audits, performance audits, evaluations, inspections, or
reviews) nor authorize any auditee to constrain Federal agencies from
carrying out additional audits. Any additional audits shall be planned and
performed in such a way as to build upon work performed by other auditors.
(b) Federal agency to pay for additional audits. A Federal agency that
conducts or contracts for additional audits shall, consistent with other
applicable laws and regulations, arrange for funding the full cost of such
additional audits.
(c) Request for a program to be audited as a major program. A Federal
agency may request an auditee to have a particular Federal program audited
as a major program in lieu of the Federal agency conducting or arranging
for the additional audits. To allow for planning, such requests should be
made at least 180 days prior to the end of the fiscal year to be audited.
The auditee, after consultation with its auditor, should promptly respond
to such request by informing the Federal agency whether the program would
otherwise be audited as a major program using the risk-based audit
approach described in ___.520 and, if not, the estimated incremental
cost. The Federal agency shall then promptly confirm to the auditee
whether it wants the program audited as a major program. If the program is
to be audited as a major program based upon this Federal agency request,
and the Federal agency agrees to pay the full incremental costs, then the
auditee shall have the program audited as a major program. A pass-through
entity may use the provisions of this paragraph for a subrecipient.
___.220 Frequency of audits.
Except for the provisions for biennial audits provided in paragraphs (a)
and (b) of this section, audits required by this part shall be performed
annually. Any biennial audit shall cover both years within the biennial
period.
(a) A State or local government 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. This requirement must still be in effect for the
biennial period under audit.
(b) Any non-profit organization that had biennial audits for all biennial
periods ending between July 1, 1992, and January 1, 1995, is permitted to
undergo its audits pursuant to this part biennially.
___.225 Sanctions.
No audit costs may be charged to Federal awards when audits required by
this part have not been made or have been made but not in accordance with
this part. In cases of continued inability or unwillingness to have an
audit conducted in accordance with this part, Federal agencies and
pass-through entities shall take appropriate action using sanctions such
as:
(a) Withholding a percentage of Federal awards until the audit is
completed satisfactorily;
(b) Withholding or disallowing overhead costs;
(c) Suspending Federal awards until the audit is conducted; or
(d) Terminating the Federal award.
___.230 Audit costs.
(a) Allowable costs. Unless prohibited by law, the cost of audits made in
accordance with the provisions of this part are allowable charges to
Federal awards. The charges may be considered a direct cost or an
allocated indirect cost, as determined in accordance with the provisions
of applicable OMB cost principles circulars, the Federal Acquisition
Regulation (FAR) (48 CFR parts 30 and 31), or other applicable cost
principles or regulations.
(b) Unallowable costs. A non-Federal entity shall not charge the following
to a Federal award:
(1) The cost of any audit under the Single Audit Act Amendments of 1996
(31 U.S.C. 7501 et seq.) not conducted in accordance with this part.
(2) The cost of auditing a non-Federal entity which has Federal awards
expended of less than $300,000 ($500,000 for fiscal years ending after
December 31, 2003) per year and is thereby exempted under ___.200(d) from
having an audit conducted under this part. However, this does not prohibit
a pass-through entity from charging Federal awards for the cost of limited
scope audits to monitor its subrecipients in accordance with
___.400(d)(3), provided the subrecipient does not have a single audit.
For purposes of this part, limited scope audits only include agreed-upon
procedures engagements conducted in accordance with either the AICPA's
generally accepted auditing standards or attestation standards, that are
paid for and arranged by a pass-through entity and address only one or
more of the following types of compliance requirements: activities allowed
or unallowed; allowable costs/cost principles; eligibility; matching,
level of effort, earmarking; and, reporting.
___.235 Program-specific audits.
(a) Program-specific audit guide available. In many cases, a
program-specific audit guide will be available to provide specific
guidance to the auditor with respect to internal control, compliance
requirements, suggested audit procedures, and audit reporting
requirements. The auditor should contact the Office of Inspector General
of the Federal agency to determine whether such a guide is available. When
a current program-specific audit guide is available, the auditor shall
follow GAGAS and the guide when performing a program-specific audit.
(b) Program-specific audit guide not available.
(1) When a program-specific audit guide is not available, the auditee and
auditor shall have basically the same responsibilities for the Federal
program as they would have for an audit of a major program in a single
audit.
(2) The auditee shall 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 ___.315(b), and a corrective
action plan consistent with the requirements of ___.315(c).
(3) The auditor shall:
(i) Perform an audit of the financial statement(s) for the Federal program
in accordance with GAGAS;
(ii) Obtain an understanding of internal control and perform tests of
internal control over the Federal program consistent with the requirements
of ___.500(c) for a major program;
(iii) Perform procedures to determine whether the auditee has complied
with laws, regulations, and the provisions of contracts or grant
agreements that could have a direct and material effect on the Federal
program consistent with the requirements of ___.500(d) for a major
program; and
(iv) Follow up on prior audit findings, perform procedures to assess the
reasonableness of the summary schedule of prior audit findings prepared by
the auditee, and report, as a current year audit finding, when the auditor
concludes that the summary schedule of prior audit findings materially
misrepresents the status of any prior audit finding in accordance with the
requirements of ___.500(e).
(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. The auditor's report(s) shall state that the
audit was conducted in accordance with this part and include the
following:
(i) An opinion (or disclaimer of opinion) as to whether the financial
statement(s) of the Federal program is presented fairly in all material
respects in conformity with the stated accounting policies;
(ii) A report on internal control related to the Federal program, which
shall describe the scope of testing of internal control and the results of
the tests;
(iii) A report on compliance which includes an opinion (or disclaimer of
opinion) as to whether the auditee complied with laws, regulations, and
the provisions of contracts or grant agreements which could have a direct
and material effect on the Federal program; and
(iv) A schedule of findings and questioned costs for the Federal program
that includes a summary of the auditor's results relative to the Federal
program in a format consistent with ___.505(d)(1) and findings and
questioned costs consistent with the requirements of ___.505(d)(3).
(c) Report submission for program-specific audits.
(1) The audit shall be completed and the reporting required by paragraph
(c)(2) or (c)(3) of this section submitted within the earlier of 30 days
after receipt of the auditor's report(s), or nine months after the end of
the audit period, unless a longer period is agreed to in advance by the
Federal agency that provided the funding or a different period is
specified in a program-specific audit guide. (However, for fiscal years
beginning on or before June 30, 1998, the audit shall be completed and the
required reporting shall be submitted within the earlier of 30 days after
receipt of the auditor's report(s), or 13 months after the end of the
audit period, unless a different period is specified in a program-specific
audit guide.) Unless restricted by law or regulation, the auditee shall
make report copies available for public inspection.
(2) When a program-specific audit guide is available, the auditee shall
submit to the Federal clearinghouse designated by OMB the data collection
form prepared in accordance with ___.320(b), as applicable to a
program-specific audit, and the reporting required by the program-specific
audit guide to be retained as an archival copy. Also, the auditee shall
submit to the Federal awarding agency or pass-through entity the reporting
required by the program-specific audit guide.
(3) When a program-specific audit guide is not available, the reporting
package for a program-specific audit shall consist of the financial
statement(s) of the Federal program, a summary schedule of prior audit
findings, and a corrective action plan as described in paragraph (b)(2) of
this section, and the auditor's report(s) described in paragraph (b)(4) of
this section. The data collection form prepared in accordance with
___.320(b), as applicable to a program-specific audit, and one copy of
this reporting package shall be submitted to the Federal clearinghouse
designated by OMB to be retained as an archival copy. Also, when the
schedule of findings and questioned costs disclosed audit findings or the
summary schedule of prior audit findings reported the status of any audit
findings, the auditee shall submit one copy of the reporting package to
the Federal clearinghouse on behalf of the Federal awarding agency, or
directly to the pass-through entity in the case of a subrecipient. Instead
of submitting the reporting package to the pass-through entity, when a
subrecipient is not required to submit a reporting package to the
pass-through entity, the subrecipient shall provide written notification
to the pass-through entity, consistent with the requirements of
___.320(e)(2). A subrecipient may submit a copy of the reporting package
to the pass-through entity to comply with this notification requirement.
(d) Other sections of this part may apply. Program-specific audits are
subject to ___.100 through ___.215(b), ___.220 through ___.230,
___.300 through ___.305, ___.315, ___.320(f) through ___.320(j),
___.400 through ___.405, ___.510 through ___.515, and other referenced
provisions of this part unless contrary to the provisions of this section,
a program-specific audit guide, or program laws and regulations.
Subpart C--Auditees
___.300 Auditee responsibilities.
The auditee shall:
(a) Identify, in its accounts, all Federal awards received and expended
and the Federal programs under which they were received. Federal program
and award identification shall include, as applicable, the CFDA title and
number, award number and year, name of the Federal agency, and name of the
pass-through entity.
(b) Maintain internal control over Federal programs that provides
reasonable assurance that the auditee is managing Federal awards in
compliance with laws, regulations, and the provisions of contracts or
grant agreements that could have a material effect on each of its Federal
programs.
(c) Comply with laws, regulations, and the provisions of contracts or
grant agreements related to each of its Federal programs.
(d) Prepare appropriate financial statements, including the schedule of
expenditures of Federal awards in accordance with ___.310.
(e) Ensure that the audits required by this part are properly performed
and submitted when due. When extensions to the report submission due date
required by ___.320(a) are granted by the cognizant or oversight agency
for audit, promptly notify the Federal clearinghouse designated by OMB and
each pass-through entity providing Federal awards of the extension.
(f) Follow up and take corrective action on audit findings, including
preparation of a summary schedule of prior audit findings and a corrective
action plan in accordance with ___.315(b) and ___.315(c), respectively.
___.305 Auditor selection.
(a) Auditor procurement. In procuring audit services, auditees shall
follow the procurement standards prescribed by the Grants Management
Common Rule (hereinafter referred to as the "A-102 Common Rule") published
March 11, 1988 and amended April 19, 1995 [insert appropriate CFR
citation], Circular A-110, "Uniform Administrative Requirements for Grants
and Agreements with Institutions of Higher Education, Hospitals and Other
Non-Profit Organizations," or the FAR (48 CFR part 42), as applicable (OMB
Circulars are available from the Office of Administration, Publications
Office, room 2200, New Executive Office Building, Washington, DC 20503).
Whenever possible, auditees shall make positive efforts to utilize small
businesses, minority-owned firms, and women's business enterprises, in
procuring audit services as stated in the A-102 Common Rule, OMB Circular
A-110, or the FAR (48 CFR part 42), as applicable. In requesting proposals
for audit services, the objectives and scope of the audit should be made
clear. Factors to be considered in evaluating each proposal for audit
services include the responsiveness to the request for proposal, relevant
experience, availability of staff with professional qualifications and
technical abilities, the results of external quality control reviews, and
price.
(b) Restriction on auditor preparing indirect cost proposals. 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 restriction applies to the base year used in the preparation
of the indirect cost proposal or cost allocation plan and any subsequent
years in which the resulting indirect cost agreement or cost allocation
plan is used to recover costs. To minimize any disruption in existing
contracts for audit services, this paragraph applies to audits of fiscal
years beginning after June 30, 1998.
(c) Use of Federal auditors. Federal auditors may perform all or part of
the work required under this part if they comply fully with the
requirements of this part.
___.310 Financial statements.
(a) Financial statements. The auditee shall prepare financial statements
that reflect its financial position, results of operations or changes in
net assets, and, where appropriate, cash flows for the fiscal year
audited. The financial statements shall be for the same organizational
unit and fiscal year that is chosen to meet the requirements of this part.
However, organization-wide financial statements may also include
departments, agencies, and other organizational units that have separate
audits in accordance with ___.500(a) and prepare separate financial
statements.
(b) Schedule of expenditures of Federal awards. The auditee shall also
prepare a schedule of expenditures of Federal awards for the period
covered by the auditee's financial statements. While not required, the
auditee may choose to provide information requested by Federal awarding
agencies and pass-through entities to make the schedule easier to use. For
example, when a Federal program has multiple award years, the auditee may
list the amount of Federal awards expended for each award year separately.
At a minimum, the schedule shall:
(1) List individual Federal programs by Federal agency. For Federal
programs included in a cluster of programs, list individual Federal
programs within a cluster of programs. For R&D, total Federal awards
expended shall be shown either by individual award or by Federal agency
and major subdivision within the Federal agency. For example, the National
Institutes of Health is a major subdivision in the Department of Health
and Human Services.
(2) For Federal awards received as a subrecipient, the name of the
pass-through entity and identifying number assigned by the pass-through
entity shall be included.
(3) Provide total Federal awards expended for each individual Federal
program and the CFDA number or other identifying number when the CFDA
information is not available.
(4) Include notes that describe the significant accounting policies used
in preparing the schedule.
(5) To the extent practical, pass-through entities should identify in the
schedule the total amount provided to subrecipients from each Federal
program.
(6) Include, in either the schedule or a note to the schedule, the value
of the Federal awards expended in the form of non-cash assistance, the
amount of insurance in effect during the year, and loans or loan
guarantees outstanding at year end. While not required, it is preferable
to present this information in the schedule.
___.315 Audit findings follow-up.
(a) General. The auditee is responsible for follow-up and corrective
action on all audit findings. As part of this responsibility, the auditee
shall prepare a summary schedule of prior audit findings. The auditee
shall also prepare a corrective action plan for current year audit
findings. The summary schedule of prior audit findings and the corrective
action plan shall include the reference numbers the auditor assigns to
audit findings under ___.510(c). Since the summary schedule may include
audit findings from multiple years, it shall include the fiscal year in
which the finding initially occurred.
(b) Summary schedule of prior audit findings. The summary schedule of
prior audit findings shall report the status of all audit findings
included in the prior audit's schedule of findings and questioned costs
relative to Federal awards. The summary schedule shall also include audit
findings reported in the prior audit's summary schedule of prior audit
findings except audit findings listed as corrected in accordance with
paragraph (b)(1) of this section, or no longer valid or not warranting
further action in accordance with paragraph (b)(4) of this section.
(1) When audit findings were fully corrected, the summary schedule need
only list the audit findings and state that corrective action was taken.
(2) When audit findings were not corrected or were only partially
corrected, the summary schedule shall describe the planned corrective
action as well as any partial corrective action taken.
(3) When corrective action taken is significantly different from
corrective action previously reported in a corrective action plan or in
the Federal agency's or pass-through entity's management decision, the
summary schedule shall provide an explanation.
(4) When the auditee believes the audit findings are no longer valid or do
not warrant further action, the reasons for this position shall be
described in the summary schedule. A valid reason for considering an audit
finding as not warranting further action is that all of the following have
occurred:
(i) Two years have passed since the audit report in which the finding
occurred was submitted to the Federal clearinghouse;
(ii) The Federal agency or pass-through entity is not currently following
up with the auditee on the audit finding; and
(iii) A management decision was not issued.
(c) Corrective action plan. At the completion of the audit, the auditee
shall prepare a corrective action plan to address each audit finding
included in the current year auditor's reports. The corrective action plan
shall provide the name(s) of the contact person(s) responsible for
corrective action, the corrective action planned, and the anticipated
completion date. If the auditee does not agree with the audit findings or
believes corrective action is not required, then the corrective action
plan shall include an explanation and specific reasons.
___.320 Report submission.
(a) General. The audit shall be completed and the data collection form
described in paragraph (b) of this section and reporting package described
in paragraph (c) of this section shall be submitted within the earlier of
30 days after receipt of the auditor's report(s), or nine months after the
end of the audit period, unless a longer period is agreed to in advance by
the cognizant or oversight agency for audit. (However, for fiscal years
beginning on or before June 30, 1998, the audit shall be completed and the
data collection form and reporting package shall be submitted within the
earlier of 30 days after receipt of the auditor's report(s), or 13 months
after the end of the audit period.) Unless restricted by law or
regulation, the auditee shall make copies available for public inspection.
(b) Data Collection.
(1) The auditee shall submit a data collection form which states whether
the audit was completed in accordance with this part and provides
information about the auditee, its Federal programs, and the results of
the audit. The form shall be approved by OMB, available from the Federal
clearinghouse designated by OMB, and include data elements similar to
those presented in this paragraph. A senior level representative of the
auditee (e.g., State controller, director of finance, chief executive
officer, or chief financial officer) shall sign a statement to be included
as part of the form certifying that: the auditee complied with the
requirements of this part, the form was prepared in accordance with this
part (and the instructions accompanying the form), and the information
included in the form, in its entirety, are accurate and complete.
(2) The data collection form shall include the following data elements:
(i) The type of report the auditor issued on the financial statements of
the auditee (i.e., unqualified opinion, qualified opinion, adverse
opinion, or disclaimer of opinion).
(ii) Where applicable, a statement that reportable conditions in internal
control were disclosed by the audit of the financial statements and
whether any such conditions were material weaknesses.
(iii) A statement as to whether the audit disclosed any noncompliance
which is material to the financial statements of the auditee.
(iv) Where applicable, a statement that reportable conditions in internal
control over major programs were disclosed by the audit and whether any
such conditions were material weaknesses.
(v) The type of report the auditor issued on compliance for major programs
(i.e., unqualified opinion, qualified opinion, adverse opinion, or
disclaimer of opinion).
(vi) A list of the Federal awarding agencies which will receive a copy of
the reporting package pursuant to ___.320(d)(2) of OMB Circular A-133.
(vii) A yes or no statement as to whether the auditee qualified as a
low-risk auditee under ___.530 of OMB Circular A-133.
(viii) The dollar threshold used to distinguish between Type A and Type B
programs as defined in ___.520(b) of OMB Circular A-133.
(ix) The Catalog of Federal Domestic Assistance (CFDA) number for each
Federal program, as applicable.
(x) The name of each Federal program and identification of each major
program. Individual programs within a cluster of programs should be listed
in the same level of detail as they are listed in the schedule of
expenditures of Federal awards.
(xi) The amount of expenditures in the schedule of expenditures of Federal
awards associated with each Federal program.
(xii) For each Federal program, a yes or no statement as to whether there
are audit findings in each of the following types of compliance
requirements and the total amount of any questioned costs:
(A) Activities allowed or unallowed.
(B) Allowable costs/cost principles.
(C) Cash management.
(D) Davis-Bacon Act.
(E) Eligibility.
(F) Equipment and real property management.
(G) Matching, level of effort, earmarking.
(H) Period of availability of Federal funds.
(I) Procurement and suspension and debarment.
(J) Program income.
(K) Real property acquisition and relocation assistance.
(L) Reporting.
(M) Subrecipient monitoring.
(N) Special tests and provisions.
(xiii) Auditee Name, Employer Identification Number(s), Name and Title of
Certifying Official, Telephone Number, Signature, and Date.
(xiv) Auditor Name, Name and Title of Contact Person, Auditor Address,
Auditor Telephone Number, Signature, and Date.
(xv) Whether the auditee has either a cognizant or oversight agency for
audit.
(xvi) The name of the cognizant or oversight agency for audit determined
in accordance with ___.400(a) and ___.400(b), respectively.
(3) Using the information included in the reporting package described in
paragraph (c) of this section, the auditor shall complete the applicable
sections of the form. The auditor shall sign a statement to be included as
part of the data collection form that indicates, at a minimum, the source
of the information included in the form, the auditor's responsibility for
the information, that the form is not a substitute for the reporting
package described in paragraph (c) of this section, and that the content
of the form is limited to the data elements prescribed by OMB.
(c) Reporting package. The reporting package shall include the:
(1) Financial statements and schedule of expenditures of Federal awards
discussed in ___.310(a) and ___.310(b), respectively;
(2) Summary schedule of prior audit findings discussed in ___.315(b);
(3) Auditor's report(s) discussed in ___.505; and
(4) Corrective action plan discussed in ___.315(c).
(d) Submission to clearinghouse. All auditees shall submit to the Federal
clearinghouse designated by OMB the data collection form described in
paragraph (b) of this section and one copy of the reporting package
described in paragraph (c) of this section for:
(1) The Federal clearinghouse to retain as an archival copy; and
(2) Each Federal awarding agency when the schedule of findings and
questioned costs disclosed audit findings relating to Federal awards that
the Federal awarding agency provided directly or the summary schedule of
prior audit findings reported the status of any audit findings relating to
Federal awards that the Federal awarding agency provided directly.
(e) Additional submission by subrecipients.
(1) In addition to the requirements discussed in paragraph (d) of this
section, auditees that are also subrecipients shall submit to each
pass-through entity one copy of the reporting package described in
paragraph (c) of this section for each pass-through entity when the
schedule of findings and questioned costs disclosed audit findings
relating to Federal awards that the pass-through entity provided or the
summary schedule of prior audit findings reported the status of any audit
findings relating to Federal awards that the pass-through entity provided.
(2) Instead of submitting the reporting package to a pass-through entity,
when a subrecipient is not required to submit a reporting package to a
pass-through entity pursuant to paragraph (e)(1) of this section, the
subrecipient shall provide written notification to the pass-through entity
that: an audit of the subrecipient was conducted in accordance with this
part (including the period covered by the audit and the name, amount, and
CFDA number of the Federal award(s) provided by the pass-through entity);
the schedule of findings and questioned costs disclosed no audit findings
relating to the Federal award(s) that the pass-through entity provided;
and, the summary schedule of prior audit findings did not report on the
status of any audit findings relating to the Federal award(s) that the
pass-through entity provided. A subrecipient may submit a copy of the
reporting package described in paragraph (c) of this section to a
pass-through entity to comply with this notification requirement.
(f) Requests for report copies. In response to requests by a Federal
agency or pass-through entity, auditees shall submit the appropriate
copies of the reporting package described in paragraph (c) of this section
and, if requested, a copy of any management letters issued by the auditor.
(g) Report retention requirements. Auditees shall keep one copy of the
data collection form described in paragraph (b) of this section and one
copy of the reporting package described in paragraph (c) of this section
on file for three years from the date of submission to the Federal
clearinghouse designated by OMB. Pass-through entities shall keep
subrecipients' submissions on file for three years from date of receipt.
(h) Clearinghouse responsibilities. The Federal clearinghouse designated
by OMB shall distribute the reporting packages received in accordance with
paragraph (d)(2) of this section and ___.235(c)(3) to applicable Federal
awarding agencies, maintain a data base of completed audits, provide
appropriate information to Federal agencies, and follow up with known
auditees which have not submitted the required data collection forms and
reporting packages.
(i) Clearinghouse address. The address of the Federal clearinghouse
currently designated by OMB is Federal Audit Clearinghouse, Bureau of the
Census, 1201 E. 10th Street, Jeffersonville, IN 47132.
(j) Electronic filing. Nothing in this part shall preclude electronic
submissions to the Federal clearinghouse in such manner as may be approved
by OMB. With OMB approval, the Federal clearinghouse may pilot test
methods of electronic submissions.
Subpart D--Federal Agencies and Pass-Through Entities
___.400 Responsibilities.
(a) Cognizant agency for audit responsibilities. Recipients expending more
than $25 million ($50 million for fiscal years ending after December 31,
2003) a year in Federal awards shall have a cognizant agency for audit.
The designated cognizant agency for audit shall be the Federal awarding
agency that provides the predominant amount of direct funding to a
recipient unless OMB makes a specific cognizant agency for audit
assignment.
Following is effective for fiscal years ending on or before December 31,
2003: To provide for continuity of cognizance, the determination of the
predominant amount of direct funding shall be based upon direct Federal
awards expended in the recipient's fiscal years ending in 1995, 2000,
2005, and every fifth year thereafter. For example, audit cognizance for
periods ending in 1997 through 2000 will be determined based on Federal
awards expended in 1995. (However, for States and local governments that
expend more than $25 million a year in Federal awards and have previously
assigned cognizant agencies for audit, the requirements of this paragraph
are not effective until fiscal years beginning after June 30, 2000.)
Following is effective for fiscal years ending after December 31, 2003:
The determination of the predominant amount of direct funding shall be
based upon direct Federal awards expended in the recipient's fiscal years
ending in 2004, 2009, 2014, and every fifth year thereafter. For example,
audit cognizance for periods ending in 2006 through 2010 will be
determined based on Federal awards expended in 2004. (However, for 2001
through 2005, the cognizant agency for audit is determined based on the
predominant amount of direct Federal awards expended in the recipent's
fiscal year ending in 2000).
Notwithstanding the manner in which audit cognizance is determined, a
Federal awarding agency with cognizance for an auditee may reassign
cognizance to another Federal awarding agency which provides substantial
direct funding and agrees to be the cognizant agency for audit. Within 30
days after any reassignment, both the old and the new cognizant agency for
audit shall notify the auditee, and, if known, the auditor of the
reassignment. The cognizant agency for audit shall:
(1) Provide technical audit advice and liaison to auditees and auditors.
(2) Consider auditee requests for extensions to the report submission due
date required by ___.320(a). The cognizant agency for audit may grant
extensions for good cause.
(3) Obtain or conduct quality control reviews of selected audits made by
non-Federal auditors, and provide the results, when appropriate, to other
interested organizations.
(4) Promptly inform other affected Federal agencies and appropriate
Federal law enforcement officials of any direct reporting by the auditee
or its auditor of irregularities or illegal acts, as required by GAGAS or
laws and regulations.
(5) Advise the auditor and, where appropriate, the auditee of any
deficiencies found in the audits when the deficiencies require corrective
action by the auditor. When advised of deficiencies, the auditee shall
work with the auditor to take corrective action. If corrective action is
not taken, the cognizant agency for audit shall notify the auditor, the
auditee, and applicable Federal awarding agencies and pass-through
entities of the facts and make recommendations for follow-up action. Major
inadequacies or repetitive substandard performance by auditors shall be
referred to appropriate State licensing agencies and professional bodies
for disciplinary action.
(6) Coordinate, to the extent practical, audits or reviews made by or for
Federal agencies that are in addition to the audits made pursuant to this
part, so that the additional audits or reviews build upon audits performed
in accordance with this part.
(7) Coordinate a management decision for audit findings that affect the
Federal programs of more than one agency.
(8) Coordinate the audit work and reporting responsibilities among
auditors to achieve the most cost-effective audit.
(9) For biennial audits permitted under ___.220, consider auditee
requests to qualify as a low-risk auditee under ___.530(a).
(b) Oversight agency for audit responsibilities. An auditee which does not
have a designated cognizant agency for audit will be under the general
oversight of the Federal agency determined in accordance with ___.105.
The oversight agency for audit:
(1) Shall provide technical advice to auditees and auditors as requested.
(2) May assume all or some of the responsibilities normally performed by a
cognizant agency for audit.
(c) Federal awarding agency responsibilities. The Federal awarding agency
shall perform the following for the Federal awards it makes:
(1) Identify Federal awards made by informing each recipient of the CFDA
title and number, award name and number, award year, and if the award is
for R&D. When some of this information is not available, the Federal
agency shall provide information necessary to clearly describe the Federal
award.
(2) Advise recipients of requirements imposed on them by Federal laws,
regulations, and the provisions of contracts or grant agreements.
(3) Ensure that audits are completed and reports are received in a timely
manner and in accordance with the requirements of this part.
(4) Provide technical advice and counsel to auditees and auditors as
requested.
(5) Issue a management decision on audit findings within six months after
receipt of the audit report and ensure that the recipient takes
appropriate and timely corrective action.
(6) Assign a person responsible for providing annual updates of the
compliance supplement to OMB.
(d) Pass-through entity responsibilities. A pass-through entity shall
perform the following for the Federal awards it makes:
(1) Identify Federal awards made by informing each subrecipient of CFDA
title and number, award name and number, award year, if the award is R&D,
and name of Federal agency. When some of this information is not
available, the pass-through entity shall provide the best information
available to describe the Federal award.
(2) Advise subrecipients of requirements imposed on them by Federal laws,
regulations, and the provisions of contracts or grant agreements as well
as any supplemental requirements imposed by the pass-through entity.
(3) Monitor the activities of subrecipients as necessary to ensure that
Federal awards are used for authorized purposes in compliance with laws,
regulations, and the provisions of contracts or grant agreements and that
performance goals are achieved.
(4) Ensure that subrecipients expending $300,000 ($500,000 for fiscal
years ending after December 31, 2003) or more in Federal awards during the
subrecipient's fiscal year have met the audit requirements of this part
for that fiscal year.
(5) Issue a management decision on audit findings within six months after
receipt of the subrecipient's audit report and ensure that the
subrecipient takes appropriate and timely corrective action.
(6) Consider whether subrecipient audits necessitate adjustment of the
pass-through entity's own records.
(7) Require each subrecipient to permit the pass-through entity and
auditors to have access to the records and financial statements as
necessary for the pass-through entity to comply with this part.
___.405 Management decision.
(a) General. The management decision shall clearly state whether or not
the audit finding is sustained, the reasons for the decision, and the
expected auditee action to repay disallowed costs, make financial
adjustments, or take other action. If the auditee has not completed
corrective action, a timetable for follow-up should be given. Prior to
issuing the management decision, the Federal agency or pass-through entity
may request additional information or documentation from the auditee,
including a request for auditor assurance related to the documentation, as
a way of mitigating disallowed costs. The management decision should
describe any appeal process available to the auditee.
(b) Federal agency. As provided in ___.400(a)(7), the cognizant agency
for audit shall be responsible for coordinating a management decision for
audit findings that affect the programs of more than one Federal agency.
As provided in ___.400(c)(5), a Federal awarding agency is responsible
for issuing a management decision for findings that relate to Federal
awards it makes to recipients. Alternate arrangements may be made on a
case-by-case basis by agreement among the Federal agencies concerned.
(c) Pass-through entity. As provided in ___.400(d)(5), the pass-through
entity shall be responsible for making the management decision for audit
findings that relate to Federal awards it makes to subrecipients.
(d) Time requirements. The entity responsible for making the management
decision shall do so within six months of receipt of the audit report.
Corrective action should be initiated within six months after receipt of
the audit report and proceed as rapidly as possible.
(e) Reference numbers. Management decisions shall include the reference
numbers the auditor assigned to each audit finding in accordance with
___.510(c).
Subpart E--Auditors
___.500 Scope of audit.
(a) General. The audit shall be conducted in accordance with GAGAS. The
audit shall cover the entire operations of the auditee; or, at the option
of the auditee, such audit shall include a series of audits that cover
departments, agencies, and other organizational units which expended or
otherwise administered Federal awards during such fiscal year, provided
that each such audit shall encompass the financial statements and schedule
of expenditures of Federal awards for each such department, agency, and
other organizational unit, which shall be considered to be a non-Federal
entity. The financial statements and schedule of expenditures of Federal
awards shall be for the same fiscal year.
(b) Financial statements. The auditor shall determine whether the
financial statements of the auditee are presented fairly in all material
respects in conformity with generally accepted accounting principles. The
auditor shall also determine whether the schedule of expenditures of
Federal awards is presented fairly in all material respects in relation to
the auditee's financial statements taken as a whole.
(c) Internal control.
(1) In addition to the requirements of GAGAS, the auditor shall perform
procedures to obtain an understanding of internal control over Federal
programs sufficient to plan the audit to support a low assessed level of
control risk for major programs.
(2) Except as provided in paragraph (c)(3) of this section, the auditor
shall:
(i) Plan the testing of internal control over major programs to support a
low assessed level of control risk for the assertions relevant to the
compliance requirements for each major program; and
(ii) Perform testing of internal control as planned in paragraph (c)(2)(i)
of this section.
(3) 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)(2) of this section are not required for those compliance
requirements. However, the auditor shall report a reportable condition
(including whether any such condition is a material weakness) in
accordance with ___.510, assess the related control risk at the maximum,
and consider whether additional compliance tests are required because of
ineffective internal control.
(d) Compliance.
(1) In addition to the requirements of GAGAS, the auditor shall determine
whether the auditee has complied with laws, regulations, and the
provisions of contracts or grant agreements that may have a direct and
material effect on each of its major programs.
(2) The principal compliance requirements applicable to most Federal
programs and the compliance requirements of the largest Federal programs
are included in the compliance supplement.
(3) For the compliance requirements related to Federal programs contained
in the compliance supplement, an audit of these compliance requirements
will meet the requirements of this part. Where there have been changes to
the compliance requirements and the changes are not reflected in the
compliance supplement, the auditor shall determine the current compliance
requirements and modify the audit procedures accordingly. For those
Federal programs not covered in the compliance supplement, the auditor
should use the types of compliance requirements contained in the
compliance supplement as guidance for identifying the types of compliance
requirements to test, and determine the requirements governing the Federal
program by reviewing the provisions of contracts and grant agreements and
the laws and regulations referred to in such contracts and grant
agreements.
(4) The compliance testing shall include tests of transactions and such
other auditing procedures necessary to provide the auditor sufficient
evidence to support an opinion on compliance.
(e) Audit follow-up. The auditor shall follow-up on prior audit findings,
perform procedures to assess the reasonableness of the summary schedule of
prior audit findings prepared by the auditee in accordance with
___.315(b), and report, as a current year audit finding, when the auditor
concludes that the summary schedule of prior audit findings materially
misrepresents the status of any prior audit finding. The auditor shall
perform audit follow-up procedures regardless of whether a prior audit
finding relates to a major program in the current year.
(f) Data Collection Form. As required in ___.320(b)(3), the auditor shall
complete and sign specified sections of the data collection form.
___.505 Audit reporting.
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. The auditor's report(s) shall state that the audit was conducted
in accordance with this part and include the following:
(a) An opinion (or disclaimer of opinion) as to whether the financial
statements are presented fairly in all material respects in conformity
with generally accepted accounting principles and an opinion (or
disclaimer of opinion) as to whether the schedule of expenditures of
Federal awards is presented fairly in all material respects in relation to
the financial statements taken as a whole.
(b) A report on internal control related to the financial statements and
major programs. This report shall describe the scope of testing of
internal control and the results of the tests, and, where applicable,
refer to the separate schedule of findings and questioned costs described
in paragraph (d) of this section.
(c) A report on compliance with laws, regulations, and the provisions of
contracts or grant agreements, noncompliance with which could have a
material effect on the financial statements. This report shall also
include an opinion (or disclaimer of opinion) as to whether the auditee
complied with laws, regulations, and the provisions of contracts or grant
agreements which could have a direct and material effect on each major
program, and, where applicable, refer to the separate schedule of findings
and questioned costs described in paragraph (d) of this section.
(d) A schedule of findings and questioned costs which shall include the
following three components:
(1) A summary of the auditor's results which shall include:
(i) The type of report the auditor issued on the financial statements of
the auditee (i.e., unqualified opinion, qualified opinion, adverse
opinion, or disclaimer of opinion);
(ii) Where applicable, a statement that reportable conditions in internal
control were disclosed by the audit of the financial statements and
whether any such conditions were material weaknesses;
(iii) A statement as to whether the audit disclosed any noncompliance
which is material to the financial statements of the auditee;
(iv) Where applicable, a statement that reportable conditions in internal
control over major programs were disclosed by the audit and whether any
such conditions were material weaknesses;
(v) The type of report the auditor issued on compliance for major programs
(i.e., unqualified opinion, qualified opinion, adverse opinion, or
disclaimer of opinion);
(vi) A statement as to whether the audit disclosed any audit findings
which the auditor is required to report under ___.510(a);
(vii) An identification of major programs;
(viii)The dollar threshold used to distinguish between Type A and Type B
programs, as described in ___.520(b); and
(ix) A statement as to whether the auditee qualified as a low-risk auditee
under ___.530.
(2) Findings relating to the financial statements which are required to be
reported in accordance with GAGAS.
(3) Findings and questioned costs for Federal awards which shall include
audit findings as defined in ___.510(a).
(i) Audit findings (e.g., internal control findings, compliance findings,
questioned costs, or fraud) which relate to the same issue should be
presented as a single audit finding. Where practical, audit findings
should be organized by Federal agency or pass-through entity.
(ii) Audit findings which relate to both the financial statements and
Federal awards, as reported under paragraphs (d)(2) and (d)(3) of this
section, respectively, should be reported in both sections of the
schedule. 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.
___.510 Audit findings.
(a) Audit findings reported. The auditor shall report the following as
audit findings in a schedule of findings and questioned costs:
(1) Reportable conditions in internal control over major programs. The
auditor's determination of whether a deficiency in internal control is a
reportable condition for the purpose of reporting an audit finding is in
relation to a type of compliance requirement for a major program or an
audit objective identified in the compliance supplement. The auditor shall
identify reportable conditions which are individually or cumulatively
material weaknesses.
(2) Material noncompliance with the provisions of laws, regulations,
contracts, or grant agreements related to a major program. The auditor's
determination of whether a noncompliance with the provisions of laws,
regulations, contracts, or grant agreements is material for the purpose of
reporting an audit finding is in relation to a type of compliance
requirement for a major program or an audit objective identified in the
compliance supplement.
(3) Known questioned costs which are greater than $10,000 for a type of
compliance requirement for a major program. Known questioned costs are
those specifically identified by the auditor. In evaluating the effect of
questioned costs on the opinion on compliance, the auditor considers the
best estimate of total costs questioned (likely questioned costs), not
just the questioned costs specifically identified (known questioned
costs). The auditor shall also report known questioned costs when likely
questioned costs are greater than $10,000 for a type of compliance
requirement for a major program. In reporting questioned costs, the
auditor shall include information to provide proper perspective for
judging the prevalence and consequences of the questioned costs.
(4) Known questioned costs which are greater than $10,000 for a Federal
program which is not audited as a major program. Except for audit
follow-up, the auditor is not required under this part to perform audit
procedures for such a Federal program; therefore, the auditor will
normally not find questioned costs for a program which is not audited as a
major program. However, if the auditor does become aware of questioned
costs for a Federal program which is not audited as a major program (e.g.,
as part of audit follow-up or other audit procedures) and the known
questioned costs are greater than $10,000, then the auditor shall report
this as an audit finding.
(5) The circumstances concerning why the auditor's report on compliance
for major programs is other than an unqualified opinion, unless such
circumstances are otherwise reported as audit findings in the schedule of
findings and questioned costs for Federal awards.
(6) Known fraud affecting a Federal award, unless such fraud is otherwise
reported as an audit finding in the schedule of findings and questioned
costs for Federal awards. This paragraph does not require the auditor to
make an additional reporting when the auditor confirms that the fraud was
reported outside of the auditor's reports under the direct reporting
requirements of GAGAS.
(7) Instances where the results of audit follow-up procedures disclosed
that the summary schedule of prior audit findings prepared by the auditee
in accordance with ___.315(b) materially misrepresents the status of any
prior audit finding.
(b) Audit finding detail. Audit findings shall be presented in sufficient
detail for the auditee to prepare a corrective action plan and take
corrective action and for Federal agencies and pass-through entities to
arrive at a management decision. The following specific information shall
be included, as applicable, in audit findings:
(1) Federal program and specific Federal award identification including
the CFDA title and number, Federal award number and year, name of Federal
agency, and name of the applicable pass-through entity. When information,
such as the CFDA title and number or Federal award number, is not
available, the auditor shall provide the best information available to
describe the Federal award.
(2) The criteria or specific requirement upon which the audit finding is
based, including statutory, regulatory, or other citation.
(3) The condition found, including facts that support the deficiency
identified in the audit finding.
(4) Identification of questioned costs and how they were computed.
(5) Information to provide proper perspective for judging the prevalence
and consequences of the audit findings, such as whether the audit findings
represent an isolated instance or a systemic problem. Where appropriate,
instances identified shall be related to the universe and the number of
cases examined and be quantified in terms of dollar value.
(6) The possible asserted effect to provide sufficient information to the
auditee and Federal agency, or pass-through entity in the case of a
subrecipient, to permit them to determine the cause and effect to
facilitate prompt and proper corrective action.
(7) Recommendations to prevent future occurrences of the deficiency
identified in the audit finding.
(8) Views of responsible officials of the auditee when there is
disagreement with the audit findings, to the extent practical.
(c) Reference numbers. Each audit finding in the schedule of findings and
questioned costs shall include a reference number to allow for easy
referencing of the audit findings during follow-up.
___.515 Audit working papers.
(a) Retention of working papers. The auditor shall retain working papers
and reports for a minimum of three years after the date of issuance of the
auditor's report(s) to the auditee, unless the auditor is notified in
writing by the cognizant agency for audit, oversight agency for audit, or
pass-through entity to extend the retention period. When the auditor is
aware that the Federal awarding agency, pass-through entity, or auditee is
contesting an audit finding, the auditor shall contact the parties
contesting the audit finding for guidance prior to destruction of the
working papers and reports.
(b) Access to working papers. Audit working papers shall be made available
upon request to the cognizant or oversight agency for audit or its
designee, a Federal agency providing direct or indirect funding, or GAO at
the completion of the audit, as part of a quality review, to resolve audit
findings, or to carry out oversight responsibilities consistent with the
purposes of this part. Access to working papers includes the right of
Federal agencies to obtain copies of working papers, as is reasonable and
necessary.
___.520 Major program determination.
(a) General. The auditor shall use a risk-based approach to determine
which Federal programs are major programs. This risk-based approach shall
include consideration of: Current and prior audit experience, oversight by
Federal agencies and pass-through entities, and the inherent risk of the
Federal program. The process in paragraphs (b) through (i) of this section
shall be followed.
(b) Step 1.
(1) The auditor shall identify the larger Federal programs, which shall be
labeled Type A programs. Type A programs are defined as Federal programs
with Federal awards expended during the audit period exceeding the larger
of:
(i) $300,000 or three percent (.03) of total Federal awards expended in
the case of an auditee for which total Federal awards expended equal or
exceed $300,000 but are less than or equal to $100 million.
(ii) $3 million or three-tenths of one percent (.003) of total Federal
awards expended in the case of an auditee for which total Federal awards
expended exceed $100 million but are less than or equal to $10 billion.
(iii) $30 million or 15 hundredths of one percent (.0015) of total Federal
awards expended in the case of an auditee for which total Federal awards
expended exceed $10 billion.
(2) Federal programs not labeled Type A under paragraph (b)(1) of this
section shall be labeled Type B programs.
(3) The inclusion of large loan and loan guarantees (loans) should not
result in the exclusion of other programs as Type A programs. When a
Federal program providing loans significantly affects the number or size
of Type A programs, the auditor shall consider this Federal program as a
Type A program and exclude its values in determining other Type A
programs.
(4) For biennial audits permitted under ___.220, the determination of
Type A and Type B programs shall be based upon the Federal awards expended
during the two-year period.
(c) Step 2.
(1) The auditor shall identify Type A programs which are low-risk. For a
Type A program to be considered low-risk, it shall have been audited as a
major program in at least one of the two most recent audit periods (in the
most recent audit period in the case of a biennial audit), and, in the
most recent audit period, it shall have had no audit findings under
___.510(a). However, the auditor may use judgment and consider that audit
findings from questioned costs under ___.510(a)(3) and ___.510(a)(4),
fraud under ___.510(a)(6), and audit follow-up for the summary schedule
of prior audit findings under ___.510(a)(7) do not preclude the Type A
program from being low-risk. The auditor shall consider: the criteria in
___.525(c), ___.525(d)(1), ___.525(d)(2), and ___.525(d)(3); the
results of audit follow-up; whether any changes in personnel or systems
affecting a Type A program have significantly increased risk; and apply
professional judgment in determining whether a Type A program is low-risk.
(2) Notwithstanding paragraph (c)(1) of this section, OMB may approve a
Federal awarding agency's request that a Type A program at certain
recipients may not be considered low-risk. For example, it may be
necessary for a large Type A program to be audited as major each year at
particular recipients to allow the Federal agency to comply with the
Government Management Reform Act of 1994 (31 U.S.C. 3515). The Federal
agency shall notify the recipient and, if known, the auditor at least 180
days prior to the end of the fiscal year to be audited of OMB's approval.
(d) Step 3.
(1) The auditor shall identify Type B programs which are high-risk using
professional judgment and the criteria in ___.525. However, should the
auditor select Option 2 under Step 4 (paragraph (e)(2)(i)(B) of this
section), the auditor is not required to identify more high-risk Type B
programs than the number of low-risk Type A programs. Except for known
reportable conditions in internal control or compliance problems as
discussed in ___.525(b)(1), ___.525(b)(2), and ___.525(c)(1), a single
criteria in ___.525 would seldom cause a Type B program to be considered
high-risk.
(2) The auditor is not expected to perform risk assessments on relatively
small Federal programs. Therefore, the auditor is only required to perform
risk assessments on Type B programs that exceed the larger of:
(i) $100,000 or three-tenths of one percent (.003) of total Federal awards
expended when the auditee has less than or equal to $100 million in total
Federal awards expended.
(ii) $300,000 or three-hundredths of one percent (.0003) of total Federal
awards expended when the auditee has more than $100 million in total
Federal awards expended.
(e) Step 4. At a minimum, the auditor shall audit all of the following as
major programs:
(1) All Type A programs, except the auditor may exclude any Type A
programs identified as low-risk under Step 2 (paragraph (c)(1) of this
section).
(2) (i) High-risk Type B programs as identified under either of the
following two options:
(A) Option 1. At least one half of the Type B programs identified as
high-risk under Step 3 (paragraph (d) of this section), except this
paragraph (e)(2)(i)(A) does not require the auditor to audit more
high-risk Type B programs than the number of low-risk Type A programs
identified as low-risk under Step 2.
(B) Option 2. One high-risk Type B program for each Type A program
identified as low-risk under Step 2.
(ii) When identifying which high-risk Type B programs to audit as major
under either Option 1 or 2 in paragraph (e)(2)(i)(A) or (B), the auditor
is encouraged to use an approach which provides an opportunity for
different high-risk Type B programs to be audited as major over a period
of time.
(3) Such additional programs as may be necessary to comply with the
percentage of coverage rule discussed in paragraph (f) of this section.
This paragraph (e)(3) may require the auditor to audit more programs as
major than the number of Type A programs.
(f) Percentage of coverage rule. The auditor shall audit as major programs
Federal programs with Federal awards expended that, in the aggregate,
encompass at least 50 percent of total Federal awards expended. If the
auditee meets the criteria in ___.530 for a low-risk auditee, the auditor
need only audit as major programs Federal programs with Federal awards
expended that, in the aggregate, encompass at least 25 percent of total
Federal awards expended.
(g) Documentation of risk. The auditor shall document in the working
papers the risk analysis process used in determining major programs.
(h) Auditor's judgment. When the major program determination was performed
and documented in accordance with this part, the auditor's judgment in
applying the risk-based approach to determine major programs shall be
presumed correct. Challenges by Federal agencies and pass-through entities
shall only be for clearly improper use of the guidance in this part.
However, Federal agencies and pass-through entities may provide auditors
guidance about the risk of a particular Federal program and the auditor
shall consider this guidance in determining major programs in audits not
yet completed.
(i) Deviation from use of risk criteria. For first-year audits, the
auditor may elect to determine major programs as all Type A programs plus
any Type B programs as necessary to meet the percentage of coverage rule
discussed in paragraph (f) of this section. Under this option, the auditor
would not be required to perform the procedures discussed in paragraphs
(c), (d), and (e) of this section.
(1) A first-year audit is the first year the entity is audited under this
part or the first year of a change of auditors.
(2) To ensure that a frequent change of auditors would not preclude audit
of high-risk Type B programs, this election for first-year audits may not
be used by an auditee more than once in every three years.
___.525 Criteria for Federal program risk.
(a) General. The auditor's determination should be based on an overall
evaluation of the risk of noncompliance occurring which could be material
to the Federal program. The auditor shall use auditor judgment and
consider criteria, such as described in paragraphs (b), (c), and (d) of
this section, to identify risk in Federal programs. Also, as part of the
risk analysis, the auditor may wish to discuss a particular Federal
program with auditee management and the Federal agency or pass-through
entity.
(b) Current and prior audit experience.
(1) Weaknesses in internal control over Federal programs would indicate
higher risk. Consideration should be given to the control environment over
Federal programs and such factors as the expectation of management's
adherence to applicable laws and regulations and the provisions of
contracts and grant agreements and the competence and experience of
personnel who administer the Federal programs.
(i) A Federal program administered under multiple internal control
structures may have higher risk. When assessing risk in a large single
audit, the auditor shall consider whether weaknesses are isolated in a
single operating unit (e.g., one college campus) or pervasive throughout
the entity.
(ii) When significant parts of a Federal program are passed through to
subrecipients, a weak system for monitoring subrecipients would indicate
higher risk.
(iii) The extent to which computer processing is used to administer
Federal programs, as well as the complexity of that processing, should be
considered by the auditor in assessing risk. New and recently modified
computer systems may also indicate risk.
(2) Prior audit findings would indicate higher risk, particularly when the
situations identified in the audit findings could have a significant
impact on a Federal program or have not been corrected.
(3) Federal programs not recently audited as major programs may be of
higher risk than Federal programs recently audited as major programs
without audit findings.
(c) Oversight exercised by Federal agencies and pass-through entities.
(1) Oversight exercised by Federal agencies or pass-through entities could
indicate risk. For example, recent monitoring or other reviews performed
by an oversight entity which disclosed no significant problems would
indicate lower risk. However, monitoring which disclosed significant
problems would indicate higher risk.
(2) Federal agencies, with the concurrence of OMB, may identify Federal
programs which are higher risk. OMB plans to provide this identification
in the compliance supplement.
(d) Inherent risk of the Federal program.
(1) The nature of a Federal program may indicate risk. Consideration
should be given to the complexity of the program and the extent to which
the Federal program contracts for goods and services. For example, Federal
programs that disburse funds through third party contracts or have
eligibility criteria may be of higher risk. Federal programs primarily
involving staff payroll costs may have a high-risk for time and effort
reporting, but otherwise be at low-risk.
(2) The phase of a Federal program in its life cycle at the Federal agency
may indicate risk. For example, a new Federal program with new or interim
regulations may have higher risk than an established program with
time-tested regulations. Also, significant changes in Federal programs,
laws, regulations, or the provisions of contracts or grant agreements may
increase risk.
(3) The phase of a Federal program in its life cycle at the auditee may
indicate risk. For example, during the first and last years that an
auditee participates in a Federal program, the risk may be higher due to
start-up or closeout of program activities and staff.
(4) Type B programs with larger Federal awards expended would be of higher
risk than programs with substantially smaller Federal awards expended.
___.530 Criteria for a low-risk auditee.
An auditee which meets all of the following conditions for each of the
preceding two years (or, in the case of biennial audits, preceding two
audit periods) shall qualify as a low-risk auditee and be eligible for
reduced audit coverage in accordance with ___.520:
(a) Single audits were performed on an annual basis in accordance with the
provisions of this part. A non-Federal entity that has biennial audits
does not qualify as a low-risk auditee, unless agreed to in advance by the
cognizant or oversight agency for audit.
(b) The auditor's opinions on the financial statements and the schedule of
expenditures of Federal awards were unqualified. However, the cognizant or
oversight agency for audit may judge that an opinion qualification does
not affect the management of Federal awards and provide a waiver.
(c) There were no deficiencies in internal control which were identified
as material weaknesses under the requirements of GAGAS. However, the
cognizant or oversight agency for audit may judge that any identified
material weaknesses do not affect the management of Federal awards and
provide a waiver.
(d) None of the Federal programs had audit findings from any of the
following in either of the preceding two years (or, in the case of
biennial audits, preceding two audit periods) in which they were
classified as Type A programs:
(1) Internal control deficiencies which were identified as material
weaknesses;
(2) Noncompliance with the provisions of laws, regulations, contracts, or
grant agreements which have a material effect on the Type A program; or(3)
Known or likely questioned costs that exceed five percent of the total
Federal awards expended for a Type A program during the year.
Appendix A to Part __ - Data Collection Form (Form SF-SAC)
Appendix B to Part __ - Circular A-133 Compliance Supplement
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