Federal & State Single Audit Issues
Presented By
William Blend, CPA, CFE
Topics
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Single Audit Basics
Recipient’s Danger Areas
Single Audit Findings
SEFA Issues
Grant Auditing
OMB Reform Ideas for Comment
Tips to Help Avoid Trouble
SINGLE AUDIT BASICS
Single Audit Basics (Con’t.)
• Objectives of a Single Audit
– To determine if the entity has complied with direct and
material compliance requirements of each major program
– Used as a report card by federal funding agencies and
pass-through entities
– Gives comfort to readers regarding compliance and
internal control over compliance
Single Audit Basics (Con’t.)
• To set standards for obtaining consistency and uniformity
among federal agencies for the audit of non-federal
entities expending federal awards
– Provides a snapshot into an organization’s financial and
grant program operations
– Focus on compliance requirements that have a direct and
material effect on major programs or state projects
– Not all programs and projects are tested
Single Audit Basics (Con’t.)
Frequency of Audits
• All audits required by OMB A-133 shall be performed
annually (exceptions)
• Submission to federal audit clearinghouse
– Within one month after completion of the single audit
– No later than 9 months after auditee’s fiscal year
Single Audit Basics (Con’t.)
1. Audit of financial statements and reporting on the
SEFA
2. Compliance audit of federal awards
•
The term “single audit” could be perceived as
misleading by some, since it appears reporting is
done related to “two” audits; one on the fair
presentation of the financial statements, and the
other on compliance with major federal programs…
Single Audit Basics (Con’t.)
• Conducted in accordance with Government
Auditing Standards (GAS)
• Covers entire operations of the organization
• Fairly presented financial statements
• Adequate internal control structure
• Compliance with laws and regulations
• Follow-up on prior audit findings
Single Audit Basics (Con’t.)
Components of the SEFA
Section 1
Section 2
Section 3
Summary of
auditor’s results
Financial
statement
findings
Federal award
findings and
questioned
costs
Single Audit Basics (Con’t.)
• Auditee Responsibilities
– Defined in OMB Circular A-133 Subpart C and FL
Single Audit Act
• Financial statements
• Schedule of expenditures of federal awards
• Summary schedule of prior audit findings
• Management’s views and corrective action plan
• Identify all awards received/expended; under
which program
Single Audit Basics (Con’t.)
• Auditee Responsibilities
– Defined in OMB Circular A-133 and FL Single Audit
Act
• Financial statements
• Schedule of expenditures of federal awards
• Summary schedule of prior audit findings
• Management’s views and corrective action plan
• Identify all awards received/expended; under
which program
Single Audit Basics (Con’t.)
• Auditee Responsibilities, con’t
• Maintain IC over federal programs
• Comply with laws, regulations, provisions of
contracts/grants
• Ensure Single Audit is performed and submitted
when due
• Follow up and take corrective action on audit
findings
Single Audit Basics (Con’t.)
Single audit reporting package
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Financial statements
Schedule of expenditures of federal awards (SEFA)
All applicable footnotes to both F/S and SEFA
Auditor's reports
Schedule of findings and questioned costs
Summary Schedule of Prior Audit Findings (if
applicable)
• Corrective Action Plan (if applicable)
• Data Collection Form (technically not part but
required to be filed)
Single Audit Basics (Con’t.)
• Auditor Responsibilities
– Defined in OMB Circular A-133 and FL Single Audit Act
• Audit the financial statements in accordance with
GAAS, GAGAS
• Understand internal control over Federal programs
to plan the audit to support low level of control
risk
• Test compliance with laws, regulations, provisions
of contract and grant agreements that are direct
and material to each major program
• Report findings in A-133 report
Single Audit Basics (Con’t.)
• Auditor Responsibilities, con’t
– Audit of the Schedule of Expenditures of Federal
Awards
• In relation to the financial statements taken as a
whole
• As a basis for the selection of major programs
Single Audit Basics (Con’t.)
Auditor’s Required Reports
 Financial Statement opinion(s)
 Compliance and I/C and over financial reporting
and other matters (Yellow Book)
 Compliance and I/C over major programs
(A-133 report)
RECIPIENT’S DANGER AREAS
Recipient’s Danger Areas
• Lack of understanding of Program/Project
compliance requirements
– Federal Regulations
– State Statutes / FAC
– Grant Agreements
• Lack of internal controls over compliance
– Prevent controls
– Detect controls
Recipient’s Danger Areas (Con’t.)
• Untimely or lack of reconciliation between
program reporting and accounting records
– General ledger
– Program/project reporting
• Failure to monitor subrecipients
– External audits do not eliminate responsibility
SINGLE AUDIT FINDINGS
Common Findings
• Schedule of Expenditures of Federal Awards
– Errors in information reported
– Amounts not reconciled to general ledger or financial
statements
– No centralized function to ensure completeness
• Federal Suspension & Debarment
– Lack of documentation
• Federal/State Reporting
– Reports not filed timely
– Reports not reconciled to general ledger
Common Findings (Con’t.)
• Eligibility
– Individuals not qualified
– Documentation inadequate
• Activities Allowed or Unallowed
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Overpayments not corrected
No certification that work was completed
Lack of documentation to support activities
Lack of documentation to support acquisition of
capital assets under state contract
– Lack of support to document review
Common Findings (Con’t.)
• Subrecipients
– Lack of monitoring
• Program Income
– Netted against expenditures on SEFA
– Not considered in subsequent draw downs
• Property Acquired
– Capital assets not identified as acquired with Federal
or state dollars
• Matching
– Wrong amounts allocated
Florida Auditor General on NFPs
• Finding No 1: Licensing of Auditors
– Verify that auditors hold active licenses
• Finding No. 2: Audit Report Reviews
– Ensure reports and schedules are submitted in
accordance with reporting requirements
Florida Auditor General on Local
Governments
• Notes describing accounting polices and
procedures not included.
• Auditor’s opinion on schedule of state assistance
not included.
• Incorrect reference in report on compliance to
Executive Office of Governor vs. Florida
Department of Financial Services
Florida Auditor General on Local
Governments
• Type of opinion issued on state projects not disclosed.
• Statement as to whether or not FS audit disclosed
other findings not included in the schedule of findings
and questioned costs as required by Section 10.557
Rules of Auditor General.
• Incorrect threshold reported to distinguish between
Type A and B state projects.
SEFA ISSUES
Schedule of Expenditures of Federal Awards
and State Financial Assistance (SEFA)
• SEFA is a client-prepared schedule
• Reports the total expenditures of federal awards and
state projects and serves as the primary basis for the
auditor’s major program/project determination
• Circular A-133 §.310(b) includes the requirements for
Federal Awards
• FAC Chapter 69I-5.003 includes the requirements for
State Financial Assistance
SEFA Terms
Federal
Florida State
Federal Award
State Financial Assistance
Federal Program
State Project
Catalog of Federal Domestic Assistance
(CFDA)
Catalog of State Financial Assistance
(CSFA)
Federal Agency
State Agency
Pass-through Entity
Pass-through Entity
Expenditures
Expenditures
Direct Programs
Direct Projects
Indirect Programs
Indirect Projects
Contract/Grant No.
Contract/Grant No.
Transfers to Subrecipients
Transfers to Subrecipients
SEFA Type A and B Determination
Federal
Florida State
Type (A):
Type (A):
$300,000 or 3% - If total federal awards
= or >$300,000 and = or <$100 million
$100,000 or 30% - If total state awards
are between $300,000 and $1,000,000
3 million or .3% - If total federal awards
>$100 million and = or <$10 billion
$300,000 or 3% - If total state awards
> $100 million
$30 million or .15% - If total federal
awards exceed $100 million
Type (B):
Type (B) (requrie risk evaluation):
$100,000 or .3% - If total federal awards
= or <$100 million
$50,000 or 10% - If total state awards
between $300,000 and $1,000,000
$300,000 or .03% - If total federal awards
>$100 million
$100,000 or 1% - If total state awards
>$100 ,000,000 million
Example Entity
Schedule of Expenditures of Federal Awards
For the Year Ended June 30, 20x1
Note that footnotes
have been excluded.
Federal Grantor/Pass-through Grantor/Program or Cluster Title
Federal
CFDA
Number
Pass-Through
Entity
Identifying
Number
Federal Expenditures
Department of Agriculture Direct Programs
Summer Food Service Program for Children - Commodities
Total Department of Agriculture Direct Programs
10.559
Department of Housing and Urban Development Direct Programs
Community Development Block Grants/Entitlement Grants
Section 8 Housing Choice Vouchers
Total Department of Housing and Urban Development Direct Programs
14.218
14.871
1,235,632
800,534
2,036,166
Department of Education Direct Programs
Impact Aid
Literacy Through School Libraries
Subtotal Department of Education Direct Programs
84.041
84.364
372,555
28,655
401,210
Department of Education Pass Through Programs From:
State Department of Education - Title I Grants to Local Educational Agencies
Total Department of Education
84.010
Total Expenditures of Federal Awards
$
23-8345-7612
46,000
46,000
1,239,398
1,640,608
$
3,722,774
SEFA Expenditure when to record
Federal Awards/State Financial Assistance
Basis for Determining When Expended
Grants, cost-reimbursement contracts, cooperative When the expenditure or expense transactions occur
agreements, and direct appropriations
(incurred vs. disbursed)
Amounts passed through to subrecipients
When the disbursement is made to the subrecipient
Loan and loan guarantees
When the loan proceeds are used
Donated property, including donated surplus
property
When the property is received
Food commodities
When the food commodities are distributed or
consumed
Interest subsidies
When amounts are disbursed, entitling the entity to
the subsidy
Insurance
When the insurance is in force
Endowments
When federally restricted amounts are held
Program income
When received or used
SEFA Reporting of Expenditures
 Based on amounts paid (full accrual)
 Should be reconciled to financial statements
 Commodities reflected at fair value
 Loans reflected at outstanding balances
 If program involves both federal and state dollars:
 Report separately, if separate program/project
 Report federal expenditures ONLY, if state is used for
matching
 Do not report in state section, if federal program
GRANT AUDITING
Audit Considerations
• Major programs are the programs we will audit
• Generally we audit the programs that are large, risky,
and new
• Major program determination is a prescription for
assessing the size, risk and newness of programs
• Basis for our budgets and thus our fees, so must be done
accurately, and done early in the process
• Additional programs can add large chunks of time to the
audit, so must keep the client informed of any changes
to major program determination
Entity Low-Risk, High-Risk Evaluation
• Determine if entity is a low-risk auditee
– Considerations for the two preceding years include:
• A-133 audit performed
• Unqualified opinion on Financial Statements and SEFA
• No Material Weaknesses noted
• No compliance findings that have a material impact on
a Type A program
• No known/likely question costs > 5% of total awards
expended on Type A program
Entity Low-Risk, High-Risk Evaluation
Significance of Low-Risk Determination
• Low-risk auditee determination dictates coverage of
SEFA required to be obtained by the auditor
– Low-Risk Auditee = 25%
– High-Risk Auditee = 50%
• After this is determined, auditor can begin the
process of selection of major programs
• Not applicable to state grants
Major Program Flow Chart
Step 1
Step 2
Step 3
Identify
"Type A"
programs
Identify lowrisk "Type
A"
programs
Identify
high-risk
"Type B"
programs
Step 4
Determine
major
programs
to audit
Audit Process
Identify Grant
for Testing
Review Grant
Documents
Review
Applicable
Compliance
Supplement
Identify Population
to Test
Determine/Create
Testing Procedures
Perform Tests
Determine
Direct and
Material
Evaluate Results
Risk Considerations
• Considerations for Assessing Risk:
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Weakness in internal control over compliance
Skill level of those responsible for program compliance
Administration under multiple internal control structures
System for monitoring subrecipients
Information systems utilized
Prior audit findings
Audited as a major program in the past
Reviews by oversight agency or pass-thru entity completed
recently
– Auditor judgment
What Determines Direct & Material
• First, Determine Applicable Compliance Requirements
– Part 2 – Matrix of Compliance Requirements
– Part 7 – Guidance for Auditing Programs Not Included
• Subjective Factors
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Personal views / auditor judgment
Experience
Accepted risk
Industry expectation
• Qualitative and quantitative factors
Cluster Consideration
• Similar requirements but different CFDA numbers can be clustered
based on the compliance supplement
• Treated as one program for major program determination and
testing
• Awards with the same CFDA number will also be clustered together
• Most common:
– Research and Development
– Student Financial Aid
– Homeland Security
– Special Education
• Part 5 of the Compliance Supplement for information on clusters
Finding Requirements
• Information to be included in findings:
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Information on program
Criteria or specific requirement
Condition
Questioned Cost
Context
Effect
Cause
Recommendation
Response of responsible officials and Corrective Action
Plan
Audit Quality
Steps to help ensure a quality Single Audit
• Audit firm must have quality, knowledgeable staff with
the right skills for your Yellow Book and single audits
• Access to all grant financial and program records
• Identification of all federal programs
Audit Quality
Steps to help ensure a quality Single Audit
• Access to key staff both financial and program level
• Clients should be actively involved – show interest
in process and ask questions
• Maintain open communications through all phases of
the process
AICPA Audit Guide: GAS/A-133 Audits
• Two main sections of the guide
– Chapters 2-4: Yellow Book audits
– Chapters 5-13: A-133 audits
– Chapter 14: Program-specific audits
• Appendices
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Single Audit Act
Circular A-133
Risk Assessment Standards
Schedule of changes from prior
edition
Audit Quality
AICPA – Governmental Audit Quality Center (GAQC)
• Dedicated Center Web site with a complete listing of CPA
firm members in your state
• Illustrative Auditor’s Reports with examples of
Government Auditing Standards, OMB Circular A-133
and HUD reports
• Web seminars, webcasts, and teleconferences
updating you on a variety of technical, legislative,
regulatory, and practice management subjects
OMB REFORM IDEAS
Background
Improving Regulation and Regulatory Review
• Tailor regulations to impose the least burden, while being consistent with
obtaining regulatory objectives
• Eliminate unnecessary and reforming requirements that are overly
burdensome
• Culmination of a year of work by the Fed and non-Fed financial assistance
community
• Currently federal reforms only
OMB Reform Ideas for Comment
A. Reforms to Audit Requirements
B. Reforms to Cost Principles
C. Reforms to Administrative Requirements
A. Reforms to Audit Requirements
Concentrating audit resolution and oversight resources
on higher-dollar, higher-risk awards
• <$1 million in federal awards would not be required to
conduct a Single Audit
• $1 million to $3 million in federal awards requires more
focused version of the Single Audit
• >$3 million in federal awards requires a full Single
Audit
A. Reforms to Audit Requirements (Con’t.)
Streamlining the universal compliance requirements in
the Circular A-133 Compliance Supplement
• The universal compliance requirements could be
streamlined to focus on proper stewardship of Federal
Funds
• Allows agencies to concentrate on the requirements
most essential to managing waste, fraud, and abuse,
and reducing improper payments
• Subset of compliance requirements would be targeted
(discussion of two)
A. Reforms to Audit Requirements (Con’t.)
Strengthening the guidance on audit follow-up for
Federal awarding agencies
• Designate a senior accountable agency official to oversee
the audit resolution process
• Implement audit-risk metrics
• Encourage agencies to engage in cooperative audit
resolution with recipients; and
• Take a proactive approach to resolving weaknesses and
deficiencies
A. Reforms to Audit Requirements (Con’t.)
Reducing burdens on pass-through entities and
subrecipients from audit follow-up
• Applicable to entities that receive grants and funds
through subawards
• Conduct audit follow-up of the subawards
• Eliminates duplicate audit follow-up work performed
by a pass-through entity
B. Reforms to Cost Principles
• For indirect (“facilities and administrative”) costs,
using flat rates instead of negotiated rates
• Exploring alternatives to time-and-effort reporting
requirements for salaries and wages
• Charging directly allocable administrative support as
a direct cost
B. Reforms to Cost Principles (Con’t.)
• Including the cost of certain computing devices as
allowable direct cost supplies
• Clarifying the threshold for an allowable, maximum
residual inventory of unused supplies
• Eliminating requirements to conduct studies of cost
reasonableness for large research facilities
B. Reforms to Cost Principles (Con’t.)
• Eliminating restrictions on use of indirect costs
recovered for depreciation or use allowances
• Eliminating requirements to conduct a leasepurchase analysis for interest costs and to provide
notice before relocating federally sponsored
activities from a debt-financed facility
• Eliminate requirements that printed “help-wanted”
advertising comply with particular specifications
B. Reforms to Cost Principles (Con’t.)
• Allowing for the budgeting for contingency funds for
certain awards
• Allowing for excess or idle capacity for certain
facilities, in anticipation of usage increases
• Allowing costs for efforts to collect improper
payment recoveries
B. Reforms to Cost Principles (Con’t.)
• Specifying that gains and/or losses due to
speculative financing arrangements are unallowable
• Providing nonprofit organizations an example for the
Certificate of Indirect Costs
• Providing nonprofit organizations with an example
of indirect cost proposal documentation
requirements
C. Reforms to Administrative Requirements
• Creating a consolidated, uniform set of
administrative requirements
• Requiring pre-award consideration of each
proposal's merit and each applicant’s financial risk
• Requiring agencies to provide 90-days’ notice of
funding opportunities
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C. Reforms to Administrative Requirements (Con’t.)
• Providing a standard format for announcements of
funding opportunities
• Reiterating that information collections are subject
to Paperwork Reduction Act approval
TIPS TO AVOID TROUBLE
General Tips to Help Ensure Compliance
• Identify all federal awards received and expended by program
• Maintain internal control over federal programs
• Comply with laws, regulations, and provisions of contracts or
grant agreements
• Prepare appropriate financial statements
• Ensure audits are properly performed and submitted when
due
• Prepare schedule of prior audit findings and corrective action
plan
General Tips to Help Ensure Compliance
(Con’t.)
– Ensure rigorous procurement processes
– Develop robust governance structures that support the
benefit of audits
– Consider the qualifications of your audit firm
– Evaluate the reasonableness of the firm’s anticipated
hours in relation to the proposed fee based on the work
to be performed
– Be well-educated about the Single Audit process and
what it requires of both auditees and auditors
Tips for Grant Managers
• Document your controls using COSO
• Make sure everyone in your organization knows
your control system
• Periodically, review the internal control system and
see if it is working
• Closely monitor new employees for strict
compliance with policies
First Step to Compliance
Which Circular Do I Follow?
Although there are six grant circulars, you are only covered by three of them,
depending on type of entity:
States, local governments, and Indian Tribes follow:
– A-87 for cost principles, Relocated to 2CFR, Part 225
– A-102 for administrative requirements (common rule), and
– A-133 for audit requirements
Educational Institutions (even if part of a State or local government) follow:
– A-21 for cost principles, Relocated to 2CFR, Part 200
– A-110 for administrative requirements, Relocated to 2 CFR, Part 215, and
– A-133 for audit requirements
First Step to Compliance (Con’t.)
Which Circular Do I Follow? (Con’t)
Non-Profit Organizations follow:
– A-122 for cost principles, Relocated to 2 CFR, Part 230
– A-110 for administrative requirements, Relocated to 2 CFR, Part 215 and
– A-133 for audit requirements
Subrecipient Monitoring
• Document Subrecipient vs. Vendor A-133 .210
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Determine eligibility
Performance measured against federal program objectives
Programmatic decision-making
Responsibility to adherence to federal compliance requirements
Carryout program of organization
vs.
Provides goods and services in normal course of business
Provides similar goods/services to many different purchasers
Operates in competitive environment
Goods/services are ancillary to operation of the federal program
Not subject to compliance requirements
Subrecipient Monitoring (Con’t.)
• Pass-through Entity Responsibility A-133 .400
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Identify CFDA # for each Subrecipient
Advise Subrecipient of federal and other requirements
Monitor activities of Subrecipient
Ensure that Subs that spend more than $500,0000 have Single
Audit
Make management decisions on all findings within 6 months of
issuance
Consider impact on own records of Subs’ findings
Require Subs to permit access to records
Keep Subs’ report submissions
Subrecipient Monitoring (Con’t.)
• Identify all subrecipients/federal pass-throughs
• Develop monitoring file
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Site visits
Contracts
Cross-agency info
A-133 reports
Correspondence on issue resolution
Tips on Time and Effort
• Time and Effort Reports:
– Get your employees into the habit of completing after-thefact, timely, credible documentation that represents a
reasonable estimate of the time worked on each grant
project
• Timely, Accurate Financial and Performance Reports:
– Late reports often indicate weaknesses in grant
management systems
– Late reports are ‘red flags’ that may invite scrutiny
Tips Cost Transfers and Credits
• Cost Transfers:
– Shifts of costs between programs look suspicious
– Those occurring close to the end of a project are particularly
suspect
• Applicable Credits:
– Don’t forget to subtract credits from your grant charges
before submitting to the awarding agencies
• Purchase discounts
• Rebates & refunds
• Contract settlements
Tips Cash Management & Property
Records
• Cash Management:
– Minimize the time elapsing between drawing down federal
cash under your letter of credit and disbursing it by check
– Credit any interest earned back to the federal government
• Property Records:
– Make sure your property records include all of the required
data elements outlined in Circulars A-102 and A-110
Tips Equipment Inventory and Procurement
• Equipment Inventory:
– Take inventory of all equipment that has been acquired
with federal funds (at least once every two years)
– Reconcile the inventory count to your property records
• Noncompetitive Procurement:
– If you award any contracts for goods or services on a solesource basis, prepare a written justification as to why you
proceeded with the transaction
• Example: Emergency, no responses
Tips on In-kind Contributions
• Over-Valuation of Third-Party, In-kind
Contributions:
– Carefully and reasonably estimate the fair
market value of services, supplies, equipment,
and facilities that you receive from third parties
and employ in a grant as part of your matching or
cost sharing
Results of Noncompliance
• Percentage of federal awards withheld until audit
completion
• Withholding/disallowing overhead costs
• Suspend federal awards
• Terminating federal award
QUESTIONS?