Applying the Uniform Guidance for Federal Awards in Your Single Audits

Recently, Diane Edelstein filmed a web-cast in New York City on behalf of the AICPA on “Applying the Uniform Guidance for Federal Awards in Your Single Audits”. This blog post provides some key information from that presentation on auditee responsibilities in complying with Single Audit requirements.

Key Considerations in Applying the Uniform Guidance to Single Audits

Does your organization require a Single Audit? If your organization receives over $750,000 in federal funding, you are responsible for complying with the newly issued Uniform Guidance, which establishes uniform administrative requirements, cost principles and audit requirements for federal awards to nonfederal entities. The Uniform Guidance replaces eight circulars including OMB Circular A-133 as the Single Audit compliance document your organization must follow. The Uniform Guidance applies to awards received on or after December 26, 2014 for administrative requirements and cost principles.

Some Key Differences Found in the Uniform Guidance for Your Organization to be Aware of

• The audit threshold has increased from $500,000 to $750,000.
• The Minimum Type A Program threshold has increased from $300,000 to $750,000.
• The term ‘contractor’ replaces the term ‘vendor’.
• Auditees must obtain and evaluate the auditor’s peer review reports during the audit procurement process.
• Corrective action plans and summary schedule of prior findings must address GAGAS findings.
• There is added auditee responsibility to take reasonable measures to safeguard protected personally identifiable information.
• A requirement has been added that a government-wide quality study must be performed every six years.

Key Compliance Responsibilities Your Organization Must Adhere To

• Identification of federal programs and understanding and complying with compliance requirements.
• Establishing and maintaining internal control over compliance.
• Evaluating and monitoring internal control over compliance.
• Taking corrective action when needed.

Per the Uniform Guidance you organization is responsible for preparing the SEFA (Schedule of Expenditures of Federal Awards).

What Must the SEFA Include at a Minimum?

• Federal Programs by Federal Agency
  -Clusters – the cluster name, list individual federal programs within a cluster of programs, and the applicable federal agency name.
• Federal Awards received as a sub-recipient – the name of the pass through entity and identifying number assigned to the pass-through entity.
• Total federal awards expended for each individual program and the CFDA number or other ID number.
• The total amount provided to sub-recipients from each federal program must be shown on the face.
• Federal awards expended for loan and loan guarantee program must go on the face of the SEFA.
• Notes to the SEFA must provide a description of the significant accounting policies used in preparing the SEFA, disclose whether or not your organization elected to use the 10 percent de minimis indirect cost rate, and when applicable disclose the outstanding ending balances of loans and loan guarantees.

Do you have questions regarding the Uniform Guidance? Please contact us to explore the implications for your organization.

Please note this summary is not meant to substitute for reading the Uniform Guidance in its entirety.