Single Audit Submissions
On December 26, 2013 the U.S. Office of Management and Budget (OMB) issued at 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (commonly known as “Uniform Guidance”), which supersedes and streamlines requirements from OMB Circulars A-21, A-87, A-110, and A-122; Circulars A-89, A-102, and A-133; and the guidance in Circular A-50 on Single Audit Act follow-up.
This Uniform Guidance was developed in response to the November 23, 2009 Executive Order 13520 on Reducing Improper Payments and February 28, 2011 Presidential Memorandum on Administrative Flexibility, Lower Costs, and Better Results of State, Local, and Tribal Governments. The Council on Financial Assistance Reform (COFAR) was established in October 2011 and has led several efforts to improve delivery, management, coordination, and accountability of Federal grants and cooperative agreements, which includes the development of the uniform guidance.
The audit requirements of 2 CFR Part 200, Subpart F (Subpart F) apply to audits of non-Federal entity fiscal years beginning on or after December 26, 2014 (i.e., audits for calendar year-end December 31, 2015 or fiscal year-end June 30, 2016). The revised audit requirements are not applicable to fiscal years beginning prior to that date. Early implementation is not permissible.
Links to the Uniform Guidance, training presentations, and training webcasts can be found at http://www.whitehouse.gov/omb/grants_docs
. Please continue to monitor the Office of the Budget website for additional information regarding this guidance and potential commonwealth specific guidance.
Purpose for Single Audit Submission
In accordance with the Subpart F and other relevant federal and commonwealth single audit policy and regulations, a subrecipient that expends $750,000 or more in federal awards during its fiscal year is required to provide the appropriate single or program-specific audit in accordance with the provisions outlined in 2 CFR Part 200.501.
Entities Required to Perform a Single Audit
§200.501 Audit requirements.
(a) Audit required. A non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single or program-specific audit conducted for that year in accordance with the provisions of this part.
(b) Single audit. A non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with §200.514 Scope of audit except when it elects 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 statutes, regulations, or the terms and conditions of the Federal award do not require a financial statement audit of the auditee, the auditee may elect to have a program-specific audit conducted in accordance with §200.507 Program-specific audits. 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 $750,000. A non-Federal entity that expends less than $750,000 during the non-Federal entity's fiscal year in Federal awards is exempt from Federal audit requirements for that year, except as noted in §200.503 Relation to other audit requirements, but records must be available for review or audit by appropriate officials of the Federal agency, pass-through entity, and Government Accountability 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.
(f) Subrecipients and Contractors. An auditee may simultaneously be a recipient, a subrecipient, and a contractor. Federal awards expended as a recipient or a subrecipient are subject to audit under this part. The payments received for goods or services provided as a contractor are not Federal awards. Section §200.330 Subrecipient and contractor determinations sets forth the considerations in determining whether payments constitute a Federal award or a payment for goods or services provided as a contractor.
(g) Compliance responsibility for contractors. In most cases, the auditee's compliance responsibility for contractors is only to ensure that the procurement, receipt, and payment for goods and services comply with Federal statutes, regulations, and the terms and conditions of Federal awards. Federal award compliance requirements normally do not pass through to contractors. However, the auditee is responsible for ensuring compliance for procurement transactions which are structured such that the contractor is responsible for program compliance or the contractor's records must be reviewed to determine program compliance. Also, when these procurement transactions relate to a major program, the scope of the audit must include determining whether these transactions are in compliance with Federal statutes, regulations, and the terms and conditions of Federal awards.
(h) 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 agreement with the for-profit subrecipient must 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 agreement, and post-award audits. See also §200.331 Requirements for pass-through entities.
Refer to the Federal Audit Clearinghouse’s site for required elements of Single Audit and Program-Specific Audit reporting packages.
Procedures for Submitting the Single Audit Report or Program-Specific Audit Report for Years Ending Prior to December 31, 2015 (in accordance with OMB Circular A-133 guidance)
Electronic submission is required for all reporting years ending prior to December 31, 2015. The reporting package must be submitted electronically in a single portable document format, or PDF, file to RA-BOASingleAudit@pa.gov
Steps for Submission
- Complete the Single Audit/Program Specific Audit Reporting Package Checklist (PDF) (Checklist) to ensure your package contains all required elements. Please click the Checklist link to retrieve the fillable version of the Checklist.
- Email the completed Single Audit or Program-Specific Audit Reporting Package and the Checklist in a single PDF file to RA-BOASingleAudit@pa.gov. The subject line of the email must identify the exact name on the Single Audit or Program-Specific Audit Reporting Package and the period end date to which the package applies.
- You will receive an email to confirm the receipt of the Single Audit or Program-Specific Audit Reporting Package and the completed Checklist.
Procedures for Submitting the Single Audit Report or Program-Specific Audit Report for the Year Ending December 31, 2015 and Subsequent Years (in accordance with Subpart F)
For single audit reports for the year ending December 31, 2015 and subsequent years, and in accordance with the new auditing and reporting requirements of Subpart F, §200.512 (3g), the FAC and the commonwealth each have responsibilities.
Federal Audit Clearinghouse Responsibilities
The FAC must make available to the public the reporting packages received in accordance with paragraph (c) of this section and §200.507 Program-specific audits, paragraph (c), except for Indian tribes exercising the option in (b)(2) of this section, and maintain a data base of completed audits, provide appropriate information to Federal agencies, and follow up with known auditees that have not submitted the required data collection forms and reporting packages.
Commonwealth of Pennsylvania Responsibilities
The Office of the Budget, Bureau of Audits (BOA) will no longer require auditees to submit Single Audit Reports for the year ending December 31, 2015 and subsequent years. To track the submission of the Single Audit Report to the FAC, BOA will require the auditee to email only the FAC confirmation of receipt, the certified copy of the data collection form, and the Checklist to RA-BOASingleAudit@pa.gov
Steps for Submission
- Submit the Single Audit or Program-Specific Audit Report to the FAC and receive an email confirmation of receipt from the FAC.
- Email the FAC confirmation of receipt, a certified copy of the data collection form, and the completed Checklist (PDF) to RA-BOASingleAudit@pa.gov. The subject line of the email must identify the exact name on the Single Audit or Program-Specific Audit Reporting Package and the period end date pertaining to the reporting package.
- You will receive an email from BOA confirming the receipt of the FAC’s confirmation, the certified copy of the data collection form, and the completed Checklist.
NOTE: Requests for information in accordance with the Right to Know Law (RTKL), must be submitted directly to OBRightToKnow@pa.gov. Requests sent to any other email address listed on this website will not be considered an official RTKL request.