Single Audit Update for Not-for-Profit Organizations
Background of OMB A-133 Compliance Supplement
Each year, the Federal Government provides over $400 billion in grants to State, local and tribal governments, colleges, universities and other non-profit organizations (“non-Federal entities”). In order to ensure oversight of these grants, the Single Audit Act of 1984 (with amendment in 1996) was created which creates requirements for audits of non-Federal entities that control and issue federal financial assistance programs. Single audits are financial statement and federal awards’ audits of non-federal entities. They are intended to provide assurance to the federal government that award recipients are following program requirements. Single audits are required for organizations that expend $750,000 or more in federal funds during any fiscal year. Each federal agency can dictate what compliance requirements will be subject to audit. Therefore, compliance requirements are dependent on the type of award received.
The OMB A-133 Compliance Supplement (the “Supplement”) is a guide that identifies compliance requirements that the federal government expects to be considered as part of an audit required by the Single Audit Act. The Supplement is an extensive tool created by the Office of Management and Budget (“OMB”) of the United States federal government. It is used by auditors of federal assistance and federal grant programs, as well as their recipients, to determine compliance requirements, audit objectives, and suggested procedures.
2022 OMB A-133 Supplement
Annually, the Supplement is issued with updates for new and deleted federal programs. The OMB also makes changes to existing programs by other federal agencies. The latest Supplement, issued on May 11, 2022, is used to test Single Audit compliance for entities with a fiscal year ending on or after June 30, 2022.
The Matrix of Compliance Requirements (the “Matrix”) is included as Part 2 of the Supplement. The Matrix identifies the compliance requirements of the relevant programs that the federal government has determined are subject to audit.
The Matrix includes 12 requirements:
- Activities Allowed or Un-allowed
- Allowable Costs/Cost Principles
- Cash Management
- Equipment Real Property Management
- Matching, Level of Effort, Earmarking
- Period of Performance
- Procurement Suspension & Debarment
- Program Income
- Subrecipient Monitoring
- Special Tests and Provisions
Since issuance of the 2019 Compliance Supplement, each federal agency has been mandated by OMB to limit the number of compliance requirements subject to the audit to six. This six-requirement mandate continues to not apply to programs not included in the Supplement. Programs that are not included in the Supplement should continue to follow the framework in Part 7 of the Supplement. For 2022, there were minimal changes to the Matrix.
The Agency Program Requirements and Clusters of Programs are included as Parts 4 and 5 of the Supplement, respectively. The 2022 updates reflect program additions and deletions, program title changes, COVID-19 and statutory requirement updates, reference updates, and technical changes and corrections.
Several new programs were added to the Supplement this year
- Lead-Based Paint Capital Fund Program and Housing Related Hazards Capital Fund (section 14.888)
- Emergency Rental Assistance Program (21.023)
- Homeowner Assistance Fund Program (21.026)
- Coronavirus Capital Projects Fund (21.029)
- Emergency Connectivity Fund Program (32.009)
- Shuttered Venue Operators Grant (59.075)
- Family Violence Prevention and Services/Domestic Violence Shelter and Supportive Services (93.671)
Appendix IV of the Supplement includes a list of programs deemed to be higher risk. It states that auditors are not prohibited from determining that a program or other cluster that has been designated as high risk per the Supplement qualifies as a low-risk program if the following criteria are met:
- The program otherwise meets the criteria for a low-risk program
- The percentage of COVID-19 related funding in the program during the entity’s fiscal year is not material to the program as a whole.
In 2022, there are no changes to the normal risk assessment process for higher-risk programs.
Appendix VII includes additional guidance on COVID-19 funding for 2022. Subsections in this appendix include the definition of COVID-19 funding, treatment of donated personal protective equipment on the schedule of expenditures of federal awards, identification of compliance requirements for COVID-19 related awards, and more.
Summary and Sources
The Supplement is a critical tool for auditors of federal assistance programs. However, recipients of these program funds should also be aware of compliance requirements.
Single audits must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report(s) or nine months after the end of the audit period.
About the Author
The information contained within this article is provided for informational purposes only and is current as of the date published. Online readers are advised not to act upon this information without seeking the service of a professional accountant, as this article is not a substitute for obtaining accounting, tax, or financial advice from a professional accountant.