4E5 - Single Audit Act

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University of Illinois, Chicago *

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435

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Accounting

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Nov 24, 2024

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4E5 – Single Audit Act Reporting Objectives of a Single Audit Engagement - Audit of F/S in accordance with Yellow Book/GAGAS - Audit of Schedule of Expenditures of Federal Awards o In relation to the F/S as a whole, in accordance with SASs - Report on Internal Control Over Compliance related to major programs – NO assurance expressed - Report on Compliance for Each Major Program o Reasonable assurance about whether noncompliance that could have a direct and material effect on a major federal program occurred Defining Federal Awards - Federal financial assistance and federal cost-reimbursement contracts that auditees receive directly from federal awarding agencies or indirectly from pass-through entities - Procurement contracts excluded - Federal program = Federal awards under same CFDA number, or from same agency for same purpose o Catalogue of Federal Domestic Assistance (CFDA) - OMB Circular defined program clusters Non-Cash Considerations - Food stamps, donated surplus property, etc. o Free rent received alone – NO o Free rent received as part of a federal award to carry out a federal program – YES - Generally value at FMV at time of receipt or the assessed value provided by the federal agency Recent Significant Changes Related to Federal Awards - On December 25, 2013, the OMB released 2 CFR Chapter I, Chapter II, Part 200 o Et al. Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards; Final Rule - Note : We will refer to this guidance as “Revised OMB Guidance” throughout Who Will be Affected by Revised OMB Guidance? - Federal agencies - States and local governments - Not-for-profits - Institutions of higher education - Indian tribes Consolidation of Multiple OMB Circulars - The Revised OMB Guidance supersedes and consolidates requirements from 8 existing OMB circulars into 1 document. - Including OMB Circular A-133, Audits of States, Local Governments and Non-Profit Organizations o The core structure of the single audit process will remain unchanged, but how the process is applied is changed
An Increase in the Single Audit Threshold - For fiscal years beginning before 1/1/15: o Nonfederal entities that expend $500,000 or more in a year in federal awards are REQUIRED to have a single or program-specific audit - For fiscal years beginning on or after 1/1/15: o Nonfederal entities that expend $750,000 or more in a year in federal awards required to have a single or program-specific audit - Estimated that 87% of entities will continue to have audits under The Revised OMB Guidance Changes to the Major Program Determination Process - Under OMB Circular A-133, auditors uses a 4-step risk-based major program determination process o Calculates a threshold based on the amount of federal dollars expended o Above which programs are designated as “type A” programs and below which are “type B” programs o Follows a prescribed process to assess program risk to identify which programs will be audited as major programs - The Revised OMB Guidance retains the prior process, but makes changes to each of the 4 steps OMB Circular A-133 – Step 1 of the Major Program Determination Process - For fiscal years beginning before 1/1/15: o Entities with total federal awards expended of $10 million or less the type A threshold is $300,000 in federal awards expended o For entities with total federal awards expended over $10 million the $300,000 threshold starts to increase Revised OMB Guidance – Changes to Step 1 of the Major Program Determination Process - The Revised OMB Guidance is changing the sliding scale threshold used to determine type A and type B programs. The new sliding threshold is illustrated below: Total federal awards expended: Type A/B threshold: Equal to $750,000 but < $25 million $750,000 Exceed $25 million but < $100 million Total federal awards expended times .03 Exceed $100 million but < $1 billion $3 million Exceed $1 billion but < $10 billion Total federal awards expended times .003 Exceed $10 billion but < $20 billion $30 million Exceed $20 billion Total federal awards expended time .0015 Safe Harbor Guidance Related to Step 1 and Large Loan and Loan Guarantees - When federal program loans > 4 X’s the largest non-loan program, considered a large loan o MUST consider this a Type A program o Exclude value in determining the threshold for other Type A programs - Considered a federal program loan if value of federal awards expended for loans within the program is 50% or more of the total federal awards expended for the program o Cluster of programs treated as one program
Step 2 of the Major Program Determination Process: Low-Risk Type A Programs OMB Circular A-133 Revised OMB Type A program low-risk if both: Type A program low-risk if both: - Audited as a major program in at least 1 of 2 most recent years - Audited as a major program in at least 1 of 2 most recent years - NO audit finding in most recent audit, UNLESS judged inconsequential under auditor judgment - No material weaknesses, NO modified compliance opinion, or NO questioned costs >5% of total awards expended Step 3 of the Major Program Determination Process: High-Risk Type B Programs OMB Circular A-133 Revised OMB - 2 options are available based on specified formulas - NOT REQUIRED to identify more high-risk Type B programs than at least 25% of number of low-risk Type A programs - Assess risk until number of programs reached Step 3 of the Major Program Determination Process: Inconsequential Type B Programs OMB Circular A-133 Revised OMB - Generally ONLY REQUIRED to perform risk assessments on Type B programs > $100,000 - Sliding scale for entities >$33,333,335 federal awards expended - Only REQUIRED to perform risk assessments on Type B programs >25% of Type A threshold determined in Step 1 Revised OMB Guidance: Changes to Step 4 of the Major Program Determination Process - Step 4 of the major program determination process relates to the actual selection of programs to be audited as a major o Select all the type A programs NOT identified as low-risk in Step 2 o Select the high-risk type B programs identified in Step 3 o Consider if there are any programs to be audited as major based on a federal agency request - The final step is the application of the percentage-of-coverage rule o Percentage-of-coverage rule applied in Step 4 will change due to Revised OMB Guidance Elimination of Certain Guidance in OMB A-133 Related to First Year Audits OMB Circular A-133 - MAY depart from four step process for first-year audits o First-year Single Audit or change in auditors - Elect all Type A programs plus Type B until percentage-of-coverage rule met - MAY only use once every 3 years Revised OMB - Does NOT allow for variation from four step process
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Step 4 of the Major Program Determination Process: Percentage-of Coverage Rule OMB Circular A-133 Revised OMB REQUIRES audit as major programs in the aggregate of: - 50% of total awards expended - 25% if a low-risk auditee REQUIRES audit as major program in the aggregate of: - 40% of total awards expended - 20% if a low-risk auditee Question #1 In accordance with Office of Management and Budget audit requirements for audits of non-Federal entities expending Federal awards, which of the following statements is accurate regarding Federal awards expended? a) Donated surplus property cannot be valued at the assessed value provided by the federal agency b) Food stamps cannot be valued at fair market value at the time of the receipt c) Government loans are classified as noncash assistance programs d) Free rents received as part of an award to carry out a federal program are treated as federal funds expended Question #2 Under 2 CFR Chapter I, Chapter II, Part 200 released in December 2013, the threshold for a single or program-specific audit of federal awards was established for nonfederal entities that expend _________ or more in a year in federal awards. a) $500,000 b) $750,000 c) $300,000 d) $100,000 Question #3 Which of the following is NOT a change in federal program compliance audit requirements resulting from implementation of 2 CFR Chapter I, Chapter II, Part 200? a) 8 different OMB Circulars were combined into 1 document b) Fewer federal programs will qualify as major programs requiring compliance testing c) Oversight and cognizant agencies have NO authority to provide subjective waivers allowing entities to qualify as low-risk auditees d) Type A programs are determined at a flat $300,000 threshold for all entities Question #4 Wolf is auditing an entity’s compliance with requirements governing a major federal financial assistance program in accordance with federal requirements. Wolf detected noncompliance with requirements that have a material effect on the program. Wolf’s report on compliance SHOULD express: a) No assurance on the compliance tests b) Reasonable assurance on the compliance tests c) A qualified or adverse opinion d) An adverse or disclaimer of opinion
Question #5 In auditing compliance with requirements governing major federal financial assistance programs under the Single Audit Act, the auditor’s consideration of materiality differs from materiality under generally accepted auditing standards. Under the Single Audit Act, materiality is: a) Calculated in relation to the financial statements taken as a whole b) Determine separately for each major federal financial assistance program c) Decided in conjunction with the auditor’s risk assessment d) Ignored, because all account balances, regardless of size, are fully tested