Treasury, Single Audit Compliance for Tribal Entities
Summary
A July 2023 Treasury Office of Recovery Programs presentation introducing Single Audits and the Compliance Supplement to award recipients. A Single Audit is required from every recipient that expends $750,000 or more in aggregate federal financial assistance within its fiscal year. The audit has two parts: an audit of the financial statements, policies and internal controls, and a test of compliance with the requirements of the federal awards. The auditor checks whether the recipient keeps an accounting system with adequate internal controls, presents financial statements in accordance with generally accepted accounting principles (GAAP) and submits accurate financial reports. Reporting packages are due to the Federal Audit Clearinghouse (FAC) at the earlier of 30 calendar days after receipt of the auditor's report or nine months after the fiscal year end.
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“Treasury, Single Audit Compliance for Tribal Entities.”
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OFFICE OF RECOVERY PROGRAMS
Introduction to Single Audits and the
Compliance Supplement
ORP Office of Grant Policy
July 2023
Single Audit Overview
What is a Single Audit?
• Single Audits are required from all recipients who expend $750,000 or
more in aggregate federal financial assistance within their fiscal year
• Single Audits are comprised of two main sections:
o Financial Statements: Audit of a recipient’s financial statements,
policies, documentation, and system of internal controls
o Programmatic Compliance Evaluation: Test of a recipient’s compliance
with the requirements of their federal awards which often assesses the
effectiveness of award spending and evaluate performance progress
Single Audit Objectives
What are the Objectives of Single Audits?
• Determines if the recipient (i.e., Auditee):
o Established an accounting system with adequate internal controls that
provide full accountability for assets, liabilities, revenues, and
expenditures
o Prepared financial statements which are presented fairly and in
accordance with generally accepted accounting principles (GAAP)
o Submitted financial reports, cash reports, and claims for advances and
reimbursements that contain accurate and reliable financial data, and
are presented in accordance with the terms and conditions of the
financial assistance awards’ agreements
o Expended federal funds in accordance with the terms of award
agreements and those provisions of federal law or regulations that
could have a material effect on the financial statements or on the
financial assistance awards tested
High-level Single Audit FAQs
Who Is Subject to a Single Audit?
• Auditees which meet the $750,000 expenditure threshold within their fiscal year
• Note: For-profit organizations and foreign entities are NOT subject to Single
Audits unless required due to unique circumstances
Who Conducts Single Audits?
• Independent Auditors procured or otherwise arranged by Auditees
When are Single Audits Conducted?
• An Auditee’s Single Audit is conducted after the conclusion of their fiscal year
• Single Audit reporting packages are due to the Federal Audit Clearinghouse (FAC)
the earlier between 30 calendar days after receipt of an Auditor’s report, or
within nine months after the Auditee’s fiscal year end
What Types of Programs are Subject to Single Audits?
• Programs that award federal financial assistance (e.g., grants, cooperative
agreements, direct payments for specified use awards, and loans)
Federal Level Single Audit Roles
OMB is responsible for issuance and GAO is responsible for issuance of the
maintenance of Single Audit Generally Accepted Government
regulations, annual Compliance Auditing Standards (GAGAS) and
Supplement, and coordinating with performing Government-wide reviews
federal awarding agencies and studies
Federal Awarding Agencies
DEPARTMENT OF THE TREASURY
The Federal Audit Clearinghouse (FAC)
collects and disseminates single and
program-specific audit reports and
information on-behalf of the OMB
Key Auditee Responsibilities (200.508-509; 200.303)
Auditees are responsible for arranging their Single Audits and ensuring they are
performed properly. Auditees must establish internal controls and evaluate or monitor
compliance with federal statutes, regulations, and the terms and conditions of their
awards.
Key Auditee responsibilities include:
(hire the Auditor)
Key Auditor Responsibilities (2 CFR 200.514; 200.516)
Auditors determine whether the Auditee’s internal control systems provide reasonable
assurance that it is managing federal awards in compliance with applicable laws,
regulations, and agreement terms.
Key Auditor responsibilities include:
*
**
*Generally Accepted Government Auditing Standards (GAGAS)
**Generally Accepted Accounting Principles (GAAP)
Auditee vs. Auditor Responsibilities Comparison
(2 CFR 200.303; 200.509-200.521; 200.514)
Auditee Responsibilities Auditor Responsibilities
•Establish and maintain effective internal control •Conduct audit in accordance with GAGAS, 2 CFR
over federal awards Part 200, Subpart F, and the Compliance
•Comply with federal statutes, regulations, and the Supplement, if applicable
terms and conditions of each award •Determine whether Auditee financial statements
•Procure and arrange for the audit are presented fairly in all material respects in
•Prepare financial statements and Schedule of conformity with GAAP
Expenditures of Federal Awards (SEFA) •Test the Auditee's internal controls
•Follow up and take corrective action on audit •Determine whether the Auditee complied with
findings identified by Auditors, including preparing applicable statutes, regulations, and terms and
a summary schedule of prior audit findings, and a conditions of federal awards
corrective action plan for current audit findings •Follow up on the status prior-year audit findings
•Submit the SF-SAC Data Collection Form, and the schedule and related corrective action plan (e.g.,
single audit report package to the Federal Audit implemented, in progress, or repeat)
Clearinghouse (FAC). Ensure the documents do not •Complete and sign the specified sections of the SF-
contain any personally identifiable information (PII) SAC in the FAC
Compliance Supplement Overview
What is the Compliance Supplement?
• 2 CFR Part 200, Subpart F – Audit Requirements includes broad instructions for
Agencies, Auditees (i.e., recipients, subrecipients), and Auditors for how to
conduct Single Audits and program-specific audits
• OMB issues the Compliance Supplement annually to provide Auditors with
guidance and program-specific instructions for how to evaluate Auditees that is
distinct from what is required in 2 CFR Part 200
• Prior to 2019, Auditors were required to evaluate 12 Compliance Requirements
for every major program based on the major program threshold for each Auditee
(also know as the Type A/B threshold)
• Since 2019, Agencies must identify up to 6 Compliance Requirements which
Auditors should evaluate for each program in the Compliance Supplement, this is
also known as A/B plus 5
• In the absence of a Compliance Supplement, Auditors evaluate all 12 Compliance
Requirements
Compliance Supplement Objectives and Impacts
Objectives Impacts
Non-Federal Entities
Resource to understand Single • Non-Federal entities are required to ensure
Audit Compliance Requirements that Auditors follow the Single Audit
and program-specific audit instructions in the Compliance Supplement
requirements
Auditors
Provides direction on which 6 of • Direction and testing instructions reduce
the 12 Compliance Requirements Auditor burden by narrowing the scope of
to focus testing for programs and Single Audits
how to test them • Auditors provide more in-depth, targeted
analysis on programs included in the
Compliance Supplement
Compliance Supplement Sections
2023 HAF Compliance Matrix View in the Supplement
Link to the 2023 HAF Compliance Supplement
COMPLIANCE REQUIREMENTS
HAF Compliance Requirements
A. Activities Allowed or Unallowed H. Period of Performance
B. Allowable Costs/Cost Principles L. Reporting
E. Eligibility M. Subrecipient Monitoring
G. Matching, Level of Effort, Earmarking
Single Audit Report Submission Package (2 CFR 200.515)
The Auditee is required to submit its Single Audit Report to the FAC within 30
calendar days after receipt of the Auditor’s report, or within nine months
after the close of the Auditee’s fiscal year, whichever is earlier.
Once the Single Audit is completed, the “report package” submitted to
Federal Audit Clearinghouse will include:
• Auditor’s report on the financial statements of the entity and SEFA evaluation
• Auditees financial statements and SEFA
• Auditor’s report(s) on internal control over financial reporting, compliance and
other GAGAS requirements
• Auditor’s report on compliance and internal control over compliance (major
programs)
• Auditor’s schedule of current findings and questioned costs
• Auditee’s summary schedule of prior-year audit findings, if applicable
• If available, the Auditee’s corrective action plan of current year findings
Questions and Contact Info
• Questions?
• Please direct any single audit questions to:
• Nasr Fahmy, ORP Single Audit Advisor
• 202-527-4036
• Nasr.Fahmy@treasury.gov
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