Sneak Preview: OMB Proposes To Raise Single Audit Threshold to $1 Million
(The following was excerpted from a recent Thompson Grants Compliance Expert article.) In its recently proposed revisions to the uniform guidance, the Office of Management and Budget (OMB) is proposing to raise the single audit threshold from $750,000 in federal awards expended within a fiscal year to $1 million, the first increase in the single audit threshold (§200.501) since the guidance (2 C.F.R. Part 200) was first issued in 2013.
“OMB reviewed audit submission data as well as economic data when determining the increase to this threshold,” the agency explained in the proposed guidance published in the Oct. 5 Federal Register. “Every two years, the director of OMB is authorized to adjust the dollar amount of this threshold consistent with the purposes of the Single Audit Act, provided the director does not make such adjustments below $300,000.” In turn, the agency notes in §200.501 that a nonfederal entity that does not expend $1 million in federal awards in a fiscal year would be exempt from a single audit (§200.501(e)).
The increased audit threshold was one of several proposed revisions made throughout Subpart F of the uniform guidance to meet OMB’s goal in updating the guidance, to address administrative priorities, offer streamlining, and reduce burdens for agencies and recipients. (Editor's note: Thompson Grants editors are covering the key changes within the recently proposed revisions to the uniform guidance. Articles on Subpart C (pre-award); Subpart D (post-award); and Subpart E (cost principles) are available in the "News" section of Thompson Grants Compliance Expert.)
OMB also proposes to clarify in §200.502(b) that, when determining what types of federal awards are expended, loan and loan guarantees retain their federal character through the end of the federal award period of performance unless otherwise specified in statute or federal agency regulations. It also would clarify in §200.502(g) that federal noncash assistance (such as free rent, food commodities, donated property or donated surplus property that is received as part of a federal award to carry out a federal program) must be valued at fair market value at the time of receipt, or at the assessed value provided by the federal agency, and must be included in determining the total amount of federal award.
In §200.507(c), OMB proposed to simplify the language for submitting program-specific audits to read: “Unless a different period is specified in the program-specific audit guide, the audit must be submitted within 30 calendar days after receiving the auditor’s report(s) or nine months after the end of the audit period (whichever is earlier). The reporting package is due the next business day when the due date falls on a Saturday, Sunday or federal holiday.”
(The full version of this story has now been made available to all for a limited time here.)
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