Subpart F: Audit Requirements

Summary: Subpart F outlines the "Single Audit" process, a comprehensive annual review required for any entity spending more than $750,000 in federal funds. This "system-wide" audit replaces the need for dozens of individual agency audits, providing a holistic view of the municipality's financial health. It mandates that auditors evaluate both the financial statements and the "compliance" with the specific requirements of each major grant program. The results of this audit are made public in the "Federal Audit Clearinghouse," affecting the entity's future "Risk Profile." This subpart ensures that there is a "remedy" for non-compliance, requiring "Corrective Action Plans" for every finding. For the municipality, Subpart F is the "final exam" that validates their stewardship of federal tax dollars. It is the ultimate mechanism for ensuring "Audit-Ready" compliance across all disaster recovery projects.

Subpart F governs the "Single Audit" process, the final gatekeeper for grant closure. It requires entities expending more than $1,000,000 (updated threshold) in federal funds to undergo an independent audit of their financial statements and compliance. CFOs are responsible for the accuracy of the SEFA and the swift resolution of any findings to prevent "high-risk" status in future disasters.

  • Key Takeaways & Call to Action:
  • SEFA Accuracy: Prepare a Schedule of Expenditures of Federal Awards (SEFA) that accurately identifies the FEMA Project Worksheet numbers and Assistance Listing numbers.
  • Audit Follow-Up: Implement a Corrective Action Plan (CAP) for any finding within 30 days to demonstrate management's commitment to compliance.
  • Auditor Selection: Follow the procurement standards in §200.317-327 when selecting an audit firm to ensure the audit cost itself remains eligible.
  • CTA: Reconcile the SEFA against the General Ledger quarterly to ensure all disaster expenditures are captured and audit-ready.

  • §200.501 Audit Requirements
  • Call to Action: You must arrange for a "Single Audit" if your total federal expenditures exceed $750,000 in a single fiscal year. This section is essential because it is a statutory requirement; failure to perform this audit results in the suspension of all current and future federal funding. The audit provides an independent "seal of approval" that your financial management systems are working as intended. It identifies "material weaknesses" before they become catastrophic failures, allowing for early correction. This section ensures that the municipality remains a "Low-Risk Auditee," which streamlines future grant applications.

2 CFR 200 UNIFORM GUIDANCE

Subpart F: Audit Requirements

200.501 Audit requirements

Mandates a Single Audit or Program-Specific Audit for entities expending $1,000,000 or more in Federal awards during a fiscal year.

Determines the legal trigger for high-level oversight; failure to conduct this audit is a material breach of the grant agreement.

200.502 Basis for determining Federal awards expended

Details how to calculate the value of Federal awards used (including loans, property, and interest subsidies) to see if the $1M threshold is met.

Ensures accurate reporting of total federal exposure; miscalculating this figure can lead to missed audit requirements and subsequent legal penalties.

200.503 Relation to other audit requirements

Clarifies that the Single Audit is intended to meet all Federal audit needs, though agencies may conduct additional 'for cause' reviews.

Reduces administrative burden by providing a 'standard' audit that all agencies must generally accept as the primary compliance check.

200.507 Program-specific audits

Allows for a specific program audit instead of a full Single Audit when a recipient expends Federal awards under only one Federal program.

Provides a streamlined and less costly compliance path for specialized or smaller entities with a narrow scope of federal funding.

200.508 Auditee responsibilities

Requires the recipient to procure the audit, prepare financial statements, and follow up on audit findings.

The mechanical anchor of compliance; the recipient—not the auditor—is legally responsible for the accuracy of the financial reporting.

200.510 Financial statements

Mandates the preparation of a Schedule of Expenditures of Federal Awards (SEFA) and a summary of prior audit findings.

The SEFA is the primary document used by auditors to verify that every federal dollar is accounted for and spent on eligible activities.

200.511 Audit findings follow-up

Requires the auditee to prepare a corrective action plan for current findings and a summary schedule of prior findings.

Ensures that systemic management failures are actually fixed; repeating the same finding in subsequent years can lead to the termination of funding.

200.512 Report submission

Sets strict deadlines for submitting the audit report to the Federal Audit Clearinghouse (FAC) (earlier of 30 days after receipt or 9 months after fiscal year end).

Late submission is a major red flag for federal agencies and can trigger immediate suspension of all current and future award payments.

200.513 Responsibilities

Defines the roles of the 'Cognizant Agency' for audit and the 'Oversight Agency' for audit.

Provides a clear hierarchy of federal oversight, ensuring the recipient knows which specific agency has the final authority on their audit status.

200.514 Scope of audit

Requires the audit to be conducted in accordance with GAGAS and cover the entire organization's financial operations and compliance.

Ensures the audit is deep enough to identify fraud or waste across the whole entity, protecting the integrity of the federal grant system.

200.516 Audit findings

Specifies that auditors must report significant deficiencies, material weaknesses, and all questioned costs exceeding $25,000.

The high-stakes results of the audit; findings in this category often lead to mandatory cost disallowances and repayment of funds.

200.521 Management decision

Requires the Federal agency to issue a decision on audit findings within six months of the audit report being accepted.

Provides the final 'verdict' on whether questioned costs are officially disallowed and establishes the repayment timeline for the recipient.