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Use of a Program-Specific Audit to Satisfy OMB Circular A-133 Audit Requirements 

Section 200 of Office of Management and Budget (OMB) Circular A –133 (Circular A –133) states that when an auditee expends federal awards under only one federal program (excluding research and development) and the federal program's laws, regulations, or grant agreements do not require a financial statement audit of the auditee, the auditee may elect to have a program-specific audit performed in accordance with section 235 of Circular A –133. Therefore, the auditor should determine whether there is a financial statement audit requirement before performing a program-specific audit. A program-specific audit may not be elected for research and development unless all federal awards expended were received from the same federal agency (or the same federal agency and the same pass-through entity) and that federal agency (or pass-through entity, in the case of a subrecipient) approves a program-specific audit in advance.

Program-Specific Audit Requirements

Circular A –133 requires program-specific audits to be subject to the following sections of Circular A –133 as they may apply to program-specific audits, unless contrary to the provisions of section 235 of Circular A –133, a federal program-specific audit guide, or the program's laws and regulations:

  • Purpose, definitions, audit requirements, basis for determining the federal awards expended, subrecipient and vendor determinations, and relation to other audit requirements (sections 100 through 215(b))

  • Frequency of audits, sanctions, and audit costs (sections 220 through 230)

  • Auditee responsibilities and auditor selection (sections 300 through 305)

  • Follow-up on audit findings (section 315)

  • Submission of report (sections 320(f) through 320(j))

  • Responsibilities of federal agencies and pass-through entities and management decisions (sections 400 through 405)



*An example of a situation where a program-specific audit would not be allowed would be a not-for-profit college that receives student financial aid (SFA) (and no other federal awards). That is because the Higher Education Act of 1965, as amended, requires institutions that receive SFA to undergo an annual financial statement audit.

Copyright © 2004 by the American Institute of Certified Public Accountants, Inc., New York, New York.

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AICPA Sends Congress Recommended Legislative Changes to New Partnership Audit Regime

Press Release The AICPA has submitted to Congress a set of recommended legislative changes to the new Partnership Audit Regime enacted as part of the Bipartisan Budget Act of 2015.
Published on November 17, 2017

Cybersecurity Resource Center

Tools Find information and links to valuable resources for CPAs providing cybersecurity advisory and assurance services.
Published on May 25, 2017

Assurance Research Advisory Group (ARAG) FAQs

FAQ The Assurance Research Advisory Group (ARAG) is a group of practitioners and academics formed in collaboration with the American Accounting Association (AAA).
Published on May 25, 2017

Archived 2017 Governmental Audit Quality Center Annual Update Webcast

Presentation This Governmental Audit Quality Center (GAQC) Webcast, GAQC Annual Update, will provide member participants with a summary of the key issues that should be considered as part of planning for the 2017 audit season. Remember that the GAQC membership requirements for CPA firms and State Audit Organizations (SAO) state that
Published on May 25, 2017

EBPAQC Homepage

Home To help CPAs meet the challenges of performing quality audits in this unique and complex area, the AICPA has established the Employee Benefit Plan Audit Quality Center, a firm-based voluntary membership center for firms that audit employee benefit plans.
Published on May 25, 2017

Women in the Profession Resources

Tools We have developed several formal (workshop, publication and research) and informal (guides and DVDs) resources to help CPA firms and companies develop and retain their in-house talents. See additional resources for further details.
Published on May 25, 2017

Form Alliances with Other Firms

Article Explore ideas for developing your peer network and leveraging that network to grow your firm by providing the services your clients need.
Published on May 25, 2017

Building a Cybersecurity Practice

Toolkit The PCPS Cybersecurity Toolkit provides learning resources, staff training tools, and tools to use with clients to assess their needs for Cybersecurity resources. Together, these tools will help your firm analyze your service opportunities and assist in building a Cybersecurity practice.
Published on May 25, 2017

PCPS TIC Ethics Standards Comment Letters

Comment Letters TIC Comment Letters provide the PCPS Technical Issues Committee’s (TIC) views on proposed technical standards affecting small businesses. This page contains TIC comment letters on proposed standards from the AICPA Professional Ethics Division.
Published on May 25, 2017

Governmental Audit Quality Center

Home The Governmental Audit Quality Center promotes the importance of quality governmental audits and the value of such audits to purchasers of governmental audit services. GAQC is a voluntary membership center for CPA firms and state audit organizations that perform governmental audits.
Published on May 25, 2017

GAQC CPE & Events

Overview Find information about upcoming Center Web events, AICPA Governmental conferences, and links to past Center Web events, Webcasts and calls.
Published on May 25, 2017

Not-for-Profit CPE, Events & Programs

Article AICPA Not-for-Profit Section members receive exclusive discounts on AICPA NFP products and resources. Join today, and take advantage of your Section-member discounts on other CPE events and publications.
Published on May 25, 2017

EBPAQC 401(k) Basics, Part 2 - Participant Data & Contribution Testing

Presentation EBPAQC 401(k) Basics, Part 2 - Participant Data & Contribution Testing Presentation
Published on May 25, 2017

EBPAQC 401(k) Basics, Part 1 Introduction and Planning

Presentation EBPAQC 401(k) Basics, Part 1 Introduction and Planning
Published on May 25, 2017

The EDGE Newsletter

Newsletter The EDGE Newsletter, is dedicated to providing tips and tools of interest to young professionals, including articles on building career resiliency, networking for success, and de-prioritizing the immediate to focus on the important.
Published on May 25, 2017

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