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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

CPA Examination Score Release Timeline

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Estate Planning

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Published on August 17, 2017

Draft 2017 OMB Compliance Supplement Available for Audit Planning

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Published on August 17, 2017

Practice Issue Noted With Auditee Corrective Action Plan and Summary Schedule of Prior Audit Findings

Article This article discusses concerns that auditees are not preparing a separate Corrective Action Plan (CAP) and Summary Schedule of Prior Audit Findings (SSPAF) as required by §200.511 of, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards at 2 CFR 200 (Uniform Guidance).  Both the CAP and the
Published on August 17, 2017

GAQC CPE & Events

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Published on August 17, 2017

Audit Practice Tools and Aids

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Published on August 17, 2017

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Published on August 17, 2017

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Published on August 17, 2017

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Logo The AICPA Marketing Tool Kit provides members with various high and low resolution versions of the new International Associate of AICPA logo.
Published on August 17, 2017

Church Hill Classics

Article AICPA offers member discounts on Church Hill Classics products and services.
Published on August 17, 2017

Bob Veres E-Columns

Newsletter In his e-columns, Bob Veres explores topics that help you serve your clients better, and create a more efficient, effective and profitable practice.
Published on August 17, 2017

AICPA Associate Membership Logos

Logo The AICPA Marketing Tool Kit provides members with various high and low resolution versions of the new Associate Member of AICPA logo.
Published on August 17, 2017

The Forensic and Valuation Services Center

Home The Forensic and Valuation Services Center provides CPAs with  resources for forensic and valuation services and member benefits.
Published on August 17, 2017

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