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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

Personal Financial Planning & CPA/PFS Webcasts

Webcast Our webcasts give PFP section members and CPA/PFS credential holders the opportunity to learn about timely issues as well as interact with their peers.
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Overview An overview of the Personal Financial Planning Division.
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Tax Reform Resource Center

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Comment Letters for the March 10, 2017 Non-Compliance with Laws and Regulations Exposure Draft

Comment Letters Comment letters received by the PEEC on the March 10, 2017 exposure draft.
Published on May 22, 2017

GTs NOCLAR Comment Letter

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Statement on Standards in Personal Financial Planning Services

Exposure Draft Information on the Statement on Standards in Personal Financial Planning Services.
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Webcast Archive Our webcasts/podcasts/videos give PFP/PFS members the opportunity to learn about timely issues as well as interact with their fellow peers.
Published on May 22, 2017

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Directory Get connected to our comprehensive offerings related to NFP financial reporting, assurance, tax compliance, and governance.
Published on May 22, 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 22, 2017

Not-for-Profit Governance & Management Resources

Tools This page provides resources for not-for-profit board governance, including resources related to governance structure and responsibilities, risk management, financial oversight and audit committees.
Published on May 22, 2017

Not-for-Profit News and Publications

News Not-for-profit online publications cover timely news, topics and developments related to not-for-profit activities.
Published on May 22, 2017

GAQC Alert No. 335

Newsletter Register for Head Start Program Update Web Event on June 15th
Published on May 22, 2017

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