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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.
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Comment Letters for the July 7, 2017 State And Local Government Entities Exposure Draft

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Enhancing Audit Quality

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Cybersecurity Resource Center

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October 2017 Reviewer Alert

Newsletter Download the October 2017 Reviewer Alert (PDF).
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Personal Financial Planning & CPA/PFS Webcasts

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Published on October 18, 2017

Top Financial and Tax Planning Ideas

Webcast Archive In this webcast, Bob Keebler, CPA/PFS will provide 50 ideas to generate Income Tax Alpha.
Published on October 18, 2017

Accounting Associations and Networks Directory

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Published on October 18, 2017

AICPA Gold Medal Award of Distinction Winners

Article The Gold Medal Award of Distinction recognizes a person whose influence on the accounting profession as a whole is especially notable in comparison to other industry leaders. * Indicates the award was given Posthumously
Published on October 18, 2017

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Article The AICPA Board of Directors acts as the executive committee for the governing Council which determines Institute programs and establishes general policies.
Published on October 18, 2017

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AICPA Board of Directors Meeting Minutes

Meeting Minutes The minutes of the AICPA Board of Directors Meetings provide information on what the Board is discussing at each of their regularly scheduled meetings.
Published on October 18, 2017

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