AICPA Comments on Proposed Single Audit Revisions

July 18, 2013

Members that perform single audits of federal awards should be aware that the American Institute of CPAs (AICPA) sent comments to the U.S. Office of Management and Budget (OMB) on June 2, 2013, regarding proposed revisions to the rules for single audits of state and local governments and non-profit organizations; the OMB cost principles; and the federal administrative requirements for federal awards contained in Circular A-133.  The OMB proposal represents a significant grant reform effort on the part of the federal government and is the second step in a multi-step process in OMB's federal grants improvement initiative that began in 2012. 

In its comprehensive comment letter, the AICPA supported the overall direction of OMB’s proposed rule (Reform of Federal Policies Relating to Grants and Cooperative Agreements: Cost Principles and Administrative Requirements) and the related proposed guidance document (Proposed OMB Uniform Guidance: Cost Principles, Audit, and Administrative Requirements for Federal Awards).  The AICPA also expressed appreciation for OMB’s responsiveness to feedback provided by the AICPA in its April 30, 2012, comment letter on OMB’s related Advance Notice, Reform of Federal Policies Relating to Grants and Cooperative Agreements; Cost principles, and Administrative Requirements (Including Single Audit Act). 

Although generally supportive of the proposal, the AICPA offered 75 specific comments in its comment letter.  The AICPA identified significant concerns in a number of areas including the future effective date, federal capacity and coordination issues, and a lack of clarity around certain changes to the cost principles, indirect cost rules, and time and effort requirements.

The AICPA noted that its comments are based on what OMB has proposed to date.  Since the revisions to the OMB Compliance Supplement that are described in the proposals have yet to be developed and will have a “significant effect on the successful implementation of the audit provisions in the final regulations,” the AICPA urged OMB to expose the draft revisions for public comment.

Going forward, the AICPA will continue to monitor this project closely and work to ensure that the final single audit rules are clear, efficient and effective. 

More details about OMB’s proposed revisions can be found on the website of the AICPA’s Governmental Audit Quality Center.