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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

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Article The Not-for-Profit Entities Revenue Recognition Task Force has been created to address issues which may arise due to FASB's new revenue recognition standard. Here you will find the issues identified and further discussion.
Published on December 04, 2016

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Article The Software Entities Revenue Recognition Task Force has been created to address issues which may arise due to FASB's new revenue recognition standard. Here you will find the issues identified and further discussion.
Published on December 04, 2016

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Article The Telecommunications Entities Revenue Recognition Task Force has been created to address issues which may arise due to FASB's new revenue recognition standard. Here you will find the issues identified and further discussion.
Published on December 04, 2016

Timeshare Entities Revenue Recognition Task Force

Article The Timeshare Entities Revenue Recognition Task Force has been created to address issues which may arise due to FASB's new revenue recognition standard. Here you will find the issues identified and further discussion.
Published on December 04, 2016

Revenue Recognition Task Force Implementation Issue Status

Report This document contains information on the status of revenue recognition implementation issues identified by select AICPA Revenue Recognition Task Forces.
Published on December 04, 2016

2017 PFP Summit An Experience for Leaders Among Leaders

Video Deepen professional relationships by attending the AICPA’s PFP Summit.  Experience lively discussions and interactive sessions;  compare notes with esteemed peers and enjoy nightly networking activities/
Published on December 02, 2016

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Overview AICPA is committed to promoting CPAs as the most trusted professional and premier providers of tax services. We offer information and resources related to tax return planning, preparation, examination and representation, with practice tools to assist with navigating the IRS, tax practice quality control and management, as well as guidance
Published on December 02, 2016

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