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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

Financial Reporting Framework for Small and Medium Size Entities

Overview Learn about the Financial Reporting Framework for Small- and Medium-Sized Entities (FRF for SMEs) and access toolkits for CPAs, small businesses and their financial statement users.
Published on May 23, 2017

Building a Cybersecurity Practice

Toolkit The PCPS Cybersecurity Toolkit provides learning resources, staff training tools, and tools to use with clients to assess their needs for Cybersecurity resources. Together, these tools will help your firm analyze your service opportunities and assist in building a Cybersecurity practice.
Published on May 23, 2017

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Overview The PCPS Firm Practice Management Center supports CPA firms in the everyday intricacies of running a practice.
Published on May 23, 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 May 23, 2017

Cybersecurity Resource Center

Tools Find information and links to valuable resources for CPAs providing cybersecurity advisory and assurance services.
Published on May 23, 2017

Attest interpretation no. 4 of AT-C section 105

Guidance Attest interpretation no. 4, Performing and Reporting on an Attestation Engagement Under Two Sets of Attestation Standards, of AT-C section 105, Concepts Common to All Attestation Engagements
Published on May 23, 2017

Recently Issued Attest Interpretations

Guidance Find recently issued interpretations of AT standards
Published on May 23, 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.
Published on May 22, 2017

Personal Financial Planning

Overview An overview of the Personal Financial Planning Division.
Published on May 22, 2017

ARSC Meeting Materials and Highlights

Meeting Materials Meeting materials for meetings of the Accounting and Review Services Committee.
Published on May 22, 2017

ASB Meeting Materials and Highlights

Meeting Materials This listing of recent and upcoming Auditing Standards Board meeting dates, includes links to agenda materials and meeting highlights.
Published on May 22, 2017

Tax Reform Resource Center

Overview The Tax Reform Resource Center will be updated frequently with news, analysis, resources and the information you need to understand how coming changes will affect you and your clients.
Published on May 22, 2017

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

Comment Letter GT' submitted a comment letter on the NOCLAR exposure draft.
Published on May 22, 2017

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