2012-09-13 A133 Audit Prep
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The document provides an overview of the requirements for non-profit organizations receiving over $500,000 in federal awards to undergo an A-133 audit. It discusses determining major programs, applicable compliance requirements, internal controls, and procedures auditors will perform to test compliance with each requirement. The presentation also lists reference materials and websites for additional information on A-133 audit requirements and federal grants management.
2012-09-13 A133 Audit Prep
- 1. Preparing for the A-133 Audit and Requirements for NFP Organizations Receiving Federal Awards Julie L. Jones, Accounting Services Partner September 13, 2012 Thrive. Grow. Achieve.
- 2. AGENDA OVERVIEW OF OMB CIRCULAR A-133 REVIEW OF SAMPLE REPORTS • Schedule of Federal Awards • Grant Tracking • Federal Financial Report • Drawdown Requests COMMON FINDINGS RESOURCES 2
- 3. OVERVIEW OF AN A-133 AUDIT • EXPEND MORE THAN $500,000 OF FEDERAL FUNDS IN ONE YEAR • THERE ARE 3 OPINIONS: • Audit of the Financial Statements and Schedule of Federal Awards • Compliance Audit • Internal Controls 3
- 4. DETERMINING A MAJOR PROGRAM • LOW RISK AUDITEE • CALCULATION OF TYPE A AND TYPE B PROGRAMS • RISK ASSESSMENT OF TYPE A PROGRAMS • RISK ASSESSMENT OF TYPE B PROGRAMS 4
- 5. COMPLIANCE REQUIREMENTS (MATRIX) 1. ACTIVITIES ALLOWABLE AND UNALLOWABLE 2. ALLOWABLE COSTS/COST PRINCIPLES (A-122) 3. CASH MANAGEMENT 4. DAVIS-BACON ACT 5. ELIGIBILITY 6. EQUIPMENT AND REAL PROPERTY MANAGEMENT 7. MATCHING, LEVEL OF EFFORT, AND EARMARKING 8. PERIOD OF AVAILABILITY OF FUNDS 5
- 6. COMPLIANCE REQUIREMENTS (CONTINUED) 9. PROCUREMENT AND SUSPENSION AND DEBARMENT 10. PROGRAM INCOME 11. REAL PROPERTY ACQUISITION AND RELOCATION ASSISTANCE 12. REPORTING 13. SUBRECIPIENT MONITORING 14. SPECIAL TESTS AND PROVISIONS 6
- 7. HOW TO DETERMINE WHICH REQUIREMENTS APPLY • COMPLIANCE MATRIX IN SUPPLEMENT • READ GRANT AGREEMENTS • DISCUSSIONS WITH INDIVIDUALS WITHIN ORGANIZATION • MAKE INQUIRIES OF GRANTING AGENCY PERSONNEL 7
- 8. INTERNAL CONTROLS • DEFINITION OF INTERNAL CONTROLS • SEGREGATION OF DUTIES • MANAGEMENT’S RESPONSIBILITY • USED IN THE DETECTION OF FRAUD 8
- 9. ACTIVITIES ALLOWABLE AND UNALLOWABLE/COST PRINCIPLES (A-122) INTERNAL CONTROL • Obtain an understanding of the internal control structure and test internal controls sufficient to support the low assessed level of control risk. COMPLIANCE • Gain an understanding of grant activities. • Review allowability in accordance w/ A-122. 9
- 10. CASH MANAGEMENT INTERNAL CONTROL • Obtain an understanding of the internal control structure and test internal controls sufficient to support the low assessed level of control risk. COMPLIANCE • Advances vs. Reimbursements • Test a sample of draw downs to determine that the internal control procedures are followed • Interest earned on advances 10
- 11. DAVIS BACON ACT INTERNAL CONTROL • Obtain an understanding of the internal control structure and test internal controls sufficient to support the low assessed level of control risk. COMPLIANCE • Select a sample of construction contracts and perform the following: – Verify that the required prevailing wage rate clauses were included – Verify that the contractor submitted weekly the required certified payrolls 11
- 12. ELIGILIBILITY INTERNAL CONTROL • Obtain an understanding of the internal control structure and test internal controls sufficient to support the low assessed level of control risk. COMPLIANCE • Eligibility for individuals • Eligibility for Group of Individuals or Area of Service Delivery • Eligibility for Sub-recipients 12
- 13. EQUIPMENT AND REAL PROPERTY MANAGEMENT INTERNAL CONTROL • Obtain an understanding of the internal control structure and test internal controls sufficient to support the low assessed level of control risk. COMPLIANCE • Inventory Management of Equipment • Physical inventory taken every two years • Trace selected purchases to property records • Physical inspection of the property • Disposition of Equipment and Real Property 13
- 14. MATCHING, LEVEL OF EFFORT INTERNAL CONTROL • Obtain an understanding of the internal control structure and test internal controls sufficient to support the low assessed level of control risk. COMPLIANCE • Verify that required matching contributions were met • Determine the source of matching contributions and verify that it is an allowable source • Verify the reasonableness of values assigned to in- kind contributions • Verify that the level of effort requirements and percentage or dollar requirements for earmarking are met 14
- 15. PERIOD OF AVAILABILITY INTERNAL CONTROL • Obtain an understanding of the internal control structure and test internal controls sufficient to support the low assessed level of control risk. COMPLIANCE • Review the grant documents to determine the period of availability. • Test a sample of transactions charged to the Federal award before, during, and after the end of period of availability. 15
- 16. PROCUREMENT AND SUSPENSION AND DEBARMENT INTERNAL CONTROL • Obtain an understanding of the internal control structure and test internal controls sufficient to support the low assessed level of control risk. • Obtain the Organization’s procurement policies and verify that the policies comply with federal requirements. COMPLIANCE • Verify that contract files exist and that they document a significant history of procurement including the following: • Rationale for the chosen method of procurement • Selection of contract type • Contractor selection or rejection • Basis of contract price • Cost or price analysis • Contract modifications • Justification for any limitation on competition • www.epls.gov 16
- 17. PROGRAM INCOME INTERNAL CONTROL • Obtain an understanding of the internal control structure and test internal controls sufficient to support the low assessed level of control risk. COMPLIANCE • Program income may be used in one of three ways and requires specific approval from the grantor: – deducted from outlays – added to the project budget – used to meet matching requirements 17
- 18. REAL PROPERTY ACQUISITION AND RELOCATION ASSISTANCE INTERNAL CONTROL • Obtain an understanding of the internal control structure and test internal controls sufficient to support the low assessed level of control risk. COMPLIANCE • Property Acquisitions – Appraisal, Negations, and Residential Relocations • Replacement Housing Payments • Rental or Downpayment Assistance • Business Relocations – Moving expenses and Business reestablishment expenses 18
- 19. REPORTING INTERNAL CONTROL • Obtain an understanding of the internal control structure and test internal controls sufficient to support the low assessed level of control risk. COMPLIANCE Financial Reports • Select a sample of reports and trace amounts reported to GL. • Review reports for clerical accuracy and timely filing. • Obtain written representation from management that the reports provided are true copies of the reports submitted to the grantor. Performance Reports • Verify that the data was accumulated and summarized in accordance with the stated criteria. 19
- 20. SUBRECIPIENT MONITORING INTERNAL CONTROL • Obtain an understanding of the internal control structure and test internal controls sufficient to support the low assessed level of control risk. COMPLIANCE • Ascertain whether the Organization has provided subrecipient’s with the necessary guidelines and has monitored the subrecipient’s activities and reports. • Obtain copies of each subrecipient’s audit report and verify that the effects of the subrecipient’s non- compliance are properly reflected in the pass-thru entity’s records. 20
- 21. SPECIAL TESTS INTERNAL CONTROL • Obtain an understanding of the internal control structure and test internal controls sufficient to support the low assessed level of control risk. TYPES OF SPECIAL TESTS • Examples from a DHHS Grant: – Review Panel must consist a minimum of 5 people – The panel must include an employee of the state or local health department – Submit a letter that lists the members of the panel, the members affiliation, and the project director – Keep on file of the voting results signed by the program review panel that states the vote for approval or disapproval of each proposed item 21
- 22. AUDITOR’S REPORTING PACKAGE AUDITED FINANCIAL STATEMENTS SCHEDULE OF EXPENDITURE OF FEDERAL AWARDS SUMMARY SCHEDULE OF PRIOR AUDIT FINDINGS CORRECTIVE ACTION PLAN AUDITOR’S REPORT(S), INCLUDING A SCHEDULE OF FINDINGS AND QUESTIONED COSTS DATA COLLECTION FORM 22
- 23. REFERENCE MATERIALS OMB CIRCULAR A-133, AUDITS OF STATES, LOCAL GOVERNMENTS, AND NON-PROFIT ORGANIZATIONS OMB CIRCULAR A-122, COST PRINCIPLES FOR NON- PROFIT ORGANIZATIONS OMB CIRCULAR A-110, UNIFORM ADMINISTRATIVE REQUIREMENTS FOR GRANTS AND COOPERATIVE AGREEMENTS WITH INSTITUTIONS OF HIGHER EDUCATION, HOSPITALS AND OTHER NON-PROFIT ORGANIZATIONS GOVERNMENT AUDITING STANDARDS (YELLOW BOOK) OMB CIRCULAR A-133 COMPLIANCE SUPPLEMENT (UPDATED ANNUALLY AROUND MARCH) CATALOG OF FEDERAL DOMESTIC ASSISTANCE (CFDA) CHECKPOINT, GOVERNMENT DOCUMENTS LIBRARY, SINGLE AUDITS, AAG GOVERNMENT AUDITING STANDARDS AND CIRCULAR A-133 AUDITS 23
- 24. WEBSITES OMB WEB SITE WWW.WHITEHOUSE.GOV/OMB/ (LOOK UNDER GRANTS MANAGEMENT) GAO WEB SITE WWW.GAO.GOV CATALOG OF FEDERAL DOMESTIC ASSISTANCE WEB SITE WWW.CFDA.ORG FEDERAL AUDIT CLEARING HOUSE HTTP://HARVESTER.CENSUS.GOV/SAC 24