Federal programs and amounts Critical to the correct determination of major programs in a single audit is getting a complete and accurate Schedule of Expenditures of Federal Awards (SEFA) from the client. The SEFA for Sneeringer’s presentation (simplified for purposes of illustration) contains the following federal programs and amounts for a Dec. 31, 2020, fiscal-year-end client: Despite the existence of new coronavirus relief money from the HIV Emergency Project Grants and CRF programs, according to the guidance in the 2020 Office of Management and Budget (OMB) Compliance Supplement and related Addendum, the determination of major programs does not change for the single audit of this client. “A lot of auditors think, ‘There’s CARES Act money. Of course it’s high-risk. We’re going to have to audit it.’ Not necessarily,” Sneeringer said. “There’s still a process, a series of required steps we go through, given this mix of awards and knowing what’s been audited in the past and what hasn’t been audited.” When total federal expenditures are less than $25 million, a Type A program is one with expenditures of $750,000 or more; the others are Type B programs. A Type A program that has not been audited in the past two audits is considered high-risk and would be considered a major program to be audited. A Type A program also is high-risk if in the last audit period it was identified with a material weakness, had a modified opinion, or had known or likely questioned costs of more than 5% of the federal expenditures for that program. In the example, the CRF program is brand-new funding that has never been audited before, and at $800,000, it is a Type A program because its expenditures exceed the $750,000 threshold. “So we know this is going to be a major program,” Sneeringer said. “It’s a Type A program, never been audited before, 100%, take it to the bank.” The Research and Development Cluster is a Type A program as a whole, and the Nursing Research is considered part of that Type A program for single audit purposes even though its funding on its own is just $300,000. The Violence Against Women program, meanwhile, is a Type A program because its expenditures are $1 million. In the example, the audit of the program last year found a significant deficiency in its internal controls. Despite that, the program still isn’t guaranteed to be high-risk because a material weakness, not a significant deficiency, is the threshold for high risk. “A significant deficiency doesn’t get you automatic high risk, you still have to look at the other required steps for risk determination in the Uniform Guidance,” Sneeringer said. The HIV Emergency Project Grants expenditures are just $650,000. So, even though it’s new, it’s a Type B program and doesn’t automatically need to be audited. Instead, the Uniform Guidance has the auditor use a formula to identify how many high-risk Type B programs need to be audited (based on the number of low-risk Type A programs) and then the auditor goes through a risk assessment process to determine which high-risk Type B program will be tested as a major program. That determination depends on several factors defined in the Uniform Guidance as well as auditor judgment.


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