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New Audit Threshold for OMB Circular A-133
 

December 9, 2003 -- The Office of Management and Budget (OMB) has revised Circular A-133, “Audits of States, Local Governments, and Non-Profit Organizations.”  Effective for fiscal years ending after December 31, 2003, the annual A-133 audit threshold will be increased from $300,000 to $500,000. 

Organizations that receive Federal funds, either directly or though a pass-through agency, will be subject to the A-133 audit requirements if they spend $500,000 or more in Federal funds during the year.  Even if an organization’s expenditures of Federal funds falls below the threshold, the Federal government retains the authority to audit or investigate any organization that is suspected of using the Federal funds improperly.

The OMB reported the following statistics regarding this change in the June 27, 2003 Federal Register (Vol. 68, No. 124):

§         Almost 6,000 entities will be relieved of the A-133 audit requirements.

§         Less than one half of one percent of total Federal awards will be exempted.

The OMB determined the benefits of relieving the administrative burden of almost 6,000 entities outweighed the increased risk to the Federal agencies that award the grants.  Under the Single Audit Act Amendments of 1996, the OMB Director may review and increase the threshold on a biennial basis.

In response to criticism of the increased risk to the Federal agencies, the OMB reminded the agencies that the audit is only one way to monitor grantees.  OMB suggested that the agencies should be communicating the CFDA (Catalog of Federal Domestic Assistance) number.  With the CFDA number, the grantee can more easily identify the compliance requirements it must meet.  At http://www.cfda.gov, the grantee may enter the CFDA number to get up-to-date guidance related to agency contact information and compliance requirements.  The OMB also suggested that the Federal agencies take advantage of its authority to review financial and program records throughout the year using site visits or agreed-upon procedures engagements for certain compliance requirements.

The revised circular is available electronically at http://www.omb.gov. Go to the “Grants Management” page and then to the “Circulars” page.

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