When is a 2 CFR Part 200 audit or Single Audit required, and how much oversight is a grantee required to have over these audits?
Date Published: May 2015
A 2 CFR Part 200 audit is required if your organization expends more than $750,000 in federal funds during your fiscal year. CDBG grantees and subrecipients that expend $750,000 or more in a year in federal awards must have an audit conducted in accordance with 2 CFR Part 200, Subpart F—Audit Requirements except when they elect to have a program-specific audit conducted. A program audit is an audit of one federal program (such as CDBG). A program-specific audit is allowed when the grantee or subrecipient expends federal awards under only one federal program. A single audit is an audit that includes both an entity's financial statements and its federal awards (from all applicable federal programs). If a grantee or subrecipient expends less than $750,000 a year in federal awards, it is exempt from the audit requirements for that year; however, records must be available for review or audit by appropriate officials of the federal agency, pass-through entity and the Government Accountability Office.
Your agency's oversight should be in the form of monitoring to ensure compliance with CDBG regulations and any requirements imposed by your agency. Advise subrecipients of requirements imposed on them by federal laws, regulations, and the provisions of contracts or grant agreements as well as any supplemental requirements imposed by the grantee. Monitor the activities of subrecipients as necessary to ensure that CDBG funds are used for authorized purposes in compliance with laws, regulations, and the provisions of the subrecipient agreement and those performance goals are achieved. Ensure that a subrecipient or non-federal agency expending $750,000 or more in federal awards during their fiscal year has met the audit requirements of 2 CFR 200 for that fiscal year in accordance with the provisions of Subpart F—Audit Requirements.