Sneak Preview: Revised FAQ Answers Numerous New Single Audit Questions

September 1, 2017 | By Jerry Ashworth | Post a Comment

xsass_bookshot(The following was excerpted from a recent article in the Single Audit Information Service.) Nonfederal entities that have a single audit performed under Subpart F of the Office of Management and Budget’s (OMB) uniform grant guidance may not allow their auditor to prepare their summary schedule of prior audit findings or a corrective action plan for the current-year audit findings, OMB explained in its recently revised Frequently Asked Questions addressing provisions in the uniform guidance.

OMB, in conjunction with the now-disbanded Council on Financial Assistance Reform (COFAR), issued the updated FAQ, which contains 24 new questions, several of which pertain to audit-related issues, and four revised questions. The FAQ, dated July 2017 but released in early August, is now in its fourth version, and it updates the previous FAQ released in September 2015.

The 47-page document notes that the questions and answers were presented by COFAR. OMB recently disbanded COFAR, the interagency group created in 2011 to coordinate federal financial assistance reform and oversee the integration of uniform grant guidance, under an OMB memorandum to federal agencies aimed at reducing governmental burden. Financial assistance priorities going forward will be considered by the Chief Financial Officers Council, which was the umbrella organization over COFAR. The FAQ is designed to provide additional context and background on the guidance to help stakeholders understand policy changes.

In response to a new question (.511-1) seeking clarification about audit follow-up provisions in §200.511 of the uniform guidance, OMB stated that because an auditor must be independent of the auditee, the auditee must prepare the summary schedule of prior audit findings and the corrective action plan. In addition, the auditee must submit the corrective action plan on auditee letterhead.

OMB further responded that the auditee must prepare the corrective action plan in a document separate from the auditor’s findings (§200.511(c)). Therefore, an auditee may not simply reference the “views of responsible officials” section of the findings to fulfill its responsibility for the preparation of a corrective action plan.

(The full version of this story has now been made available to all for a limited time on Thompson’s Grants Compliance Expert site.)

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