CDC Clarifies Single Audit Requirement Under Block Grant Program

January 17, 2018 | By Jerry Ashworth | Post a Comment

KPwn1JyQ_400x400Overseeing grant programs has never been the easiest task, and confusing regulations and requirements tend to make that process even harder. That’s why it was heartening to see that the Department of Health and Human Services’ Centers for Disease Control and Prevention (CDC) issue a clarification to its regulations to better explain its stance on single audit requirements.

The clarification particularly pertains to using the single audit to comply with section 1906(b) of the Public Health Service (PHS) Act under the Preventive Health and Health Services Block Grant. The Public Health Services Act requires states to receive an annual independent audit of its expenditures from payments received from the federal government. To meet this requirement, states often submit single audits. The Single Audit Act, 31 USC 7501 et seq., includes the following provision:

“An audit conducted in accordance with this chapter shall be in lieu of any financial audit of Federal awards which a non‐Federal entity is required to undergo under any other Federal law or regulation. To the extent that such audit provides a Federal agency with the information it requires to carry out its responsibilities under Federal law or regulation, a Federal agency shall rely upon and use that information.”

The Single Audit Act also authorizes agencies to “conduct or arrange for additional audits which are necessary to carry out its responsibilities under Federal law or regulation … [so long as] such audits [are] not duplicative of other audits of federal awards.”

CDC has clarified that a recipient may use an audit under the Single Audit Act to comply with the audit provision under the block grant program if: (1) the audit is conducted annually; (2) the audit meets the requirements of the Single Audit Act; (3) the recipient submits that audit to, and receives acceptance of the audit by, the Federal Audit Clearinghouse; and (4) the recipient ensures that applicable Catalog of Federal Domestic Assistance (CFDA) number 93.758 is listed on the Schedule of Expenditures of Federal Awards (SEFA) contained in that audit.

It further noted that this audit requirement does not: (1) conflict with the Single Audit Act requirement; (2) require an audit of the applicable CFDA in addition to the audit required by the Single Audit Act; (3) require submission of the audit required by the Single Audit Act to CDC; and (4) mandate treatment of the applicable CFDA as a major program under the Single Audit Act.

The National Association of State Auditors, Comptrollers and Treasurers applauded the clarification, particularly the last provision. “This is good news given that states were receiving notices from CDC requiring the block grant to be selected as a Type B [major] program in all single audits,” it said in a recent statement.

Clarifications and Frequent Asked Questions can always help those in the grants community, and more federal awarding agencies should consider issuing more of these when the need arises. We’re glad to see CDC took the initiative.

Let us know your reaction to this clarification. We’d love to hear from you.

As a reminder, we have all of our Federal Funding Training Forums scheduled for 2018. Please let me know if you have questions or can make any of these. We hope to see you there!

  • Wednesday Feb 7 – Friday Feb 9 in PHOENIX

  • Wednesday May 1 – Friday May 4 in ST LOUIS

  • Wednesday July 25 – Friday July 27 in MINNEAPOLIS

  • Wednesday October 17 – Friday October 19 in ATLANTA


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