Subrecipient Monitoring: A-133 Single Audit Compliance Michigan State Police Emergency Management and Homeland Security Division Jackie Reese, Audit Unit Manager Richard Sheaffer, Auditor
Dec 23, 2015
Subrecipient Monitoring: A-133 Single Audit Compliance
Michigan State PoliceEmergency Management and Homeland Security Division
Jackie Reese, Audit Unit Manager
Richard Sheaffer, Auditor
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• To remind all pass-through entities (Regional Fiduciary) of their Single Audit, A-133 responsibilities.
• To provide a job aid for pass-through entities (Regional Fiduciary) to successfully monitor their subrecipients’ single audit compliance.
Objectives
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The Single Audit Act and
OMB Circular A-133
• Audits of States, Local Governments, and Non-Profit Organizations.
• Established Federal audit regulations for entities that receive Federal financial assistance.
• Established subrecipient monitoring responsibilities.
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Responsibilities and Guidance
• OMB Circular A-133, Audits of States, Local Governments, and Non-Profit Organizationshttp://www.whitehouse.gov/omb/rewrite/circulars/a133/a133.html
• U.S. Department of Homeland Security Preparedness Directorate – Financial Management Guidehttp://www.dhs.gov/xlibrary/assets/Grants_FinancialManagementGuide.pdf
• U.S. Department of Homeland Security, 2009 Homeland Security Grant Program, Guidance and Application Kithttp://www.fema.gov/pdf/government/grant/hsgp/fy09_hsgp_guidance.pdf
• 2009 Homeland Security Grant Program Grant Agreement
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Federal Awarding Agency
Recipient
Subrecipient
Flow of Federal Financial Assistance
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Federal Awarding Agency =
Recipient =
Subrecipient =
(Grantor)
(Subgrantor)
(Subgrantee)
Flow of Federal Financial Assistance
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Federal Awarding Agency =
Recipient =
Subrecipient =
DHS
MSP EMHSD
Regional Fiduciary
Flow of Federal Financial Assistance
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Federal Awarding Agency =
Recipient =
Subrecipient =
Subrecipient =
DHS
MSP EMHSD
Regional Fiduciary
Local Jurisdiction
Pass-through
Pass-through
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Roles and Responsibilities
• DHS is the Federal awarding agency.
• MSP EMHSD is the recipient and a pass-through entity.
• Regional Fiduciary is a subrecipient and a pass-through entity.
• Local Jurisdiction is a subrecipient.
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Who is required to have a single audit?
A recipient/subrecipient that expends at least $500,000 in total federal awards in a year.
Important Notes:• This includes all Federal grant money expended from all
Federal grant programs, not just the programs you administer.
• Usually, a CPA firm conducts the single audit and prepares the report. Your entity (Regional Fiduciary) does not conduct the single audit and does not prepare the report.
OMB Circular A-133 §.200 (b)
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Important Note: If you have a Single Audit, report the correct pass-through entity on the Schedule of Expenditures of Federal Awards
(SEFA)
• MSP-EMHSD shall report DHS• Regional Fiduciary shall report MSP-EMHSD• Local Jurisdiction shall report Regional Fiduciary
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When is the Single Audit Due?
Within nine months after fiscal year end.
• FYE 06/30/2009 → Due 03/31/2010 • FYE 09/30/2009 → Due 06/30/2010• FYE 12/31/2009 → Due 09/30/2010
OMB Circular A-133 §.320 (a)
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Where should the Single Audit be submitted?
• To the Federal Clearinghouse• To all agencies and pass-through agencies that
provide funds to your agency.
○ MSP EMHSD → DHS (and other agencies)○ Regional Fiduciary → MSP EMHSD (and other agencies)○ Local Jurisdiction → Regional Fiduciary (and other
agencies)
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Pass-through Entity Responsibility
Who needs to review the Single AuditReport?
• MSP-EMHSD reviews their subrecipients (Regional Fiduciary and any other subrecipients).
• Regional Fiduciary reviews their subrecipients.
OMB Circular A-133 §.400 (d)(4-6)
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Important Note
• You may already have personnel in your organization reviewing Single Audit Reports.
• If so, be able to provide contact name and phone number to MSP-EMHSD upon request.
• Communicate, communicate, communicate.
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Major Parts of the Single Audit Report
• Report on Internal Control over Financial Reporting and on Compliance and other matters based on an audit of Financial Statements performed in accordance with government auditing standards. (Results summarized in the Schedule of Findings and Questioned Costs.)
• Report on Compliance with requirements applicable to each major program and on Internal Control over compliance in accordance with OMB A-133. (Results summarized in the Schedule of Findings and Questioned Costs.)
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Major Parts of the Single Audit Report
• Corrective Action Plan (Generally included in the Schedule of Findings and Questioned Costs.)
• Schedule of Findings and Questioned Costs.
• Summary Schedule of Prior Audit Findings.
• Schedule of Federal Expenditures and Federal Awards (SEFA).
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Job Aid
• Sample Subrecipient Single Audit Review Form
Sample form is provided for guidance only and is not required.
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Completion of Review
• Management Decision○ On audit findings that apply to Federal
awards your agency passed through.○ Within 6 months of receipt of single audit
report.○ Ensure that the subrecipient takes
appropriate and timely corrective action.
OMB Circular A-133 §.405
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Additional Resources
• Federal Program Names and CFDA #:
https://www.cfda.gov/index?s=main&mode=list&tab=list
• Local Audit Reports:
http://www.michigan.gov/treasury/0,1607,7-121-1751_31038---,00.html
• Data Collection Form (Federal Clearinghouse)http://harvester.census.gov/sac/dissem/entity.html
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Questions
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Contact Information
Richard Sheaffer, Auditor
Phone: (517) 333-4624
Cell: (517) 282-7548
Email: [email protected]
Jackie Reese, Audit Unit Manager
Phone: (517) 324-2330
Email: [email protected]