ACT STANDARDS;
2) WHETHER THE SUBRECIPIENT HAS EXPENDED FEDERAL FUNDS IN ACCORDANCE WITH APPLICABLE LAWS.
3) ENSURE CORRECTIVE ACTION IS TAKEN ON IDENTIFIED AREAS OF NONCOMPLIANCE;
4) CONSIDER ADJUSTMENT OF THE PRIMARY RECIPIENT'S BOOKS BASED ON AUDITS OF THE SUBRECIPIENT; AND
5) ENSURE INDEPENDENT AUDIT ACCESS TO RECORDS AND FINANCIAL STATEMENTS OF THE SUBRECIPIENT.
THE SINGLE AUDIT ACT REQUIRES SUBRECIPIENTS TO BE AUDITED IN ACCORDANCE WITH THE ACT OR, IF THE SUBRECIPIENT HAS NOT HAD AN AUDIT PERFORMED IN ACCORDANCE WITH THE ACT, THE PRIMARY RECIPIENT MUST, BY REVIEWING AUDITS PERFORMED IN ACCORDANCE WITH FEDERAL LAW OR THROUGH OTHER MEANS, (I.E., PROGRAM REVIEWS), ENSURE CORRECTIVE ACTION IS TAKEN FOR ITEMS OF NONCOMPLIANCE. ID. AT 7502(E) (L (A-B)
THEREFORE, IT APPEARS THAT EITHER THE SUBRECIPIENT MUST HAVE AN AUDIT PERFORMED WHICH MEETS THE ACT STANDARDS OR THE PRIMARY RECIPIENT MUST PERFORM AN AUDIT OF THE SUBRECIPIENT WHICH MEETS ACT STANDARDS, WHICH COULD BE ACCOMPLISHED THROUGH PROGRAM REVIEWS. SEE, OMB CIRCULARS A-128(9)(A-E) AND A-133(10)(A-E).
ARE SHELTERED WORKSHOPS AND COMMUNITY RESIDENTIAL CENTERS REQUIRED TO CONFORM TO THE HEIGHTENED AUDIT REQUIREMENTS OF THE SINGLE AUDIT ACT OF 1984? THE ANSWER WILL DEPEND, INITIALLY, WHETHER THE PROGRAM RECEIVES $25, 000.00 OR MORE PER FISCAL YEAR IN FEDERAL FINANCIAL ASSISTANCE. IF A SHELTERED WORKSHOP/COMMUNITY RESIDENTIAL PROGRAM APPLIES FOR AND RECEIVES $25,000.00 OR MORE PER YEAR THROUGH THE FEDERAL GOVERNMENT'S PRIMARY RECIPIENT (I.E., IN MOST INSTANCES, THE STATE), THEN THE LAW REQUIRES THAT THE PRIMARY RECIPIENT BE ABLE TO ACCOUNT FOR THE FEDERAL FINANCIAL ASSISTANCE RECEIVED. THIS MAY BE DONE BY RECEIVING AN AUDIT PERFORMED UNDER THE HEIGHTENED ACT AUDIT STANDARDS FROM THE SUBRECIPIENT. OR, IT MAY REQUIRE, IF SUCH AN AUDIT IS NOT AVAILABLE FROM THE SUBRECIPIENT, THAT THE PRIMARY RECIPIENT CONDUCT A PROGRAM REVIEW OR PERFORM ITS OWN AUDIT WHICH WOULD MEET ACT AUDIT STANDARDS.
ARE SUBRECIPIENTS WHO RECEIVE LESS THAN $25,000.00 IN FEDERAL FINANCIAL ASSISTANCE PASSED THROUGH THE PRIMARY RECIPIENT REQUIRED TO CONDUCT AUDITS UNDER ACT STANDARD? NO, NOT SPECIFICALLY. HOWEVER, STATE OR LOCAL LAW OR REGULATIONS, OR PERHAPS EVEN CONTRACT TERMS, MAY REQUIRE PROGRAMS TO CONDUCT AUDITS IN ACCORDANCE WITH ACT REQUIREMENTS.
(JANIE SIMMS HIPP)