Infusion of stimulus money gives single audits (A-133) new meaning
The American Recovery and Reinvestment Act (ARRA) of 2009 has significant implications for audits performed under OMB Circular A-133. If you have received funds under the ARRA, you probably know that they come with an unprecedented demand for accountability and transparency and require reporting an unparalleled amount of data.
In other words there are a lot of strings attached, and even if you are accustomed to single audits for other types of federal funds, as a recipient of ARRA funding you must be prepared for additional rules and regulations along with stringent reporting requirements.
Accountability to taxpayers
In 1984, when the Office of Management and Budget (OMB) Circular A-133 went into effect, the goal was to gain consistency and uniformity in reporting how federal funds were spent across federal agencies. Now the focus is to reassure the American taxpayers that their money is being wisely spent.
All recipients, and many subrecipients, of recovery funds are required to make quarterly reports (Section 1512 reporting) that will be published on the website, Recovery.gov. The reports must indicate the amount of money received, the projects funded, the status of the projects, the number of jobs created, and the number of jobs retained. The quarterly reports are to be cumulative and, if the total amount of federal funds your organization has expended, including ARRA funds, is $500,000 or more, the organization will need to file a single audit.
Help with A-133 single audits
In this environment of increased oversight, it is more important than ever to find qualified A-133 auditors who have significant experience with these grants and can ensure the quality of your single audit. The Plante Moran A-133 audit team can offer both.
Plante Moran performs the second highest number of single audits in the United States and is a member of the AICPA Government Audit Quality Center. In fact, the leader of the Plante & Moran single audit team sits on the Quality Center’s executive board.
Where to begin with A-133 compliance
Read your grant carefully and understand all the various A-133 requirements for compliance. In addition, understand which OMB circulars apply to your organization. For instance, different circulars apply to not-for-profits than apply to schools or local governments.
All organizations receiving federal funds are required to maintain strong internal controls using a COSO framework. The five elements of COSO are:
- Control activities
- Risk assessment
- Information and communications
- Control environment
It will be important for you to document your policies and procedures in writing. As part of the audit process our A-133 auditors will need to gain an understanding of your controls, determine if they have been placed in operation, and test if they are effective. They will then perform detailed tests in order to provide the required opinion on whether your organization complied with the requirements applicable to your grants.
It is clear the recovery act funds will bring opportunities as well as challenges. It is never too soon to begin planning for how you will account for and track the funds you receive.