Posted Date: March 29, 2018

Author:  Federal Student Aid

Subject: Single Audit Submission Requirements for Fiscal Years Ending Within Calendar Year 2018

On April 28, 2017, the Department issued an announcement concerning Single Audits performed under 2 Code of Federal Regulations (C.F.R.) Section 200, OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) for fiscal years ending within calendar year 2017.  For such audits, we directed Single Audit filers to continue using guidance we provided in our August 5, 2016 announcement.  Our August 5, 2016 announcement detailed the requirement for Single Audit filers to submit an audit annually and, in the event that the Student Financial Assistance Cluster, which includes the Title IV programs, was not audited as a major program because it was identified as a low-risk program, the filer should contact its School Participation Division to report the low-risk determination.

This guidance serves to update Single Audit filers of audit submission requirements for fiscal years ending within calendar year 2018.        

Audit Requirements:  According to 2 C.F.R. § 200.518(a), under a Single Audit, the auditor must use a risk-based approach to determine which Federal programs are major programs. Part of the major program determination requirements at 2 C.F.R. § 200.518 require an auditor to identify larger Federal programs (Type A programs) which are low-risk. If a Type A program is identified as low-risk, it is not required to be audited as a major program, unless necessary to comply with the percentage of coverage rule. For a Type A program to be considered low-risk, it must, among other requirements, have been audited as a major program in at least one of the two most recent audit periods.

Public and non-profit entities with institutions participating in the Title IV programs that submit a Single Audit that does not include the Student Financial Assistance Cluster as a major program will no longer be required to notify their respective School Participation Division of the low-risk assessments.

Reminder:   Institutions must still submit (via the Department’s eZ-Audit system) their complete Single Audit each year by the due date regardless of whether the Student Financial Assistance Cluster was audited as a major program. 

The impact on year three testing requirements (after two years of low risk assessments) for fiscal year 2019 audits and beyond is still under review.

If you have any questions about audit submission or sampling requirements, please contact Patrice Fleming, Performance Improvement and Procedures Service Group at (202) 377-4209 or via email at Patrice.Fleming@ed.gov for additional information.

   

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