Understanding Uniform Guidance Audit Requirements

The Office of Management and Budget’s Uniform Guidance, codified in the Code of Federal Regulations, sets forth standard requirements for federal award recipients, including financial management, internal controls, property management, conflict of interest policies, and subrecipient monitoring.  

The goal of Uniform Guidance is to simplify compliance, safeguard proper use of funds, and increase performance, transparency, and accountability for all involved.  

Prior to receiving a federal grant, organizations should establish a strong financial foundation by following Generally Accepted Accounting Principles (GAAP) and maintaining records on an accrual basis to remain audit-ready. Organizations should also focus on implementing strong internal controls over financial reporting and compliance, including cybersecurity measures to protect data and prevent loss, as well as written standards of conduct covering conflicts of interest.  

These steps not only support effective grant management but also position the organization to comply with Uniform Guidance, which outlines specific audit requirements for federal award recipients. 

Does Your Organization Need a Uniform Guidance Audit?  

A Uniform Guidance audit is required for any non-federal entity that spends $1,000,000 or more in reimbursable expenses under federal awards during a fiscal year beginning on or after October 1, 2024. For earlier fiscal years, the threshold was $750,000. Audit reports are due nine months after the fiscal year ends, typically by September 30.  

Key points in determining if the Uniform Guidance threshold has been exceeded: 

• Your organization’s expenses are reimbursed by grants awarded directly from federal agencies (e.g., NIH, DOE) or indirectly through pass-through entities (universities, state/local government, or prime contractors).  
• Acting as a pass-through entity does not exempt you; sub-awards should be included 
• The determining factor is funds expended, not merely received.  
• Expenses should include any indirect costs charged to the grants. 
• Total expenditures should be determined based on the organization's fiscal year 

 Continue reading for how to proceed if you’ve determined your organization exceeds the threshold and therefore requires a Uniform Guidance audit.  

2 Audit Options under Uniform Guidance 

Under the Uniform Guidance, there are two types of audits based on the nature of the federal awards received by an organization: 

1. Program-Specific Audit (PSA) 

Under the Code of Federal Regulations, a PSA can be elected when all federal expenditures during the fiscal year come from a single federal agency, such as the NIH or DOE.  

This program-specific audit focuses on accuracy of the Schedule of Expenditures of Federal Awards, or SEFA, being compliant with the Office of Management and Budget Compliance Supplement.  It also includes signed opinion letters and a summary of audit results that communicate required findings under the Code of Federal Regulations. 

2. Single Audit 

Under the Code of Federal Regulations, a single audit is required when an organization receives federal funding from multiple agencies during the same fiscal year. For example, an organization receives grants from both the NIH and DOE.  

A single audit includes the above focuses and results. It also requires an entity-wide financial statement audit and will consist of financial reporting findings required to be reported under the Code of Federal Regulations. 

Reporting Audit Results   

The deadline to submit the final audit report to the applicable grant agency is nine months after the end of the audit period, typically September 30th following a December 31st year-end.  

We can help provide you with any submission information and details needed. We can also offer recommendations for any findings of non-compliance during the audit to avoid future findings and adhere to best practices going forward. 

Choosing the Right Audit Path Forward 

Determining the audit requirements for federal grant audits under the Uniform Guidance can be complex. Determining whether a PSA or single audit is the right path for your organization can also be challenging.   

EisnerAmper’s dedicated governmental audit team has deep experience navigating these complexities. We can assist you in evaluating your federal award activity, interpreting Uniform Guidance requirements, and identifying the appropriate audit approach. In addition, our professionals are fully equipped to perform both program-specific audits and single audits, delivering a thorough, efficient, and compliant audit process from start to finish.