By: Marci Thomas
The Office of Management and Budget (OMB) published it’s long awaited Super Circular on December 26, 2013, in the Federal Register. The Super Circular consolidates eight circulars so that there is one conformed set of cost principles and one conformed set of administrative requirements, along with the guidance to auditors previously known as Circular A-133.
The guidance also makes changes to the risk based approach raising the threshold for a single audit up to $750,000, and the minimum threshold separating Type A and Type B programs, to the same amount. There are other notable changes to the risk based approach, including the percent of coverage change from 25% to 20% for low risk auditees, and from 50% to 40% for those not considered low risk. The OMB did not reduce the number of compliance requirements as expected. To see all the changes go to this website.
The revised data collection form was scheduled for release on January 7, 2014. A draft of the form and instructions is available on the Federal Audit Clearinghouse site (as of January 8th). Due to the delay in the site for filings being active, the OMB has granted an extension until February 28, 2014. The extension is automatic and there is no approval required. The extension applies only to single audits for the fiscal periods ending in 2013. Auditees with findings are encouraged to submit as soon as the 2013 Form becomes available.
I will be offering a workshop on January 22, 2014, at NCACPA’s office in Morrisville. This workshop will discuss the provisions of the Super Circular, the revised data collection form, and the top 25 findings of the Local Government Commission on Single Audits.
Marci Thomas, CPA, MHA, is an author and discussion leader for Loscalzo Associates, Ltd., and also performs quality control and risk assessment consultations for the firm. Marci is also a clinical assistant professor at the University of North Carolina at Chapel Hill, where she teaches Healthcare Consulting and Financial Leadership. Additionally, she is a member of NCACPA’s Board of Directors and serves on the Not-for-Profit and Governmental Accounting & Auditing Committees.