Audit Requirements

1
Audit Requirements

• Second Annual NIH SBIR/STTR Conference

2
Audit? Who said anything about having an audit?

• The Department of Health Human Services did!
• HHS specifies requirements for audits of
  for-profit organizations in
• 45 CFR 74.26(d)

http//www.hhs.gov/progorg/grantsnet/adminis/cfr
45-docs/p74-subc.html74.26
3
Lets have that in plain English.

• A for-profit organization is required to have a
  non-Federal audit if
• it expended a total of 300,000 or more under one
  or more HHS awards
• AND
• at least one of the awards is an HHS grant

4
I thought the 300,000 expended threshold was
related to OMB Circular A-133 and isnt that for
non-profits and universities?

• Yes and YesHowever, 45 CFR 74.26(d) essentially
  incorporates the thresholds and deadlines of OMB
  Circular A-133.

5
So, I must have an A-133 audit if I expend
300,000 or more in HHS funds and I have at
least one grant award.

• Not exactly.

6
Good news !You have a choice.

• 45 CFR 74.26(d) provides for-profit organizations
  with two options regarding the type of audit that
  will satisfy the audit requirements.

7
1 - A financial related audit as defined in, and
in accordance with, the Government auditing
Standards (a.k.a. the Yellow Book)
OR
2 - An audit that meets the requirements of OMB
Circular A-133
http//www.gao.gov/govaud/ybk01.htm
http//www.whitehouse.gov/OMB/circulars/a133/a133.
html
8
Is there a due date?

• Yes, 45 CFR 74.26(d) essentially incorporates the
  deadlines of OMB Circular A-133 - Audits shall be
  completed and submitted within
• 30 days after receipt of the auditors report
• or
• 9 months after the end of the organizations
  fiscal year

Whichever is earlier
9
Okay, the auditors have done their work and the
audit is complete. Now what?

• Good question, the filing requirements differ
  from A-133.
• For-profit audit reports are submitted to
• National External Audit Review Center
• HHS Office of Audit Services
• 323 West 8th Street
• Lucas Place, Room 514
• Kansas City, MO 64105

10
Great, I didnt expend more than 300,000 in HHS
funds this year so Im off the hook, right?

• While it is true you are not required to have an
  audit for that particular year, keep in mind that
  your grant-related records must be available to
  NIH or other designated officials for review or
  audit.