Single Audit Readiness: Surviving Uniform Guidance Without Findings

Any non-federal entity that expends $1,000,000 or more in federal awards in a fiscal year triggers a Single Audit under 2 CFR Part 200, Subpart F. The audit is not just a financial-statement opinion — it is a compliance examination of how every federal dollar was spent, monitored, and reported. Findings get published on the Federal Audit Clearinghouse. Pass-through entities read them. Future awards depend on them.

Step 1: Build the SEFA correctly, the first time

The Schedule of Expenditures of Federal Awards drives the entire audit. Group by federal agency, then by Assistance Listing (formerly CFDA) number. Separately identify pass-through awards with the pass-through entity name and identifying number. Report loan and loan-guarantee balances at year-end plus current-year disbursements. Reconcile SEFA totals to the general ledger and to the federal financial reports (SF-425) submitted during the year.

Step 2: Identify your major programs early

The Type A/B program determination, risk assessment, and 40%/20% coverage rules dictate which programs get tested. Knowing this in Q3 — not in week one of fieldwork — lets you remediate weak controls before the auditor walks in.

Step 3: Tighten the seven compliance requirements that actually get tested

• Activities allowed / allowable costs
• Cash management
• Eligibility
• Equipment and real property management
• Matching, level of effort, earmarking
• Procurement, suspension, and debarment
• Reporting and subrecipient monitoring

Step 4: Subrecipient monitoring is where 60% of findings live

Risk-assess every subrecipient annually. Issue subaward agreements with the required §200.332 data elements. Review their Single Audits or perform agreed-upon procedures. Document everything — the auditor will ask to see your monitoring file, not just your policy.

Step 5: Procurement under the Uniform Guidance

Micro-purchase ($10,000), small purchase ($250,000), and sealed-bid thresholds all require documented price/rate quotations. Sole-source justifications must be in writing. SAM.gov debarment checks must be performed and retained for every contract above the micro-purchase threshold.

"The cheapest audit finding is the one you remediated in August. The most expensive is the one that lands in the data collection form for the world to see."

— ECG Assurance Practice

Common findings we see every year

• SEFA omissions — pass-through awards reported under the pass-through name instead of the federal agency
• Missing or stale procurement policies that don't reflect current Uniform Guidance thresholds
• Time-and-effort documentation that doesn't meet §200.430(i)
• Indirect cost rate applied inconsistently across awards
• Subrecipient monitoring documented as a checklist with no evidence of review