The Single Audit: What It Is, What You Need to Know, and What’s New?

A Single Audit is required when a non-federal entity expends $750,000 or more in federal awards during its fiscal year. The awards can be direct (straight from the federal government) or indirect (from another non-federal entity). Because it is based on total grant expenses for one year (not per grant), not every company that needs to perform a Single Audit needs one every year. However, increasingly many companies have needed their first Single Audit in recent years, due to increased federal grant funding related to the COVID-19 pandemic.

Following are some key facts about Single Audits, including requirements and changes effective in accordance with the 2024 revision to Government Auditing Standards (also known as the Yellow Book) and the data collection form:

• Non-federal entities, organizations that carry out a federal award as a recipient organization or subrecipient organization, include state and local governments, nonprofit organizations, Native American tribes, and institutions of higher education.

•  In a financial statement audit, the auditor or auditors provides their opinion on whether the financial statements as a whole are presented fairly. The purpose of the Single Audit is to determine if award recipients comply with direct and material compliance requirements for each major program. Federal agencies use Single Audit reports and findings to address problems at the grantee level or to implement changes or improvements to federal programs. It also provides assurance about the recipients’ internal controls over compliance.

• Single audits involve three layers of accounting requirements: Generally Accepted Auditing Standards (GAAS) requirements, Yellow Book requirements, also known as the Generally Accepted Government Auditing Standards (GAGAS), and Uniform Guidance requirements. There cannot be a single audit without the audit also being done under GAGAS. There can be an audit under GAGAS that does not include a single audit.

• The Single Audit Act Amendments of 1996 (Single Audit Act) were enacted to streamline and improve the effectiveness of audits of federal awards expended by states, local governments, and nonprofit entities (referred to as “non-federal entities”), as well as to reduce audit burden. The Single Audit Act requires Single Audits to be conducted by an independent auditor.

• The Single Audit Act gives the Director of the Office of Management and Budget (OMB) the authority to develop government-wide guidelines and policy statements on performing audits to comply with the Act. The most recent OMB regulation issued for this purpose is known as “Uniform Guidance”; it includes uniform cost principles and audit requirements for federal awards to non-federal entities and administrative requirements for all federal grants and cooperative agreements.

• The OMB sets the policy for single audit submissions and their deadlines. The audit package and the data collection form must be submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor’s report(s) or nine months after the end of the audit period, whichever comes first. However, the OMB is waiving the 30-day deadline for 2023 submissions. For 2023 submissions with fiscal periods ending between January 1, 2023, and September 30, 2023, requirement 2 CFR 200.512(1) stating that Single Audits are due to the Federal Audit Clearinghouse 30 days after receipt of the auditor’s report(s), is waived. These audits will be considered on time if they are submitted within nine months after their fiscal period end date.

• As of September 30, 2023, management and governance of the FAC, where federal grant audits are submitted, is transferred from the Department of Commerce’s Census Bureau to the General Services Administration (GSA). As such, the GSA is the new repository for the collection and posting of Single Audit information as of October 1, 2023; it will accept Single Audits with fiscal periods ending 2023 and later. To submit or review a Single Audit, go to the fac.gov homepage and sign in using login.gov. 

• Once you submit a Single Audit package, you cannot make further changes. What you have submitted is what will be available for review via the FAC’s audit search tool.

• On February 1, The Government Accountability Office (GAO) released the Government Auditing Standards 2024 Revision, which replaces Chapter 5 of the 2018 revision with a new Chapter 5 titled, Quality Management, Engagement Quality Reviews, and Peer Review. The 2024 revision also adds application guidance to Chapter 6, Standards for Financial Audits, to provide clarity as to when the concept of reporting key factors in audit matters, previously introduced into the AICPA auditing standards framework, might apply for financial audits of government entities and entities that receive government financial assistance. There are no other changes to the remainder of the Yellow Book.

• Government Auditing Standards 2024 Revision is effective for financial audits, attestation engagements, and reviews of financial statements for periods beginning on or after December 15, 2025, and for performance audits beginning on or after December 15, 2025. A system of quality management for financial reporting that complies with Government Auditing Standards must be designed and implemented by December 15, 2025. An audit organization should complete its evaluation of the system of quality management by December 15, 2026. Early implementation is permitted.