2019 Single Audit Update - s3.amazonaws.com · Components of a Single Audit. Government Auditing...

2019 Single Audit Update

July 23, 2019Webinar

Presented in association with

Presented by:

Stephen W. Blann, CPA, CGFM, CGMADirector of Governmental Audit QualityRehmann

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Outline

• Components of a Single Audit• The Uniform Guidance (2 CFR 200)

– Major provisions– 2019 Compliance Supplement– New Data Collection form

• The 2018 Yellow Book

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Components of a Single Audit

• Financial statement audit (GAAS)• Conducted in accordance with Government

Auditing Standards (GAGAS or the “Yellow Book”)

• Compliance audit of federal awards expended (Uniform Guidance/2 CFR 200)

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Financial Statement Audit• Results in an opinion on whether the financial

statements are fairly presented in accordance with generally accepted accounting principles

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Government Auditing Standards• Builds on the foundation of GAAS

– Adds requirements for auditor independence and continuing professional education

• Results in a report (not an opinion) on matters related to internal control over financial reporting that came to the auditors’ attention during the audit

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Compliance Audit of Federal Awards• Builds on the foundation of GAAS and GAGAS

– Adds compliance testing for “major federal programs”• Results in:

– An opinion on major program compliance– A report (not an opinion) on matters related to

internal control over compliance that came to the auditors’ attention during the audit

– An opinion on the Schedule of Expenditures of Federal Awards (SEFA) in-relation-to the financial statements

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Uniform Guidance (2 CFR 200)

• Uniform Administrative Requirements,Cost Principles, and Audit Requirements for Federal Awards

• Combined all related OMB guidance into one location– Administrative requirements (A-102, A-110)– Federal cost principles (A-21, A-87, A-122)– Single audit (A-133, A-89, parts of A-50)

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A. Acronyms and DefinitionsB. General ProvisionsC. Contents of Federal AwardsD. Standards for Financial ManagementE. Cost PrinciplesF. Audit Requirements

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Uniform Guidance: AppendicesI. Notice of funding opportunityII. Contract provisionsIII. Indirect costs – Higher EdIV. Indirect costs – NonprofitsV. SLG-wide central service cost allocation plansVI. Public assistance cost allocation plansVII. SLG indirect cost proposalsVIII. Nonprofits exempted from federal cost principlesIX. Hospital cost principlesX. Data Collection Form (SF-SAC)XI. Compliance Supplement

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Uniform Guidance (2 CFR 200) – Subpart D

Standards for Financial Management• Recipients:

– Comply with all requirements of award– Performance measurement systems– Financial management systems

• Separate identification of federal awards• Complete/accurate financial results• Support for federal draws• Effective control/accountability• Written procedures

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Standards for Financial Management• Written procedures:

– Recommended for all compliance areas– Required for implementing:

• §200.305 Payments (i.e., cash draws)• §200.318 Procurement (including conflict of interest)• Allowability of costs (Subpart E, Cost Principles)• §200.430-431 Compensation (personnel & benefits)• §200.474 Travel costs

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CPE Prompt 1 of 6

• Entities expending federal awards are required to have written procedures for which of the following:A. Drawing down grant resourcesB. Procuring goods and servicesC. Paying employeesD. All of theseE. Only B and C

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Standards for Financial Management• Internal controls:

– Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award

– “Should” be consistent with COSO (see CS Part 6) and the Green Book

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COSO: Internal Control

• 3 Objectives• 5 Components• 17 Principles

– Applicable to each level of an organization

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The Green Book

• 3 Objectives• 5 Components• 17 Principles

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Components / Principles

Control Environment• The set of standards, processes, and

structures that provide the basis for carrying out internal control across the organization– Principle 1: Demonstrate Commitment to Integrity and Ethical Values – Principle 2: Exercise Oversight Responsibility– Principle 3: Establish Structure, Authority, and Responsibility– Principle 4: Demonstrate Commitment to Competence– Principle 5: Enforce Accountability

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Risk Assessment• A dynamic and iterative process for identifying

and assessing the possibility that an event will occur and adversely affect the achievement of objectives– Principle 6: Define Objectives and Risk Tolerances– Principle 7: Identify, Analyze, and Respond to Risks– Principle 8: Assess Fraud Risk– Principle 9: Identify, Analyze, and Respond to Change

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Control Activities• The actions established through policies and

procedures that help ensure that management’s directives to mitigate risks to the achievement of objectives are carried out– Principle 10: Design Control Activities– Principle 11: Design Activities for the Information System– Principle 12: Implement Control Activities

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Information and Communication• The continual, iterative process of providing,

sharing, and obtaining necessary information to carry out internal control responsibilities to support the achievement of the entity’s objectives– Principle 13: Use Quality Information– Principle 14: Communicate Internally– Principle 15: Communicate Externally

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Monitoring Activities• Ongoing evaluations, separate evaluations, or

some combination of the two are used to ascertain whether each of the five components of internal control, including controls to effect the principles within each component, is present and functioning– Principle 16: Perform Monitoring Activities– Principle 17: Evaluate Issues and Remediate Deficiencies

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Documenting IC over Compliance

High-level Controls

Granular Controls

Entity-wide controls Program-specific controls

ControlActivities

ControlEnviron

Info &Comm

RiskAssess Monitoring

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Sheet1

ControlEnvironInfo &CommRiskAssessMonitoringControlActivities

High-level Controls

Granular Controls

Entity-wide controlsProgram-specific controls

CPE Prompt 2 of 6

• Which of these statements about internal controls over federal programs is FALSE:A. Grantees should have written policies and

proceduresB. Policies and procedures should conform to COSOC. Existing policies should be reviewed and

updated, as necessaryD. All grantees should adopt the uniform policies

provided by the OMB

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Standards for Financial Management• Other major provisions:

– Payments (grant draws/advances)– Cost sharing/matching– Program income– Budget revisions requiring prior approval– Property standards (ownership/inventory)– Subrecipient monitoring/management– Procurement standards

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Standards for Financial Management• Procurement standards:

– States may follow their own policies and procedures

– All others must follow the general procurement standards

• Use documented procurement procedures• No conflicts of interest• Consider most economical purchase option

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– All procurement transactions must be conducted in a manner providing full and open competition

– Methods:• Micro purchases < $3,500* (need only be “reasonable”)• Small purchases < $150,000 (obtain price quotes)• Over $150,000:

– Sealed bids/formal advertising– Competitive proposals– Noncompetitive proposals (sole source)

Superseded by NDAA of 2017/2018?

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– All procurement transactions must be conducted in a manner providing full and open competition

– Methods:• Micro purchases < $10,000 (need only be “reasonable”)• Small purchases < $250,000 (obtain price quotes)• Over $250,000:

– Sealed bids/formal advertising– Competitive proposals– Noncompetitive proposals (sole source)

Changes effectiveJune 20, 2018?

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– National Defense Authorization Acts (NDAA) of 2017 and 2018

• NDAA of 2017 raised thresholds for Higher Ed and certain nonprofit research organizations

• NDAA of 2018 extended these benefits to all, upon codification in the Federal Acquisition Regulations

• OMB memo, dated June 20, 2018 told federal agencieshow to implement the changes

It’s… complicated…

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– National Defense Authorization Acts (NDAA) of 2017 and 2018

• The Federal Acquisition Regulations still haven’t actually been updated as of today

• Early implementation of NDAA is permitted with approval from a Federal agency

• Auditors are instructed not to develop findings if an auditee acted in good faith and documented their decisions

…so…very… complicated!

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Uniform Guidance (2 CFR 200) – Subpart E

Federal Cost Principles• Fundamental premises :

– Applying these cost principles “should require no significant changes to sound internal accounting policies/procedures”

– The “total cost” of a Federal award is the sum of the allowable direct and allocable indirect costs less any applicable credits

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Federal Cost Principles• “Allowable” costs:

– Necessary and reasonable for the performance of the Federal award

– Conform to any limitations or exclusions set forth in these principles

– Consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity

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Federal Cost Principles• “Allowable” costs:

– Accorded consistent treatment (direct vs. indirect)– Determined in accordance with generally

accepted accounting principles– Not included as a cost or used to meet cost

sharing or matching requirements of any other federally financed program

– Adequately documented

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Federal Cost Principles• Compensation—personal services

– Allowable if:• Reasonable for services rendered• Follows local hiring policies• Determined and supported in accordance with

“Standards for Documentation” of Personnel Expenses

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– Records that accurately reflect the work performed• Supported by a system of internal control• Incorporated into the official records of the non-Federal

entity• Reasonably reflect the total compensated activity (100%)• Encompass both federal and non-federal activity• Comply with established accounting policies/practices• Support the distribution of salaries/wages among activities

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– Budget estimates (before the fact) alone are not sufficient, unless:

• The system for budgeting produces a reasonable estimate• Significant changes in actual work are identified and

corrected• Short-term fluctuations may be excluded, if the budget is

reasonable over the longer term• Internal controls include an after-the-fact review of

budgeted charges, and makes corrections as necessary

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– New guidance is much more principles-based:The focus in this final guidance on overall internal controls mitigates the risk that a non-Federal entity or their auditor will focus solely on prescribed procedures such as reports, certifications, or certification time periods which alone may be ineffective in assuring full accountability.

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CPE Prompt 3 of 6

• When charging personnel costs to a federal grant, a grantee should:A. Follow its own documented personnel policiesB. Allocate costs between programs on a

reasonable basisC. Conform to the standards of documentation

found in the Uniform GuidanceD. All of the above

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Uniform Guidance (2 CFR 200) – Subpart F

Single Audit• Starts with a financial audit conducted in

accordance with GAAS and GAGAS• Adds requirements for testing compliance

with federal grant regulations

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Stages of a

Single Audit

Determine Need

Select Major

Programs

Test IC and Compliance Reporting

• Four primary stages to a single audit

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Stages of a

Single Audit

Determine Need

Select Major

Programs


• Obtain Schedule of Expenditures of Federal Awards (SEFA) from client

• Threshold for single audit is $750,000 in current year• Test SEFA in accordance with SAS 119 sufficient to

render an in-relation-to opinion

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Stages of a

Single Audit

Determine Need

Select Major

Programs


• Consider by CFDA number or cluster• Divide programs into Type A and B

– Cut-off starts at $750,000 and goes up with total expenditures• Assess risk of Type A programs

– Type A programs that are not low-risk are major– Type A programs that are low-risk (previously audited with no

MW) are temporarily set aside, but may still be major

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Stages of a

Single Audit

Determine Need

Select Major

Programs


• If necessary, assess risk of larger Type B programs– Only required if there is a low-risk Type A program– “Larger” Type B programs are 25% of the Type A threshold– High-risk programs may be selected as major

• Risk assessment is based on auditor judgment• Identify one high-risk Type B program for every four low-risk Type

A programs (25% of the low-risk Type A programs)

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Stages of a

Single Audit

Determine Need

Select Major

Programs


• Determine if percentage of coverage is met– Required to test 40% of SEFA– For low-risk auditees, only test 20% of SEFA

• Clean single audit for two years (no material findings)• Filed on time with the Clearinghouse

– Select additional programs (auditor’s choice) until coverage is met

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Stages of a

Single Audit

Determine Need

Select Major

Programs


• For each major program, determine which compliance areas to test– Applicable per the Compliance Supplement– Applicable to the auditee– Have a direct and material effect on compliance

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Stages of a

Single Audit

Determine Need

Select Major

Programs


• Compliance areasA. Activities allowed or unallowedB. Allowable costs/cost principlesC. Cash managementD. [reserved] *E. EligibilityF. Equipment and real property

managementG. Matching, level of effort, and

earmarking

H. Period of performanceI. Procurement/suspension and

debarmentJ. Program incomeK. [reserved]L. ReportingM. Subrecipient monitoringN. Special tests and provisions

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Stages of a

Single Audit

Determine Need

Select Major

Programs


• In-relation-to opinion on the SEFA• Yellow Book report

– Internal control over financial reporting– Compliance with laws, regulations, and grant agreements

• Single Audit report– Compliance for each major program– Internal control over compliance

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Stages of a

Single Audit

Determine Need

Select Major

Programs


• Schedule of Findings and Questioned Costs– Summary of Auditors Results– Financial statement findings– Federal awards findings– Questioned costs > $25,000

• Summary Schedule of Prior Audit Findings– Status of prior federal award findings

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Stages of a

Single Audit

Determine Need

Select Major

Programs


• Data Collection Form and reporting package– Submitted online– Provides details on findings– Corrective action plan– Complete financial statements for public inspection

2 CFR 200, Appendix XI

Compliance Supplement• Issued annually to assist auditors conducting

single audits and identify auditee responsibilities– June 2019 edition is over 1,600 pages long, but

still not all-inclusive

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2 CFR 200, Appendix XI

Compliance Supplement• Part 1 – Background, Purpose, and Applicability• Part 2 – Matrix of Compliance Requirements• Part 3 – Compliance Requirements• Part 4 – Agency Program Requirements• Part 5 – Clusters of Programs• Part 6 – Internal Control• Part 7 – Guidance For Auditing Programs Not Included

in this Compliance Supplement• Appendices

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Part 1

Background, Purpose, and Applicability• Effective for June 30, 2019 FYE audits and later• Safe Harbor Status:

– The CS is updated annually, but laws change periodically, and delays are normal

– Auditors should perform reasonable procedures to ensure compliance requirements are current

– “Suggested audit procedures” are, as the name implies, only suggested – apply auditor judgment to achieve stated objectives

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Part 2

Matrix of Compliance Requirements• Lists all programs included in the Supplement

and which compliance areas are subject to audit

• Areas marked as applicable (“Y”) may not apply at a particular entity (or not be direct and material)

• Areas marked as not subject to audit (“N”) may still be applicable to the auditee

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New for 2019!

Part 2

Matrix of Compliance Requirements

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CPE Prompt 4 of 6

• Auditors are expected to:A. Perform only those tests specifically included in

the compliance supplementB. Apply professional judgment in determining

what tests to performC. Request instructions from the grantor agency for

programs not included in the CSD. Only select programs for testing that are

included in the CS

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Part 3

Compliance Requirements• Contains general guidance that applies to all

programs (not repeated in Parts 4 and 5)• Transitional guidance

– Part 3.1 – OMB Circulars (pre-12/26/2014 awards)– Part 3.2 – Uniform Guidance

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Part 3

Compliance RequirementsWe would anticipate that for many of the changes, non-Federal entities with both old and new awards may make changes to their entity-wide policies (for example payroll or procurement systems). Practically speaking, these changes would impact their existing/older awards. Non-Federal entities wishing to implement entity-wide system changes to comply with the Uniform Guidance after the effective date of December 26, 2014 will not be penalized for doing so.

COFAR FAQ .110-13

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Part 3 – Compliance Requirements

A. Activities Allowed or Unallowed• Generally unique to each Federal program

(refer to Parts 4 and 5)

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B. Allowable Costs/Cost Principles • Federal cost principles:

– OMB Circulars A-87, A-21, and A-122– 2 CFR 200, Subpart E

• Basic guidelines:– Reasonable/necessary– Allocable to the federal award– Adequately documented

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C. Cash Management• Part 3.1:

– Reimbursement based grants – program costs paid for by entity funds before reimbursement is requested

– Advance payment grants – minimize the time elapsing between transfer of funds from the US Treasury and disbursement• 31 CFR part 205 (Cash Management Improvement Act

of 1990) generally limits advances to 3 days

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C. Cash Management• Part 3.2:

– Advance payment• Preferred when written procedures exist for minimizing

the time elapsing between transfer of funds from the US Treasury and disbursement

– Reimbursement method• Used when no written policies exist, when required by

specific conditions, or upon request of the grantee

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D. [Reserved]• Formerly used for Davis-Bacon Act compliance• Moved to 20.001 Wage Rate Determination

cross-cutting section

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E. Eligibility• Generally unique to each Federal program

(refer to Parts 4 and 5)• May apply to:

– Individuals– Groups / areas of service delivery– Subrecipients

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F. Equipment/Real Property Mgmt• Title to equipment (>$5,000) purchased with

federal funds rests with the non-federal entity– Property records must be maintained– Inventory taken every 2 years– Proceeds from sale may be reinvested or returned

to the federal government

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G. Matching, Level of Effort, Earmarking• Generally unique to each Federal program

(refer to Parts 4 and 5)– Matching – local/in-kind contributions– Level of Effort – supplement vs. supplant– Earmarking - % of funding used for specific

purposes

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H. Period of Performance• Federal funds may only be expended during

the time specified in the grant agreement• Unpaid obligations must generally be

liquidated within 90 days of the end of the funding period

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I. Procurement, Suspension/Debarment• Part 3.1:

– Procurement – follow local practices• Federal awarding agency approval may be required for

procurements over $100,000 (unless notified in writing by the grantor that the amount was raised)

• Also applies if a non-Federal entity elects to delay implementation of the new procurement standards of the Uniform Guidance

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I. Procurement, Suspension/Debarment• Part 3.2:

– Procurement – follow local practices• Micro-purchase < $3,500* (need only be “reasonable”)• Small purchase < $150,000 (obtain price quotes)• Over $150,000:

– Sealed bids– Competitive proposals– Noncompetitive proposals

– All former grace periods have now expired

Changed to $10,000 and $250,000 effective

June 20, 2018? Sort of…

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I. Procurement, Suspension/Debarment• Suspension and debarment

– No “covered transactions” with federally blacklisted parties• Procurement contracts for goods or services expected

to exceed $25,000• All non-procurement transactions (subawards)

– See www.sam.gov for the list of excluded parties

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J. Program Income• Gross income directly generated by a federally

funded project– Fees– Interest– Refunds / proceeds from sales

• May be deducted from program costs, added to the budget, or used to meet matching requirements

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K. [Reserved]• Formerly Real Property Acquisition/Relocation

Assistance

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L. Reporting• Use of standard OMB forms (SF-270 & SF-425)

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M. Subrecipient Monitoring• Part 3.1:

– Responsibilities of pass-through entities:• Determining Subrecipient Eligibility• ARRA - Central Contractor Registration (CCR)• Award Identification• During-the-Award Monitoring• Subrecipient Audits• Ensuring Accountability of For-Profit Subrecipients• Pass-Through Entity Impact

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M. Subrecipient Monitoring• Part 3.2:

– Responsibilities of pass-through entities:• Identify the Award and Applicable Requirements • Evaluate Risk • Monitor • Ensure Accountability of For-Profit Subrecipients

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N. Special Tests and Provisions• Generally unique to each Federal program

(refer to Parts 4 and 5)• Part 3.1 ARRA Special Tests and Provisions:

– Separate accountability for ARRA funding– Presentation on SEFA and Data Collection Form– Subrecipient monitoring

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CPE Prompt 5 of 6

• Which of the following statements are true?A. Auditors test all requirements that are identified

as being subject to audit for a particular programB. Auditors test all requirements that could have a

direct and material effect on complianceC. Grant recipients may still be subject to

compliance requirements, even if the auditor doesn’t elect to test them during an audit

D. All of the above

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Part 4

Agency Program Requirements• Lists specific compliance requirements, audit

objectives, and suggested audit procedures for approximately 200 individual programs– There are approximately 2,200 active CFDA

numbers per www.sam.gov

• Certain federal agencies have cross-cutting sections that apply to multiple grants

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Part 5

Clusters of Programs• Clusters are groupings of CFDA numbers that

are treated as if they are a single program for purposes of the single audit– Research and Development (R&D)– Student Financial Assistance (SFA)– Other clusters (approx. 34)

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Part 6

Internal Control• Includes the 5 components and 17 principles

of COSO/Green Book previously discussed

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Part 7

Programs Not Included in the CS• Provides guidance on identifying applicable

compliance requirements, and determining appropriate audit procedures

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SF-SAC

Data Collection Form• Required for all Single Audits• Due 9 months after fiscal year end, or 30 days

after receipt of the audit report• Submitted electronically, including a text-

searchable PDF of the financial statements (will be publicly available)

• Certified by the auditor and auditee

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SF-SAC

Data Collection Form• The website is currently accepting 2011-2021

FYE submissions

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SF-SAC

Data Collection Form• Changes for 2019:

– More data validation • EIN/DUNS numbers

– More data being captured directly in text fields:• Notes to the SEFA• Details of each federal award finding• Identification of repeat comments• Corrective action plan

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CPE Prompt 6 of 6

• Which of the following statements best describes audit findings and corrective action plans under the new Data Collection Form?A. Access will be restricted to grantor agenciesB. They will be made public and publicly searchableC. Only findings will be made public, while

corrective action plans will be restricted accessD. Only corrective action plans will made be public

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Government Auditing Standards

2018 Yellow Book• Published 07/17/2018• Effective for 06/30/2020 audits

– Early implementation is not permitted– However, nonaudit services could impact

independence as early as 07/01/2019

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Government Auditing Standards

2018 Yellow Book• Key changes:

– New format and organization– Threats to independence– CPE– Peer review– Waste and abuse– Reviews and performance audits

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Online Resources

• 2019 Compliance Supplement (PDF)– https://www.whitehouse.gov/omb/management/

office-federal-financial-management/• 2 CFR 200 Frequently Asked Questions

– https://cfo.gov/grants/uniform-guidance/• Data Collection Form

– https://harvester.census.gov/facides/• 2018 Yellow Book

– https://www.gao.gov/yellowbook/overview

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https://www.whitehouse.gov/omb/management/office-federal-financial-management/https://cfo.gov/grants/uniform-guidance/https://harvester.census.gov/facides/https://www.gao.gov/yellowbook/overview

Questions?

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For more information...

Stephen W. Blann, CPA, CGFM, CGMADirector of Governmental Audit [email protected]/government

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mailto:[email protected]://www.rehmann.com/government

2019 Single Audit UpdatePresented by:OutlineComponents of a Single AuditComponents of a Single Audit�Financial Statement AuditComponents of a Single Audit�Government Auditing StandardsComponents of a Single Audit�Compliance Audit of Federal AwardsUniform Guidance (2 CFR 200)Uniform Guidance (2 CFR 200)Uniform Guidance: AppendicesUniform Guidance (2 CFR 200) – Subpart D�Standards for Financial ManagementUniform Guidance (2 CFR 200) – Subpart D�Standards for Financial ManagementCPE Prompt 1 of 6Uniform Guidance (2 CFR 200) – Subpart D�Standards for Financial ManagementCOSO: Internal ControlThe Green BookComponents / Principles�Control EnvironmentComponents / Principles�Risk AssessmentComponents / Principles�Control ActivitiesComponents / Principles�Information and CommunicationComponents / Principles�Monitoring ActivitiesUniform Guidance (2 CFR 200)�Documenting IC over ComplianceCPE Prompt 2 of 6Uniform Guidance (2 CFR 200) – Subpart D�Standards for Financial ManagementUniform Guidance (2 CFR 200) – Subpart D�Standards for Financial ManagementUniform Guidance (2 CFR 200) – Subpart D�Standards for Financial ManagementUniform Guidance (2 CFR 200) – Subpart D�Standards for Financial ManagementUniform Guidance (2 CFR 200) – Subpart D�Standards for Financial ManagementUniform Guidance (2 CFR 200) – Subpart D�Standards for Financial ManagementUniform Guidance (2 CFR 200) – Subpart E�Federal Cost PrinciplesUniform Guidance (2 CFR 200) – Subpart E�Federal Cost PrinciplesUniform Guidance (2 CFR 200) – Subpart E�Federal Cost PrinciplesUniform Guidance (2 CFR 200) – Subpart E�Federal Cost PrinciplesUniform Guidance (2 CFR 200) – Subpart E�Federal Cost PrinciplesUniform Guidance (2 CFR 200) – Subpart E�Federal Cost PrinciplesUniform Guidance (2 CFR 200) – Subpart E�Federal Cost PrinciplesCPE Prompt 3 of 6Uniform Guidance (2 CFR 200) – Subpart F�Single AuditStages of a�Single AuditStages of a�Single AuditStages of a �Single AuditStages of a�Single AuditStages of a �Single AuditStages of a�Single AuditStages of a�Single AuditStages of a�Single AuditStages of a�Single AuditStages of a �Single Audit2 CFR 200, Appendix XI�Compliance Supplement2 CFR 200, Appendix XI�Compliance SupplementPart 1�Background, Purpose, and ApplicabilityPart 2�Matrix of Compliance RequirementsPart 2�Matrix of Compliance RequirementsCPE Prompt 4 of 6Part 3�Compliance RequirementsPart 3�Compliance RequirementsPart 3 – Compliance Requirements�A. Activities Allowed or UnallowedPart 3 – Compliance Requirements�B. Allowable Costs/Cost Principles Part 3 – Compliance Requirements�C. Cash ManagementPart 3 – Compliance Requirements�C. Cash ManagementPart 3 – Compliance Requirements�D. [Reserved]Part 3 – Compliance Requirements�E. EligibilityPart 3 – Compliance Requirements�F. Equipment/Real Property MgmtPart 3 – Compliance Requirements�G. Matching, Level of Effort, EarmarkingPart 3 – Compliance Requirements�H. Period of PerformancePart 3 – Compliance Requirements�I. Procurement, Suspension/DebarmentPart 3 – Compliance Requirements�I. Procurement, Suspension/DebarmentPart 3 – Compliance Requirements�I. Procurement, Suspension/DebarmentPart 3 – Compliance Requirements�J. Program IncomePart 3 – Compliance Requirements�K. [Reserved]Part 3 – Compliance Requirements�L. ReportingPart 3 – Compliance Requirements�M. Subrecipient MonitoringPart 3 – Compliance Requirements�M. Subrecipient MonitoringPart 3 – Compliance Requirements�N. Special Tests and ProvisionsCPE Prompt 5 of 6Part 4 �Agency Program RequirementsPart 5 �Clusters of ProgramsPart 6�Internal ControlPart 7�Programs Not Included in the CSSF-SAC�Data Collection FormSF-SAC�Data Collection FormSF-SAC�Data Collection FormCPE Prompt 6 of 6Government Auditing Standards�2018 Yellow BookGovernment Auditing Standards�2018 Yellow BookOnline ResourcesQuestions?For more information...

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