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OMB A-133 Audits Due by September 30th

December 11, 2010 / Ed Jameson / Blog Posts
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For-Profit organizations (including SBIR/STTR) receiving grants in excess of $500,000 per fiscal year are required to file an OMB A-133 audit before September 30th, 2010. Many times, for-profit organizations believe they are not required to submit this audit, but that is in fact not the case! Failure to perform this audit can lead to future proposals being rejected!

To clear up this frequently asked question, we have posted the specific for-profit regulations.

We have performed this audit thousands of times with an exceptional reputation at the Division of Financial Advisory Services (DFAS), and have an expert understanding of the regulations.

To inquire further about this audit and your questions, call our office at 781-862-5170 before the September 30th deadline.

Clarification of Audit Requirements of For-Profit Organizations Including SBIR/STTR

The Department of Health and Human Services (HHS) has specified requirements for non-Federal audits of for-profit (commercial) organizations in HHS’ Title 45, Code of Federal Regulations (CFR), Part 74.26 , “Non-Federal Audits.” Per the regulations, a for-profit (commercial) organization is subject to audit requirements for a non-Federal audit if, during its fiscal year, it expended $500,000* or more under HHS awards and at least one award is a HHS grant or subgrant. Title 45 CFR Part 74.26 essentially incorporates the thresholds and deadlines of Office of Management and Budget (OMB) Circular No. A-133, “Audits of States, Local Governments and Non-Profit Organizations,” but provides for-profit organizations with two options regarding the type of audit that will satisfy the audit requirements either:

1. a financial related audit (as defined in the Government Auditing Standards, GPO Stock #020-000-00-265-4, of the HHS awards in accordance with Government Auditing Standards, or

2. an audit that meets the requirements contained in OMB Circular No. A-133

[* Note: The threshold was $300,000 for audits of fiscal years ending before January 1, 2004.]

Audits shall be completed and submitted to the following office within a period of time that is either (1) the earlier of 30 days after receipt of the auditor’s report(s), or (2) nine months after the end of the audit period (that is, the organization’s fiscal year):

U.S. Department of Health and Human Services
OIG/Office of Audit Services
1100 Walnut Street, Suite 850
Kansas City, Missouri 64105-2250

816-426-7720 (Main Office Number)
816-426-7730 (Technical Assistance)
816-426-7745 (fax)

The HHS will be identifying organizations not meeting audit requirements. Failure to comply may jeopardize eligibility for receiving future HHS awards.

For more information about audit requirements, see the information posted at the NIH Division of Financial Advisory Services website, Non-Federal Audit Requirements for Commercial (For-Profit) Organizations

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Ed Jameson, CPA, Managing Partner

I’ve been in practice for over 40 years helping our small business clients procure, manage, and survive audits on more than $6 billion in federal government contract and grant funding. We’ve been featured presenters and panel moderators at Tech Connect’s National SBIR/STTR conferences since 2010, and I’ve presented at the DOD’s Mentor Protégé Summit and present regularly for several state and local organizations.