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Audit Requirements Ninth Annual NIH SBIR/STTR Conference Las Vegas, Nevada February 26-27, 2007 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 Title 45 CFR Part 74.26(d)*

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Audit requirements l.jpg

Audit Requirements

Ninth Annual NIH SBIR/STTR Conference

Las Vegas, Nevada

February 26-27, 2007


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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 Title 45 CFR Part 74.26(d)*

* http://www.gpoaccess.gov/cfr/retrieve.html


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Can we get that in plain English?

A for-profit organization is required to

have an audit if:

  • it expended $500,000 or more under HHS awards in the fiscal year

    AND

  • at least one of the awards is an HHS grant


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What is the audit period?

  • The audit period is the awardee’s fiscal year, not the grant budget period, the grant project period or the Government’s fiscal year.


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What type of audit is required?

  • 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 requirement.


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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


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What is covered in the audit?

The auditors, among other things, will be looking at:

  • Your internal controls and the adequacy of your accounting system

  • Compliance issues such as

    • Allowable costs/ Cost Principles

    • Cash Management

    • Property Management

    • Reporting


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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 the earlier of:

  • 30 days after receipt of the auditor’s report

    or

  • 9 months after the end of the audit period


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Does a for-profit auditee have to submit a completed Data Collection Form (SF-SAC) as required by OMB Cir A-133?

  • No. Regardless of the audit option chosen, the for-profit auditee is not required to submit a Data Collection Form.


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

  • Audit reports of for-profit organizations should be submitted to:

    National External Audit Review Center

    HHS Office of Audit Services

    323 West 8th Street

    Lucas Place, Room 514

    Kansas City, MO 64105


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What happens next? complete. Now what?

  • NEAR will process the audits—checking for adequacy and to identify audit findings

  • NEAR will code each finding for tracking purposes and distribute the reports to the awarding component

  • The Special Reviews Branch of DFAS is responsible for resolving all findings coded by NEAR relating to NIH awards


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Great, I didn’t expend more than $500,000 in HHS funds this year so I’m “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.


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Why? Why? Why? this year so I’m “off the hook,” right?

  • Why an audit?

  • Why is it important to the Federal Government?

  • Why is it important to you?


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Where can I get more information? this year so I’m “off the hook,” right?

There are frequently asked questions (FAQs) related to non-federal audit requirements for commercial (for-profit) organizations at the following URL:

http://oamp.od.nih.gov/dfas/faqforprofitaudits.asp


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Questions? this year so I’m “off the hook,” right?

Lorraine Trexler

Chief,

Special Reviews Branch

Division of Financial Advisory Services

[email protected]

301-496-4494


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