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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

Audit Requirements

Ninth Annual NIH SBIR/STTR Conference

Las Vegas, Nevada

February 26-27, 2007

audit who said anything about having an audit
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

can we get that in plain english
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
what is the audit period
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.
what type of audit is required
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.
slide6
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

what is covered in the audit
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
is there a due date
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
slide9
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.
okay the auditors have done their work and the audit is complete now what
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

what happens next
What happens next?
  • 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
great i didn t expend more than 500 000 in hhs funds this year so i m off the hook right
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.
why why why
Why? Why? Why?
  • Why an audit?
  • Why is it important to the Federal Government?
  • Why is it important to you?
where can i get more information
Where can I get more information?

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

questions
Questions?

Lorraine Trexler

Chief,

Special Reviews Branch

Division of Financial Advisory Services

[email protected]

301-496-4494

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