If the combined total comes from expenditures in more than one grant program, a Single Audit is required. This allows monitoring standards to be tailored to the unique circumstances of each agency, subrecipient, and grant program.Īudits are required when a subrecipient expends $750,000 or more in a single fiscal year. Beyond that, significant flexibility is granted in the design, methodologies, and tools of the monitoring program. Programs should be monitored using the requirements of the Uniform Guidance and other applicable Federal, state, and local policies, guidance, and regulations, as well as the grant award terms and conditions and any additional subaward conditions imposed by the pass-through agency. Monitoring must encompass both fiscal compliance and programmatic performance. The terms of the Uniform Guidance are clear: monitoring is mandatory. To illustrate an example, an auditors might ask, “Does the amount expended on science textbooks fall within the budgeted allotment, and is there sufficient documentation to confirm payment and receipt” while Monitors have the flexibility to be more probing and ask, “Why didn’t students have a copy of the science textbooks-books purchased with grant funds-at the beginning of the year?” Auditing is typically not concerned with whether a program achieved its goals, its impact on end users, or the strategic value of one type of expenditure vs. Other types of financial audits-which are not mandated by the Uniform Guidance-are frequently conducted to determine whether an organization’s financial statements are accurate. Single Audits, by contrast, focus solely on fiscal compliance. Monitoring is designed “to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations,Īnd the terms and conditions of the subaward and that subaward performance goals are achieved” ( 2 CFR 200.332(d)). The most important distinction between monitoring and any form of auditing is this: monitoring includes both fiscal compliance and programmatic performance and, through the use of tools such as technical assistance, is intended to guide grantees in best practices. The major difference is in the standards used to measure compliance and what the purpose of each approach is. Both require assessments of risk, internal controls, and whether funds are allowable. Put another way, monitoring and Single Audits can be viewed as sisters-they have a lot in common, but they are distinct practices conducted at different times and governed by different sets of rules and expectations. being subject to audit findings, or worse, being required to return funds). To answer that question, we’ll examine three types of oversight: monitoring, Single Audits, and financial audits.įor an abbreviated copy of this resource, download our oversight comparison chart.Īt the Vander Weele Group, we like to say that monitoring is the preventative medicine that keeps you out of the emergency room (i.e. But what does that require, and how is it different from auditing? Subpart D of the Uniform Guidance states that non-Federal entities-for example, state agencies-that receive and distribute Federal grants (“subawards”) to subrecipients-such as municipal governments and nonprofit organizations-are responsible for monitoring the use of those funds. Even ensuring that Single Audits (formerly called A-133 audits) are conducted doesn't fulfill the legal requirement to monitor Federally funded programs, as laid out in 2 CFR Part 200 (also called the Uniform Guidance). The Inspector General’s office cited all of these findings in audit reports like the ones referenced above-reports which are now part of the public record.įor pass-through agencies, requiring simple financial auditing isn’t enough. Department of Housing and Urban Development’s Office of the Inspector General. Failing to monitor subrecipients, poor internal controls, insufficient documentation, and improperly conducted risk assessments are common findings of watchdog agencies, like the U.S.
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