Monitoring of Single-Audit Findings

As part of its subrecipient monitoring functions, the Bureau of Federal Compliance (BFC) reviews the single-audit reports for federal grant subrecipients that receive federal grants from the New Hampshire Department of Education (NHDOE).

This monitoring is done to ensure that federal grants are used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of federal awards, a requirement given to the NHDOE in Title 2 of the Code of Federal Regulations (CFR), 200.331. This web page describes single-audit requirements for both subrecipients and the NHDOE, the monitoring process, and what you can expect if your organization’s single-audit contains findings.

As part of its subrecipient monitoring functions, the Bureau of Federal Compliance (BFC) reviews the single-audit reports for federal grant subrecipients that receive federal grants from the New Hampshire Department of Education (NHDOE). This monitoring is done to ensure that federal grants are used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of federal awards, a requirement given to the NHDOE in Title 2 of the Code of Federal Regulations (CFR), 200.331. This web page describes single-audit requirements for both subrecipients and the NHDOE, the monitoring process, and what you can expect if your organization’s single-audit contains findings.

Single Audit Certification Documents

Subrecipient Requirements

Subrecipient Single-Audit

An organization must have a single-audit conducted by an independent auditor if it expends $750,000 or more in total federal grant funds in that fiscal year. Total federal grant funds not only includes those received from the NHDOE, but also those received from any other source. This requirement is given in 2 CFR 200.501(a).

Submitting the Single-Audit Report

Subrecipients must submit their single-audits and other required data packages to the Federal Audit Clearinghouse (FAC) no later than nine months after the end of their fiscal year. If your organization receives federal grants funds, the NHDOE will send you a letter each fiscal year asking you if you will be submitting a single-audit or to certify that the requirement does not apply to your organization because you did not expend more than $750,000 in federal grant funds. This letter is generally sent out by the NHDOE in September.

Other Requirements for Subrecipients

Subrecipients of federal grant funds must comply with all of the single-audit requirements for auditees given in 2 CFR 200.508.

NHDOE Requirements

The NHDOE is required by 2 CFR 200.331(d)(3) and 200.521(a) and (c) to issue a management decision for all findings in a subrecipient's single-audit report that involve federal grants awarded by the NHDOE. The management decision states whether the agency sustains or does not sustain each single-audit finding and the reason for doing so.

The NHDOE must issue the management decision within six months of either the date it receives the single-audit report or the date the report is accepted by the Federal Audit Clearinghouse, whichever is earliest.

The NHDOE is also required to follow up with subrecipients to ensure they complete corrective actions that address the findings. The management decision includes any corrective actions that need to be completed and a deadline for completion. Some corrective actions may include an enforcement action that requires the subrecipient to return federal funds to the NHDOE. The NHDOE’s requirements to follow up on single-audit findings are given in 2 CFR 200.331(d)(2) and 200.521(a).

NHDOE's Single-Audit Monitoring Process

The BFC staff review each single-audit report and each finding related to federal grants administered by the NHDOE which has been identified by an independent auditor.

Sustaining or Not Sustaining Each Finding

BFC staff carefully review the single-audit report and the subrecipient's management response for each finding in making the determination to sustain or not sustain the finding. In general, BFC staff sustains a finding, unless they determine that at least one of the following is true:

  1. The independent auditor misinterpreted federal statute.
  2. There is new federal guidance that was not available to the auditor when the single-audit was conducted.

As part of their review, BFC staff verifies that the independent auditor applied the correct federal regulations when conducting the single-audit. If the independent auditor did not apply the correct regulations, BFC staff may not sustain the finding.

Findings with Questioned Costs

If your single-audit findings include questioned costs, BFC staff may correspond with you about specific questions related to the questioned costs.

BFC staff may also ask you about questioned costs not identified in the single-audit report, but which staff believes the independent auditor should have associated with a certain finding. In this situation, staff will instruct you to contact your independent auditor, who must calculate a questioned cost amount.

The Management Decision

Once the BFC staff decides to sustain or not sustain each of your organization's findings, they issue the management decision, which will give the reason for each decision. The management decision will include corrective actions required to address the findings and timeline to complete them.

Corrective Actions

If you have not already completed corrective actions to address each single-audit finding, your organization's management decision will include a specific required action and a deadline for completion. For example, if a finding was related to missing time and effort documentation, NHDOE may require you to submit a copy of your internal policies and procedures to demonstrate that you have addressed the documentation issue. The NHDOE will provide your organization with a standardized Subrecipient Response Report template which can be used to outlined your corrective actions for each finding.

Enforcement Actions

If the NHDOE sustains findings with questioned costs, it may disallow the costs and impose a corrective action that requires your organization to return funds to the NHDOE. Your organization's management decision will include the refund amount, the deadline for submitting the refund, and other information.

Your organization may also have to complete corrective actions for findings with questioned costs.

Notice of NHDOE Policy

The NHDOE conducts federal fiscal grant subrecipient monitoring and compliance reviews, and implements related enforcement actions, in accordance with its established policies and procedures. These policies and procedures incorporate best practices and standards that may be similar to common auditing standards, but the NHDOE does not apply a specific set of external standards, such as the US Government Accountability Office’s Generally Accepted Government Auditing Standards (Yellow Book), nor is it required to do so.