School Food Authorities (SFAs) expending more than $500,000 in Federal dollars must conduct single audits in accordance with OMB Circular A-133.

Both Federal regulations (3052.225) and Circular A-133 mandate that State agencies take immediate corrective action when sub-recipients (SFAs) either do not conduct single audits, or conduct single audits not in accordance with A-133.

The performance of a single audit in accordance with A-133 is the primary, at times, the only assurance that sub-recipients (SFAs) have expended Federal funds in accordance with Federal regulations. If a single audit is not conducted, or not conducted properly, the total grant award may be considered a "questioned cost".

State agencies must also ensure that sub-recipients (SFAs) are procuring audit services in accordance with A-133. Sub-grantees, as well as grantees, must conduct all procurement in a manner providing for full and open competition. The auditor's, or the auditing firm's, objectivity must never be brought into question. Only by ensuring that full and open competition has occurred can USDA determine and conclude the objectivity of the single audit.

Refer to OMB Circular A-133, Subpart B-Audits, .225, Sanctions; Uniform Administrative Requirements for Grants and Cooperative Agreements to State and Local Governments; Circular A-110, Uniform Administrative Requirements for Grants and Agreements With Institutions of Higher Education, Hospitals and Other Non-Profit Organizations, for further information on the above issues.

Another issue that has surfaced is that SFAs are requesting extensions of the due date for their A-133 audits covering fiscal year 2009 through 2011. State Agencies have been directed not to approve grantee (SFA) requests for such extensions. This requirement improves accountability of all Federal funds and also assures uniform application of the reporting requirement to all recipients (SFAs).

If an SFA is subject to the requirement of Single Audits, they must comply with all audit requirements, including the required filing date.

SFAs are compromising their ability to participate in the federal child nutrition programs and subsequently to receive federal funds for those meals when they opt not to fully cooperate with the federal audit requirements. Penalties are much harsher now and can result in the termination of the program which in turn can ultimately result in an SFA being declared ineligible to participate in the Child and Adult Care Food Program, and the Summer Food Service Program as well as the National School Lunch Program and the School Breakfast Program. USDA will be establishing the disqualification requirements as a result of passage of the Healthy, Hunger Free Kids Act of 2010 in order to comply with Section 362 of the Act.

Questions on A-133 Audit requirements should be directed to Paula Tyner-Doyle at 518-474-3279.