Is OMB Circular A-133 still in effect?
No. OMB Circular A-133 is no longer in effect. OMB set the Single Audit rules under it until 2014, then replaced it and raised the spending threshold twice.
OMB replaced the circular with the Uniform Guidance at 2 CFR Part 200, Subpart F, which federal agencies implemented for fiscal years beginning on or after December 26, 2014. When somebody asks you for an A-133 audit today, they are asking for a Single Audit under the Uniform Guidance.
What Was OMB Circular A-133
OMB used A-133 to establish Single Audit requirements for organizations that received and expended federal funds. OMB applied it to:
- Nonprofit organizations
- State and local governments
- Public and nonprofit educational institutions
Under A-133, entities that expended $500,000 or more in federal awards in a fiscal year had to obtain a Single Audit or, when eligible, a program-specific audit. OMB set that $500,000 figure for fiscal years ending after December 31, 2003.
What Changed with the Uniform Guidance
OMB raised the Single Audit threshold twice after A-133, from $500,000 to $750,000 and then to $1,000,000.
OMB consolidated A-133, A-87, A-122 and five other circulars and guidance sources into the Uniform Guidance, 2 CFR 200.
Auditors still use a risk-based process under the Uniform Guidance to identify major federal programs.
Recipients must document effective controls over federal awards, and auditors test controls over compliance for major programs.
From A-133 to the Uniform Guidance
Single Audit threshold timeline
What replaced OMB Circular A-133, and what the threshold is now.
Until December 2014
OMB Circular A-133
Single Audit rules for states, local governments, nonprofits and public or nonprofit colleges
Threshold: $500,000 in federal awards expended
Fiscal years beginning on or after December 26, 2014
Uniform Guidance, 2 CFR 200 Subpart F
OMB superseded A-133 and consolidated it with seven other OMB circulars
Threshold: $750,000 in federal awards expended
Fiscal years beginning on or after October 1, 2024
Uniform Guidance, 2024 revision
The rule in force today, under 2 CFR 200.501
Threshold: $1,000,000 in federal awards expended
Dimov Audit
Current Single Audit Requirements
A non-federal entity that expends $1,000,000 or more in federal awards during a fiscal year beginning on or after October 1, 2024 must obtain a Single Audit. It may elect a program-specific audit only under the conditions in 2 CFR 200.501. The Federal Audit Clearinghouse applies the older $750,000 figure to audit periods that began before that date. An organization at that level must:
Have the audit performed under GAGAS, the Government Auditing Standards commonly called the Yellow Book.
Prepare a Schedule of Expenditures of Federal Awards (SEFA), reporting total federal awards expended for each program.
File the reporting package with the FAC within 30 calendar days of receiving the auditor's report, or nine months after the audit period ends, whichever comes first, under 2 CFR 200.512.
Check whether your organization needs a Single Audit
Send us your federal award listing for the year and we will tell you whether you need a Single Audit and what the audit would cover.
Other OMB circulars the Uniform Guidance replaced
- A-87.
- OMB superseded A-87 when it issued the Uniform Guidance. State, local and tribal governments now use the cost principles in Subpart E of 2 CFR Part 200 for applicable awards, subject to the award and program rules in section 200.101.
- A-122.
- OMB superseded A-122 when it issued the Uniform Guidance. Nonprofits now use the cost principles in Subpart E of 2 CFR Part 200. You find which provisions apply in your award terms, the program rules and section 200.101, and federal law sets some exceptions.
- The A-133 Compliance Supplement.
- OMB still issues it, as Appendix XI to 2 CFR Part 200. Auditors use it to identify the compliance requirements and suggested procedures for covered federal programs, in the edition for the period under audit.
Related Single Audit guidance
- What triggers a Single Audit
- Yellow Book audit compared with a Single Audit
- Single audit compared with a regular audit
- Non-profit organization audits
Treat the information as general guidance, not advice for your circumstances. Ask a CPA to review your federal award listing before deciding whether you need a Single Audit.
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Tell us how much federal money your organization expended last year and which programs it came from. We will tell you what the Uniform Guidance requires of you and what the work involves.
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Reviewed by George Dimov, CPA. Dimov Audit performs Single Audits and Yellow Book audits for organizations that spend federal award money, across all 50 states.