Rule Atlas
2 CFR Part 200: Uniform Guidance Compliance Audits: Subrecipient Monitoring and A-133
Under 2 CFR Part 200 (GASB / FASAB / GAO / OMB), uniform Guidance Compliance Audits: Subrecipient Monitoring and A-133 establishes the authoritative rules tested on the AGA CGFM. This lesson covers compliance audit requirements for federal awards under 2 CFR Part 200, focusing on subrecipient monitoring, SEFA preparation, and audit findings. VoraPrep verifies every threshold, worked table, and practice question below against the current AGA CGFM blueprint.
Current Statutory Thresholds & Limits in Effect
Core Statutory Concepts
| Feature | Uniform Guidance (2 CFR Part 200) | OMB Circular A-133 (Superseded) |
|---|---|---|
| Effective Date | December 26, 2014 (with updates) | Pre-December 26, 2014 |
| Scope | All federal awards | Federal awards to non-profits, states, local governments |
| Audit Threshold | $1,000,000 (increased from $750,000 under the 2024 2 CFR Part 200 Uniform Guidance revisions) in federal expenditures | $500,000 in federal expenditures |
| Subrecipient Monitoring | Detailed requirements for risk assessment, monitoring, and management decisions | General requirements for monitoring |
| Cost Principles | Consolidated into Subpart E | Separate circulars (A-87, A-21, A-122) |
| Internal Control | References COSO framework | References COSO framework |
A state agency, undergoing its annual Single Audit for the fiscal year ended September 30, 2025, has an audit finding related to its 'Temporary Assistance for Needy Families' (TANF) program (CFDA 93.558). The auditors identified material noncompliance with grant requirements regarding recipient eligibility documentation. According to 2 CFR Part 200.516, the audit finding must include all of the following elements, except:
Practitioner Application: Uniform Guidance Compliance Audits: Subrecipient Monitoring and A-133
A state agency receives a large federal grant and subsequently awards a portion of these funds to several local non-profit organizations as subrecipients. The state agency's internal audit team is preparing for its annual Single Audit. A critical question arises: to what extent is the state agency responsible for monitoring the compliance of its subrecipients with federal regulations, and how should this monitoring be documented and reported in the Schedule of Expenditures of Federal Awards (SEFA) and subsequent audit findings? The auditors must determine if the subrecipients' non-compliance could lead to questioned costs for the state agency, even if the state agency itself followed all direct federal requirements.
- The Uniform Guidance (2 CFR Part 200) consolidates and supersedes previous OMB circulars, including OMB Circular A-133, establishing government-wide requirements for federal awards. It outlines responsibilities for federal awarding agencies, pass-through entities, and recipients concerning financial management, audit requirements, and compliance. A key aspect is the pass-through entity's responsibility to monitor subrecipients to ensure compliance with federal award requirements.
- Subrecipient Monitoring Pass-through entities must perform specific monitoring activities to ensure subrecipients use federal funds in accordance with applicable laws, regulations, and the terms of the award. This includes: Evaluating subrecipient risk of noncompliance with federal statutes and regulations. Monitoring subrecipient activities through reports, site visits, or other means. Ensuring subrecipients have met audit requirements (e.g., Single Audit) and issuing management decisions on audit findings. Considering imposing specific conditions on subawards if a subrecipient is identified as high-risk.
Common AGA CGFM Distractors on 2 CFR Part 200
- 1Uniform Guidance (2 CFR Part 200) replaced OMB Circular A-133 and is the authoritative source for federal award requirements.
- 2Pass-through entities have significant responsibilities for subrecipient monitoring, including risk assessment, ongoing oversight, and ensuring subrecipients meet their own audit requirements.
- 3The SEFA must clearly identify federal awards and amounts passed through to subrecipients.
- 4Failure to adequately monitor subrecipients can lead to audit findings (e.g., material weaknesses in internal control) and questioned costs for the pass-through entity.
- 5The Single Audit threshold is $1,000,000 (increased from $750,000 under the 2024 2 CFR Part 200 Uniform Guidance revisions) in federal expenditures for the entity being audited.
Frequently Asked Questions: 2 CFR Part 200
What is the core rule under 2 CFR Part 200 (Uniform Guidance Compliance Audits: Subrecipient Monitoring and A-133)?
Under 2 CFR Part 200 (GASB / FASAB / GAO / OMB), uniform Guidance Compliance Audits: Subrecipient Monitoring and A-133 establishes the authoritative rules tested on the AGA CGFM. This lesson covers compliance audit requirements for federal awards under 2 CFR Part 200, focusing on subrecipient monitoring, SEFA preparation, and audit findings. VoraPrep verifies every threshold, worked table, and practice question below against the current AGA CGFM blueprint.
How is 2 CFR Part 200 tested on the AGA CGFM?
Uniform Guidance (2 CFR Part 200) replaced OMB Circular A-133 and is the authoritative source for federal award requirements. Pass-through entities have significant responsibilities for subrecipient monitoring, including risk assessment, ongoing oversight, and ensuring subrecipients meet their own audit requirements.
Where can I practice AGA CGFM questions on Uniform Guidance Compliance Audits: Subrecipient Monitoring and A-133?
Test yourself instantly with the free playable AGA CGFM question on this page, or launch VoraPrep's full AGA CGFM adaptive question bank, interactive lessons, and 1:1 exam simulator at voraprep.com/cgfm.