At a glance
The Centers for Disease Control and Prevention (CDC) is receiving questions from its foreign-based recipient community regarding audits.
Overview
The Centers for Disease Control and Prevention (CDC) is receiving questions from its foreign-based recipient community regarding audits and has compiled a list of Frequently Asked Questions (FAQs). As CDC receives additional questions, CDC will update these FAQs. If recipients have additional or clarification questions about audits, please reach out to GrantsAudit@cdc.gov.
Frequently Asked Questions
Foreign-based recipients and sub-recipients are defined consistent with the terms “foreign organization” and “foreign public entity” as set out in grants regulations found at 2 CFR Part 200.1. For the purposes of CDC’s audit processes and these FAQs, CDC uses the broader terms "foreign-based recipient" or "sub-recipient" as inclusive of these defined terms. A foreign-based recipient or subrecipient is defined as a recipient headquartered in a foreign country that is performing grant activities in a foreign country.
Per 2 CFR Part 200.501, a recipient must have a single or program-specific audit conducted for that fiscal year if the non-federal entity expends $1,000,000 or more in total on all U.S. government grants during the non-federal entity's fiscal year. Agencies may not increase the threshold; however, they do have the authority to lower the threshold.
As a policy matter, CDC has lowered the threshold for foreign-based recipients and sub-recipients, requiring those foreign-based recipients and sub-recipients to conduct audits if they expend $300,000 or more under all U.S. government grants during the recipient's fiscal year. When a single audit is not required, the foreign-based recipient may elect to have a program-specific audit conducted in accordance with 2 CFR Part 200.501.
A single audit includes an audit of both the financial statements and federal awards. Program-specific audits do not require a financial statement audit (2 CFR Part 200.501(c)). However, when a program-specific audit guide is not available, a program-specific audit must consist of the financial statement(s) of the federal program, a summary schedule of prior audit findings, and a corrective action plan (2 CFR Part 200.507(b)).
Awards to foreign-based recipients are subject to 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subparts A–F. Though the grants regulations do not specify application of Subpart F (Audit Requirements) with respect to foreign-based recipients, CDC has determined that the same principles may be applied to these recipients.
Per 2 CFR Part 200.514(a), audits must be conducted in accordance with generally accepted government auditing standards. Foreign-based recipients should refer to the (referred to as the Yellow Book) for guidance. The identify generally accepted government auditing standards (GAGAS) for use by auditors of government entities. Foreign countries and in-country jurisdictions may apply additional audit standards, such as the auditing standards promulgated by the or the auditing guidelines of the .
Applicable administrative requirements, cost principles, and audit requirements are set out in the Terms and Conditions (T&C) of the recipient's Notice of Award (NoA). The terms and conditions of federal awards apply to subrecipients unless the terms and conditions of the award specifically indicate otherwise. If any requirement in the NoA, Notice of Funding Opportunity (NOFO), the HHS Grants Policy Statement, 2 CFR Part 200, or applicable statutes/appropriations acts conflict, then statutes and regulations take precedence.
CDC requires that the auditor used by a foreign-based recipient be a U.S.-based Certified Public Accountant firm or the foreign government’s Supreme Audit Institution or equivalent. CDC may review as necessary any audits received to ensure the firm meets GAGAS requirements.