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Government Auditing Standards and Circular A-133 Audits -- AICPA Audit Guide

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Get ready to expand your knowledge of the auditing issues significant to entities subject to Government Auditing Standards and Circular A-133. Whether you're preparing your organization's financial statements or preparing for an auditing engagement, the AICPA Audit Guide Government Auditing Standards and Circular A-133 Audits provides you with the latest information on auditing issues and related financial statement considerations.

Updated with conforming changes as of October 1, 2009, the guide includes relevant guidance contained in official pronouncements issued through that date, supplemented with specific "how-to" recommendations. Information regarding SAS No. 115, Communicating Internal Control Related Matters Identified in an Audit is included.

You'll also want to check out the new chapter, "Audit Sampling Considerations of Circular A-133 Compliance Audits," which has been newly added in this edition. Also included in this edition are two practice aids "Illustrative Audit Program for the SEFA" and "Illustrative Disclosure Checklist for the SEFA" to assist in auditing the Schedule of Expenditures of Federal Awards. In addition, the guide briefly covers issues related to the American Reinvestment and Recovery Act. With all these must-have features, this guide is an essential reference for firms, small practitioners, and professionals who perform compliance audits and audits in accordance with Government Auditing Standards.

For a topical listing of subject matter by chapter, click on the Table of Contents tab.

Table of Contents

  • Chapter 1: Introduction
    • Purpose and Applicability
    • Definitions
    • Adherence to Professional Standards and Requirements
  • Part I: Government Auditing Standards Audits
    • Chapter 2: Planning Considerations of Government Auditing Standards
      • Overview
      • Relationship of Other Professional Standards and Government Auditing Standards
      • Government Auditing Standards—Ethical Principles
      • Government Auditing Standards—General Standards
        • Independence
        • Professional Judgment
        • Competence
        • Quality Control and Assurance
      • Government Auditing Standards—Fieldwork Standards
        • Auditor Communication
        • Considering the Results of Previous Audits and Attestation Engagements
        • Detecting Material Misstatements Resulting From Violations of Provisions of Contracts and Grant Agreements and Abuse
        • Developing Elements of a Finding
        • Audit Documentation
      • Additional Planning Considerations
        • Establishing an Understanding With the Auditee
        • Audit Materiality Considerations
        • Determining Compliance Requirements
        • Joint Audits
        • The Internal Audit Function
        • Communications With Other Entities
        • Exit Conference
    • Chapter 3: Financial Statement Audit Considerations of Government Auditing Standards
      • Introduction
      • Consideration of Internal Control Over Financial Reporting
        • GAAS Requirements
        • Additional Government Auditing Standards Requirements
      • Consideration of Financial Statement Misstatements, Including Compliance
        • GAAS Requirements
        • Additional Government Auditing Standards Requirements
      • Consideration of Abuse
      • Written Representations From Management
      • Reasonable Assurance
    • Chapter 4: Auditor Reporting Requirements and Other Communication Considerations of Government Auditing Standards
      • Overview
      • Government Auditing Standards—Reporting Requirements
        • Generally Accepted Auditing Standards Requirements
        • Government Auditing Standards—Additional Reporting Standards
      • Internal Control Over Financial Reporting
        • GAAS Requirements
        • Government Auditing Standards Requirements
      • Fraud, Illegal Acts, Violations of Provisions of Contracts or Grant Agreements, and Abuse
        • GAAS Requirements
        • Government Auditing Standards Requirements
      • Report on the Financial Statements
      • Report on Internal Control Over Financial Reporting and Compliance and Other Matters Based on an Audit of Financial Statements Performed in Accordance With Government Auditing Standards
      • Other Reporting and Communication Considerations
        • Findings Relating to the Financial Statements
        • Reporting Views of Responsible Officials and Planned Corrective Action
        • Other Written Communications
        • Portions of the Entity Not Audited in Accordance With Government Auditing Standards
        • Other Auditors
      • Freedom of Information Act and Similar Laws and Regulations
      • Assurance to Regulators and Oversight Agencies
      • Appendix A—Illustrative Auditor’s Reports Under Government Auditing Standards
      • Appendix B—Illustrative Auditor’s Reports Under Government Auditing Standards With SAS No. 115 Terminology
  • Part II: Circular A-133 Audits
    • Chapter 5: Overview of the Single Audit Act, Circular A-133, and the Compliance Supplement
      • Introduction
      • Single Audit Act and Circular A-133 Requirements
        • Objectives of a Single Audit
        • General Audit Requirements
        • Reporting Matters
        • Auditor Selection and Audit Costs
        • Basis for Determining When Federal Awards Are Expended
        • Subrecipient and Vendor Determinations
        • Major Program Determination
        • Auditee Responsibilities
        • Federal Awarding Agency Responsibilities
        • Pass-Through Entity Responsibilities
        • Cognizant Agency for Audit
        • Oversight Agency for Audit
        • Program-Specific Audits
      • OMB Circular A-133 Compliance Supplement
    • Chapter 6: Planning Considerations of Circular A-133
      • Introduction
      • Satisfying Circular A-133 Requirements
      • Establishing an Understanding With the Auditee
      • Audit Documentation
      • Additional Requirements of the Single Audit Act and Circular A-133 Regarding Audit Documentation and Audit Follow-Up
        • Audit Documentation Access and Retention
        • Audit Follow-Up
      • Financial Statement Audit Considerations
      • Defining the Entity to Be Audited
      • Determining the Audit Period
        • Fiscal Year and Program Period May Differ
        • Stub Periods
      • Initial-Year Audit Considerations
        • Preceding Period Audited by Another Auditor
        • Factors to Consider Under the Risk-Based Approach
      • Timing of the Completion of the Audit and Report Submission Deadlines
      • Determining the Major Programs to Be Audited
      • Audit Risk Considerations
        • Preliminary Assessment of Audit Risk
        • Components of Audit Risk
      • Assessing the Risk of Material Noncompliance
      • Audit Materiality Considerations
        • Materiality Differences Between the Financial Statement Audit and the Circular A-133 Compliance Audit
        • Materiality for Purposes of Reporting Audit Findings
      • Determining Compliance Requirements
      • Developing an Efficient Audit Approach
      • Joint Audits and Reliance on Others
      • Existence of an Internal Audit Function
      • Communications With the Cognizant or Oversight Agency for Audit and Others
      • Understanding the Applicable State and Local Compliance and Reporting Requirements
        • Impact on a Single Audit
        • Compliance Audits of State or Local Grants
        • Compliance Engagements Not Involving State or Local Governmental Financial Assistance
      • Desk Reviews and On-Site Reviews
      • Restriction on the Auditor’s Preparation of Indirect Cost Proposals
      • Appendix A—Proposed Compliance SAS
    • Chapter 7: Schedule of Expenditures of Federal Awards
      • Overview of Schedule Requirements
      • Identification of Federal Awards
        • Federal Agency and Pass-Through Entity Requirements
        • Auditee Requirements
      • Auditor Requirements Related to the SEFA
        • Issuing an “In Relation To” Opinion
        • Additional Auditor Requirements Relating to Compliance Audit Objectives
      • General Presentation Requirements
        • Basis of Accounting
        • Required Schedule Contents
        • Providing Additional Information
        • Schedule May Not Agree With Other Federal Award Reporting
        • Inclusion of Nonfederal Awards
        • Considerations Relating to State Awards
        • CFDA Number Not Available
      • Pass-Through Awards
        • Treatment of Pass-Through Awards
        • Commingled Assistance
      • Noncash Awards
        • Treatment of Noncash Awards
        • Determining the Value of the Noncash Awards Expended
        • Loan and Loan Guarantee Continuing Compliance Requirements
        • Documentation Requirements
      • Appendix A—Illustrative Schedules of Expenditures of Federal Awards
      • Appendix B—Schedule of Expenditures of Federal Awards Illustrative Tools
    • Chapter 8: Determination of Major Programs
      • Introduction
      • Applying the Risk-Based Approach
        • Step 1—Determination of Type A and Type B Programs
        • Step 2—Identification of Low-Risk Type A Programs
        • Step 3—Identification of High-Risk Type B Programs
        • Step 4—Determination of Programs to Be Audited as Major
        • Percentage-of-Coverage Rule
        • Documentation of Risk Assessment
        • Auditor Judgment in the Risk Assessment Process
      • Other Considerations Regarding the Risk-Based Approach
        • Deviation From Use of Risk Criteria
        • Federal Agency and Pass-Through Entity Requests for Additional Major Programs
        • Low-Risk Auditee Criteria
      • Criteria for Federal Program Risk
        • Current and Prior Audit Experience
        • Oversight Exercised by Federal Agencies and Pass-Through Entities
        • Inherent Risk of the Federal Programs
    • Chapter 9: Consideration of Internal Control Over Compliance for Major Programs
      • Summary of Circular A-133 Requirements Related to Internal Control Over Compliance for Federal Programs
        • Auditee Responsibilities
        • Auditor Responsibilities
      • Circular A-133 Definition of Internal Control Over Federal Programs
      • Control Objectives and the Elements of Internal Control
      • Auditor’s Consideration of Internal Control Over Compliance for Each Major Program
      • Obtaining an Understanding of Internal Control Over Direct and Material Compliance Requirements for Major Programs
        • Understanding Direct and Material Compliance Requirements and Identifying Relevant Controls
        • Compliance Supplement Internal Control Guidance
        • Multiple-Component Considerations
        • Subrecipient Considerations
      • Planning and Performing the Test of Operating Effectiveness of Internal Control Over Direct and Material Compliance Requirements for Each Major Program
        • Assessing Control Risk
        • Planning the Test of Operating Effectiveness of Internal Control Over Compliance for Each Major Program to Support a Low Assessed Level of Control Risk
        • Existence of Ineffective Internal Control in Preventing or Detecting Noncompliance
        • Performing Tests to Evaluate the Effectiveness of Controls
        • Evaluating the Results of Tests of Controls
        • Significant Deficiencies and Material Weaknesses Related to Federal Programs
      • Documentation Requirements
      • Consideration of Abuse
    • Chapter 10: Compliance Auditing Applicable to Major Programs
      • Compliance Objectives in a Circular A-133 Compliance Audit
      • Responsibilities of Auditee
      • Use of Professional Judgment
      • Audit Risk Considerations
      • Materiality Considerations
        • Materiality Judgments About Compliance Applied to Each Major Program Taken as a Whole
        • Effect of Material Noncompliance on the Financial Statements
      • Performing a Circular A-133 Compliance Audit
        • Identifying Major Programs to Be Tested
        • Identifying Direct and Material Compliance Requirements
        • Planning the Engagement
        • Consideration of Internal Control Over Compliance for Major Programs
        • Performing Compliance Testing
        • Consideration of Abuse
        • Consideration of Subsequent Events
        • Evaluation and Reporting of Noncompliance
        • Performing Follow-Up Procedures
      • Management Representations Related to Federal Awards
        • Suggested Representations
        • Refusal to Furnish Written Representations
      • State and Local Government Compliance Auditing Considerations
    • Chapter 11: Audit Sampling Considerations of Circular A-133 Compliance Audits
      • Introduction
      • Audit Sampling in a Circular A-133 Compliance Audit
        • Purpose and Nature of Audit Sampling in a Circular A-133 Compliance Audit
        • Audit Sampling in the Context of Other Audit Procedures
      • Procedures That May Not Involve Audit Sampling
        • Inquiry and Observation
        • Analytical Procedures
        • Procedures Applied to Every Item in a Population or Subpopulation in Compliance Testing
        • Individually Important Items in Compliance Testing
        • Understanding and Testing the Operating Effectiveness of Controls Over Compliance
      • Planning Considerations for Sampling Related to Tests of Controls Over Compliance and Compliance Testing
        • Determining Audit Objectives
        • Defining the Population and Considering Completeness
        • Considering the Effect of Population Size
        • Defining Control Deviation and Compliance Exception Conditions
        • Dual Purpose Samples Considerations
        • Determining the Sample Size
      • Selecting Sample Items for Testing
        • Random Selection
        • Haphazard Selection
        • Systematic Selection With a Random Start
      • Performing the Test Procedures
        • Investigate and Understand the Nature and Cause of Control Deviations and Compliance Exceptions
        • Determine If Additional Testing Is Warranted in Response to an Observed Deviation or Exception
      • Evaluating Sample Results
        • Evaluating Control Deviations
        • Reaching an Overall Conclusion on Tests of Controls
        • Evaluating Compliance Exceptions
        • Reaching an Overall Conclusion on Tests of Compliance
      • Documenting the Sampling Procedure
    • Chapter 12: Audit Considerations of Federal Pass-Through Awards
      • Introduction
      • Definitions
      • Applicability of Circular A-133
      • Pass-Through Entities, Subrecipients, and Vendors
        • Subrecipient Status Versus Vendor Status
        • Description of Relationships
        • Vendor Compliance Considerations
      • Single Audit Considerations of Pass-Through Entities
        • Pass-Through Entity Responsibilities
        • Audit Planning Considerations
        • Consideration of Internal Control Over Compliance
        • Subrecipient Monitoring
        • Reporting Considerations
        • For-Profit Subrecipients
        • Non-U.S.-Based Entities
        • State Designation of a Cluster of Programs
      • Circular A-133 Audit Considerations of Subrecipients
        • Additional Compliance Requirements Established by Pass-Through Entities
        • Information Included in the Schedule of Expenditures of Federal Awards
        • Audit Findings
        • Submission of the Report
    • Chapter 13: Auditor Reporting Requirements and Other Communication Considerations in a Single Audit
      • Overview
        • Circular A-133 Requirements
        • Reporting Package
        • Recommended Auditor’s Reports
      • Reporting on the Financial Statements and Supplementary Schedule of Expenditures of Federal Awards in Accordance With GAAS and Government Auditing Standards
        • Basis of Accounting
        • Implementing Regulations of Federal Awarding Agencies May Define the Entity to Be Audited Differently Than Does GAAP
        • Report on the Financial Statements and on the Supplementary Schedule of Expenditures of Federal Awards
      • Report on Internal Control Over Financial Reporting and on Compliance and Other Matters Based on an Audit of Financial Statements Performed in Accordance With Government Auditing Standards
      • Reporting on Compliance and Internal Control Over Compliance Applicable to Each Major Program
        • Material Instances of Noncompliance
        • Scope Limitations
        • Report on Compliance With Requirements Applicable to Each Major Program and on Internal Control Over Compliance in Accordance With Circular A-133
      • Communicating Other Findings to Management
      • Other Reporting Considerations
        • Dating of Reports
        • Other Auditors
        • When the Audit of Federal Awards Does Not Encompass the Entirety of the Auditee’s Operations
      • Schedule of Findings and Questioned Costs
        • What Should Be Reported
        • Findings Related to the Financial Statements
        • Findings Related to Federal Awards
        • Findings of Abuse
        • Detail of Audit Findings—Federal Awards
        • Other Preparation Guidance
      • Summary Schedule of Prior Audit Findings and Corrective Action Plan
      • Data Collection Form
        • Submission of Reporting Package and Data Collection Form
        • Submission by Subrecipients
        • Distribution of Reporting Package to Federal Agencies
      • Freedom of Information Act and Similar Laws and Regulations
      • Appendix A—Illustrative Auditor’s Reports Under Circular A-133
    • Chapter 14: Program-Specific Audits
      • Use of a Program-Specific Audit to Satisfy Circular A-133 Audit Requirements
      • Program-Specific Audit Requirements
      • Availability of Program-Specific Audit Guides
      • Auditee’s Responsibilities When a Program-Specific Audit Guide Is Not Available
      • Auditor’s Responsibilities When a Program-Specific Audit Guide Is Not Available
        • Audit Scope and Requirements
        • Auditor’s Reports
      • Evaluating and Reporting Abuse
      • Submission of Report
        • Timing of Submission
        • Submission When a Program-Specific Audit Guide Is Available
        • Submission When a Program-Specific Audit Guide Is Not Available
      • Appendix A—Illustrative Auditor’s Reports for Program-Specific Audits
  • Appendix
    • A: Single Audit Act Amendments of 1996
    • B: OMB Circular A-133, Audits of States, Local Governments, and Non-Profit Organizations
    • C: Schedule of Changes Made to the Text From the Previous Edition

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Excerpts

Purpose and Applicability

This Audit Guide (guide) provides guidance (chapters 1–4) on the auditor's responsibilities when conducting an audit of financial statements in accordance with Government Auditing Standards (also referred to as the Yellow Book), issued by the Comptroller General of the United States of the U.S. Government Accountability Office (GAO). This guide has been prepared using the Government Audit Standards, July 2007 Revision.

It also provides guidance (chapters 1 and 5–14) on the auditor's responsibilities when conducting a single audit or program-specific audit in accordance with the Single Audit Act Amendments of 1996 and Office of Management and Budget (OMB) Circular A-133, Audits of States, Local Governments, and Non-Profit Organizations. This guide was originally issued as Statement of Position (SOP) 98-3, Audits of States, Local Governments, and Not-for-Profit Organizations Receiving Federal Awards, in March 1998, and updated annually for conforming changes for relevant guidance contained in authoritative auditing standards and other requirements. The AICPA converted SOP 98-3 into an Audit Guide in 2003. That conversion did not supersede the guidance that appeared in SOP 98-3 but only changed its format. In 2009, the AICPA added to the content of the guide with the addition of chapter 11, "Audit Sampling Considerations of Circular A-133 Compliance Audits."

Concerning an audit of financial statements in accordance with Government Auditing Standards, this guide

•  describes the applicability of Government Auditing Standards.
•  discusses the relationship between generally accepted auditing standards and Government Auditing Standards.
•  discusses the general standards and additional fieldwork and reporting standards of Government Auditing Standards.
•  describes the auditor's responsibility for considering internal control over financial reporting, compliance with applicable laws, regulations, and provisions of contracts and grants agreements, fraud, and abuse.
•  describes the auditor's responsibility for reporting and other communications and provides examples of the required auditor's reports.

Concerning an audit of federal awards in accordance with Circular A-133,1 this guide

•  describes the applicability of and provides an overview of the requirements of the Single Audit Act Amendments of 1996 and Circular A-133.
•  discusses the relationship between Government Auditing Standards and Circular A-133.
•  describes the auditor's additional responsibilities for considering internal control over compliance with applicable laws, regulations, and program compliance requirements; performing tests of compliance with those requirements; and performing procedures on the schedule of expenditures of federal awards (SEFA).
•  discusses considerations in designing an audit approach that includes audit sampling to achieve both compliance and internal control over compliance related audit objectives in a Circular A-133 compliance audit.
•  describes the auditor's responsibilities in a program-specific audit.
•  describes the auditor's responsibility for reporting and provides examples of the required auditor's reports.

Further, this guide incorporates guidance from the following documents:

•  AU section 801A,* Compliance Auditing Considerations in Audits of Governmental Entities and Recipients of Governmental Financial Assistance (AICPA, Professional Standards, vol. 1)
•  Government Auditing Standards, July 2007 Revision
•  The Single Audit Act Amendments of 1996 and Circular A-133 (as revised by the Federal Register Notice on June 26, 2007) and the OMB Circular A-133 Compliance Supplement

1 In this guide, the use of the terms single audit or audit in accordance with Circular A-133 includes both the financial statement audit and the compliance audit that is performed under Circular A-133. The use of the term Circular A-133 compliance audit includes only the compliance audit that is performed under Circular A-133.

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