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

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This Audit Guide provides the latest information on auditing issues affecting entities that are subject to Government Auditing Standards (also referred to as the Yellow Book) and, if applicable, Office of Management and Budget (OMB) Circular A-133, Audits of States, Local Governments, and Non-Profit Organizations. A recent federal study showed that improvements are needed in the audits covered by this Guide so you should ensure you have it as part of your reference tools when performing these audits.

Updated with conforming changes as of August 1, 2008, it includes guidance on planning and performing audits under the July 2007 revision of Government Auditing Standards and OMB Circular A-133, as amended in June 2007. This edition of the guide has also been conformed to reflect the Defining Professional Requirements standards as found in SAS No. 102. Furthermore, it provides guidance on the auditor's responsibilities as set forth in SAS Nos. 112 and 114, including identifying, evaluating, and reporting deficiencies in internal control related to both financial reporting and compliance and the auditor's communications with those charged with governance.

The guide summarizes applicable requirements, guidance, and practices, and delivers "how-to" advice for handling audit issues common to entities reporting under Government Auditing Standards and OMB Circular A-133.

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
  • 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
    • Planning Considerations of Circular A-133—continued 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 Single 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 Circular A-133 Audit
      • Compliance Audits of State or Local Grants
      • Compliance Audits Not Involving Governmental Assistance
    • Desk Reviews and On-Site Reviews
    • Restriction on the Auditor's Preparation of Indirect Cost Proposals
  • 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 Schedule of Expenditures of Federal Awards
      • 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
  • 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
    • Single Audit Compliance Objectives
    • 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 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 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-
      • 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 Report
  • Chapter 12 -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
    • Auditor Reporting Requirements and Other Communication Considerations in a Single Audit—continued Submission of Reporting Package and Data Collection Form
      • Submission to Clearinghouse
      • Submission by Subrecipients
      • Requests for Copies
      • Report Retention Requirements
      • Clearinghouse Address
    • Freedom of Information Act and Similar Laws and Regulations
    • Appendix A—Illustrative Auditor's Reports Under Circular A-133
  • Chapter 13 -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
  • Appendix B - OMB Circular A-133, Audits of States, Local Governments, and Non-Profit Organizations
  • Appendix C - Comparison of Key Provisions of the Risk Assessment Standards to Previous Standards
  • Appendix D - 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 5-13) on the auditor's responsibilities when conducting a single audit or program-specific audit in accordance with the Single Audit Act Amendments of 1996 (the Single Audit Act) 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 (AICPA, Technical Practice Aids), 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.

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, this guide:

  • Describes the applicability of and provides an overview of the requirements of the Single Audit Act 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
  • 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 801, 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 and Circular A-133 (as revised by Federal Register Notice on June 26, 2007) and the OMB Circular A-133 Compliance Supplement

References to Professional Standards

In citing the professional standards, references are made to the AICPA Professional Standards publication. When referencing professional standards, this guide cites section numbers and not the original statement number, as appropriate. For example, SAS No. 54 is referred to as AU section 317.

Effect of PCAOB Standards on Entities Subject to Government Auditing Standards

The Public Company Accounting Oversight Board (PCAOB) establishes standards for audits of issuers, as that term is defined by the Sarbanes-Oxley Act of 2002 or whose audit is prescribed by the rules of the Securities and Exchange Commission (SEC). Other entities are referred to as nonissuers. Although many entities that are subject to Government Auditing Standards are nonissuers, some are issuers. Such issuers may include, for example, lending institutions that participate in federally sponsored loan programs such as housing and education. In December 2007, the GAO issued guidance titled "Guidance on Complying with Government Auditing Standards Reporting Requirements for the Report on Internal Control for Audits of Certain Entities Subject to the Requirements of the Sarbanes-Oxley Act of 2002 and Government Auditing Standards" that recognizes that the use of PCAOB's framework for assessing control deficiencies could result in inconsistencies in reporting internal control deficiencies under the Yellow Book. The GAO guidance facilitates the reporting of internal control deficiencies identified during audits conducted under both PCAOB and Yellow Book standards to ensure the consistency of information included in the Yellow Book report on internal control and to assist auditors in complying with Yellow Book standards. It is available on the Yellow Book Web site at www.gao.gov/govaud.ybk01.htm.

Effective Date

The provisions of this guide are applicable to audits of fiscal years beginning after June 30, 1996, in which the related fieldwork commences on or after March 1, 1998. The provisions of this guide, including conforming changes, that arise from AICPA auditing standards, Government Auditing Standards, the Single Audit Act, and Circular A-133 are effective as of the effective date of those standards and requirements. This guide does not change the effective dates of those standards and requirements. The auditing conforming changes made in this edition of this guide are effective for audits of financial statements for which sufficient appropriate audit evidence to support the opinion is obtained after its issuance, subject to the effective dates of the underlying authoritative pronouncements.

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Paperback 2008
Product# 012748
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