SEFA: How to Prepare the Schedule of Expenditures of Federal Awards

The schedule of expenditures of federal awards, or SEFA, is the schedule that decides how much audit work a single audit involves. Its total tells you whether the entity crossed the audit threshold. Its program lines drive the major program determination. Its accuracy is tested by the auditor but its preparation belongs to the auditee. Most single audit findings about the SEFA come from the same few problems: missing awards, wrong identifying numbers, and no reconciliation to the ledger.

This guide sets out the requirements in the Uniform Guidance, the preparation steps, and a worked example. For the whole single audit process see the single audit walkthrough.

What is the SEFA and who prepares it?

Under 2 CFR 200.510(b), the auditee must prepare a schedule of expenditures of federal awards for the period covered by its financial statements. It must include the total federal awards expended, determined under 200.502. The auditee may add information that federal agencies or pass-through entities request to make the schedule easier to use, for example separate lines by award year.

The auditor's role is to determine whether the schedule is stated fairly in all material respects in relation to the financial statements as a whole (2 CFR 200.514(b)). Practically, the auditor reports on it as supplementary information accompanying the financial statements. See the supplementary information entry and the SEFA glossary entry.

A firm that prepares the SEFA for an audit client is providing a nonattest service. Management must still take responsibility for it. The firm applies the safeguards in the nonattest services checklist.

When is a single audit required?

A non-federal entity that expends $1,000,000 or more in federal awards in its fiscal year must have a single audit or, in limited cases, a program-specific audit (2 CFR 200.501). An entity that expends less is exempt from the federal audit requirement for that year, although its records must be available for review by federal officials, pass-through entities and GAO. The $1,000,000 level applies to fiscal years beginning on or after October 1, 2024; before that the threshold was $750,000. For a calendar-year entity the first year at the higher level is the year beginning January 1, 2025.

What does 2 CFR 200.510(b) require the schedule to show?

The schedule must:

1. List individual federal programs by federal agency using the Assistance Listing number. For a cluster, give the cluster name, list the programs in it and show the agency and the Assistance Listing numbers. For research and development, show total expended either by individual award or by agency and major subdivision within the agency.
2. For awards received as a subrecipient, show the name of the pass-through entity and the identifying number the pass-through entity assigned.
3. Show total federal awards expended for each program and its Assistance Listing number or other identifying number if none is available, and the total for each cluster.
4. Include the total amount provided to subrecipients from each program.
5. For loans and loan guarantees covered by 200.502(b), disclose the outstanding balances at the end of the audit period in the notes, in addition to including the awards expended.
6. Include notes describing the significant accounting policies used to prepare the schedule and whether the auditee elected the de minimis indirect cost rate of up to 15 percent.

How do you decide what counts as expended?

2 CFR 200.502 bases the determination on when the activity related to the award occurs, meaning the events that require compliance with federal rules and award terms. Examples in the section include expenditures under grants and cooperative agreements, disbursements to subrecipients, use of loan proceeds, receipt of property, receipt or use of program income, and the period insurance is in force.

Specific rules to remember:

• Loans. Count the value of new loans made or received during the period, plus the balance from earlier years for loans with continuing compliance requirements, plus any interest subsidy or administrative allowance (200.502(b)). Prior loans with no continuing requirement other than repayment are excluded.
• Noncash assistance. Value donated property, surplus property and food commodities at fair market value at receipt or at the value the agency assessed (200.502(g)).
• Contractors versus recipients. Payments for goods or services provided as a contractor under a federal award are not subject to audit under this part (200.501(g)). The classification between subrecipient and contractor follows 200.331.
• Medicare. Medicare payments for patient care services are not federal awards under this part (200.502(h)).

Steps to build the schedule

1. Inventory every award. Pull award letters, subaward agreements, reimbursement requests and grant ledgers. Include awards received through pass-through entities, which are the ones most often missed.
2. Classify each source. Federal award, state award, contract for services, or exchange transaction. A pass-through's letter may or may not carry federal identifiers, so read the terms.
3. Find the Assistance Listing number. The number comes from the award document or the Assistance Listings on SAM.gov. If none is available, use the identifying number the agency gave.
4. Determine amounts expended under the 200.502 basis, not cash received. Reimbursement timing, advances and unspent balances do not drive the number.
5. Identify clusters using the definitions and the Compliance Supplement list so that clustered programs are totalled together.
6. Compute subrecipient pass-through amounts for each program.
7. Write the notes: basis of accounting, indirect cost rate election, loan balances and any noncash assistance.
8. Reconcile to the ledger and financial statements and resolve each difference.

Worked example (illustrative)

A nonprofit with a calendar-year 2026 fiscal year has these federal awards.

The total is 450,000 + 300,000 + 180,000 + 95,000 = $1,025,000, which exceeds $1,000,000. A single audit is required, and the notes also state the basis of accounting and whether the 15% de minimis indirect cost rate was used.

Reconciliation to the financial statements:

The program names and numbers above are examples. Always take the number and identifier from the actual award documents.

Errors that cause findings

• A pass-through award left off because the entity's records show the pass-through as the funding source.
• Wrong or missing Assistance Listing numbers, or clusters not grouped.
• Revenue figures used in place of expenditures.
• No subrecipient column or amounts that do not agree to the payments ledger.
• Loan balances omitted from the notes.
• A SEFA that does not reconcile to the financial statements.

The Compliance Supplement checklist, the major program determination worksheet and the uniform guidance checklist pick up from the schedule. The reporting package is due within 30 calendar days after the auditee receives the auditor's report or nine months after the end of the audit period, whichever is earlier (2 CFR 200.512(a)).

Frequently asked questions

Who prepares the SEFA, the auditor or the client?

The auditee is responsible for preparing it under 2 CFR 200.510(b). The auditor tests it. If the audit firm helps prepare it, the work is a nonattest service and management must take responsibility.

What goes in the notes to the SEFA?

Notes describe the significant accounting policies used to prepare the schedule and say whether the auditee used the de minimis indirect cost rate of up to 15 percent. Notes also show loan or loan guarantee balances outstanding at the end of the period where required.

Is a pass-through award included?

Yes. Awards received as a subrecipient are federal awards expended and appear with the pass-through entity's name and its identifying number.

What if I cannot find an Assistance Listing number?

Show the identifying number provided by the agency or pass-through entity. The regulation permits another identifying number when Assistance Listing information is unavailable.

Sources

• OMB, 2 CFR 200.510, Financial statements (SEFA content): https://www.ecfr.gov/current/title-2/section-200.510
• OMB, 2 CFR 200.502, Basis for determining Federal awards expended: https://www.ecfr.gov/current/title-2/section-200.502
• OMB, 2 CFR 200.501, Audit requirements, and 200.514, Scope of audit, 200.512, Report submission: https://www.ecfr.gov/current/title-2/part-200/subpart-F
• OMB, Uniform Guidance revisions effective for fiscal years beginning on or after October 1, 2024 (single audit threshold of $1,000,000): https://www.cbiz.com/insights/article/omb-issues-most-substantial-revision-to-uniform-guidance-in-10-years
• GSA, Assistance Listings on SAM.gov: https://sam.gov/content/assistance-listings
• AICPA, AU-C Section 725, Supplementary Information in Relation to the Financial Statements as a Whole

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AU-C references are to AICPA Professional Standards, paraphrased here; read the standard itself before relying on a requirement. This page is guidance, not professional advice. Report an error