Definition
Under 2 CFR 200.518(b), Type A programs are federal programs with awards expended above a threshold that depends on the entity's total federal awards expended. For totals from $1,000,000 up to $34 million, the threshold is $1,000,000. Above that it scales: total times .03 up to $100 million, $3 million up to $1 billion, total times .003 up to $10 billion, $30 million up to $20 billion, and total times .0015 above that. Programs not labelled Type A are Type B.
Why it matters in an audit or review
The classification starts major program selection. The auditor identifies low-risk Type A programs, risk-assesses Type B programs above 25 percent of the Type A threshold, and audits as major programs all Type A programs that are not low-risk, the high-risk Type B programs, and enough others so that major programs cover at least 40 percent of total federal awards expended, or 20 percent for a low-risk auditee. Major programs get compliance testing. Wrong classification means the wrong programs get tested.
Example
Illustrative: an entity with $5 million in total federal awards uses a $1,000,000 Type A threshold. A program with $1.4 million expended is Type A. One with $700,000 is Type B, and because it exceeds $250,000 (25 percent of the threshold), the auditor risk-assesses it.
Common mistakes
Using the old $750,000 threshold, or not rechecking the table after OMB revisions.
FAQ
What makes a program major?
A Type A program that is not low-risk, or a Type B program the auditor identifies as high-risk, plus programs needed to reach the coverage requirement.
Sources
- 2 CFR 200.518, Major program determination: https://www.ecfr.gov/current/title-2/section-200.518
- 2 CFR 200.519, Criteria for Federal program risk
- 2 CFR 200.520, Criteria for a low-risk auditee
Definitions paraphrase AICPA and FASB guidance; read the standard itself before relying on a requirement. Example figures are illustrative. This page is guidance, not professional advice. Report an error