The formulas
- Major program: report known questioned costs when known or likely questioned costs > $25,000 for a type of compliance requirement
- Not audited as major: report known questioned costs > $25,000
How it works
2 CFR 200.516(a)(3) requires the auditor to report known questioned costs as an audit finding when either known or likely questioned costs are greater than $25,000 for a type of compliance requirement for a major program. The finding must give information that puts the questioned costs in perspective, such as how prevalent they are.
For a program not audited as major, 200.516(a)(4) requires reporting known questioned costs greater than $25,000 that the auditor becomes aware of, for example through audit follow-up. The auditor is not required to perform procedures on such programs, so this situation is uncommon.
Illustrative figures only. Check the result against your firm's methodology before relying on it.
Common questions
What are likely questioned costs?
AU-C 935 .11 defines them as the auditor's best estimate of total questioned costs, not just the known questioned costs, developed by extrapolating from the audit evidence.
Is the threshold per program?
For major programs it is per type of compliance requirement, such as allowable costs or eligibility.
Is $25,000 the current threshold?
Yes. The eCFR text of 200.516, as revised effective October 1, 2024, states $25,000.
Sources
- 2 CFR 200.516 Audit findings, eCFR (text as revised effective October 1, 2024)
- AICPA AU-C Section 935, Compliance Audits (paragraph .11, definition of likely questioned costs)
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