The formulas
- Low-risk only if audited as major in one of the two most recent periods, and in the most recent period: no material weakness, no modified opinion, and questioned costs not above 5% of expenditures
- No significantly increased risk from 200.519(c), follow-up, or personnel and systems changes
- No OMB-approved agency notice under 200.518(c)(2)
How it works
2 CFR 200.518(c)(1) sets the step-two test for each Type A program. The program must have been audited as major in at least one of the two most recent audit periods (the most recent period for a biennial audit). In the most recent period it must not have had a material weakness in the report on internal control for major programs, a modified opinion on the program, or known or likely questioned costs above five percent of its federal awards expended.
The auditor also considers whether the criteria in 200.519(c), audit follow-up, or changes in personnel or systems show significantly increased risk. Under (c)(2), OMB can approve an agency request that a program not be low-risk for a recipient, with notice at least 180 days before the fiscal year end. Type A programs that are not low-risk are audited as major under 200.518(e)(1).
Illustrative figures only. Check the result against your firm's methodology before relying on it.
Common questions
Is this the same as a low-risk auditee?
No. Low-risk auditee status under 200.520 is for the whole entity and sets the 20% coverage rule. This test is program by program.
Does the 5% test use known or likely costs?
Either one. The program fails when known or likely questioned costs exceed 5 percent, so test the likely amount, which includes the known amount.
What about a new Type A program?
A program not audited as major in either of the two most recent periods cannot be low-risk, so it is audited as major.
Sources
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