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Uniform Guidance, in writing and in practice

We write the policies 2 CFR 200 requires, fix the processes behind them and run a mock single audit.

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Part of
Compliance Documentation
Runs as
4 stages, from map the awards to readout
You receive
6 deliverables, listed below
Pricing
Quoted after a scoping call

Crossing $1 million changes the year

For fiscal years beginning on or after 1 October 2024, a non-federal entity that spends $1,000,000 or more in federal awards in a year needs a single audit, up from $750,000. Some organizations dropped below the line. Others, growing into larger awards, will cross it for the first time. A single audit tests more than the financial statements: the auditor also tests compliance with award requirements and the internal controls over each major program, against the written policies 2 CFR 200 requires.

The requirements sit in the details. A procurement policy that does not reflect the federal standards. Salary charges built from budgets rather than actual work. A subrecipient that was never risk-assessed. Equipment bought with grant money and missing from the inventory. Each is fixable, but not in the month before fieldwork.

Engraving of a canal splitting through sluice gates into separate fields, one gate wheel in magenta.
Restricted funds flow in marked channels.

Policies the regulation expects in writing

  • Procurement and conflicts

    Documented procurement procedures that meet 2 CFR 200.318 to 200.327, including written standards of conduct covering conflicts of interest and the disciplinary actions for breaching them.

  • Cost allowability and payments

    Written procedures for deciding whether costs are allowable under subpart E and the award terms, and for payments and cash management under 200.305.

  • Time and effort

    Salary charges supported by records of actual work, with after-the-fact review and adjustment wherever budgets are used for interim charging.

  • Subrecipient monitoring

    Subrecipient and contractor determinations, risk evaluation that includes fraud risk, monitoring steps and follow-up on subrecipient audit findings.

  • Equipment and property

    Property records and a physical inventory reconciled at least every two years, with equipment defined at $10,000 per unit unless your capitalization policy sets a lower amount.

  • Indirect costs

    Rate choices, including the 15% de minimis rate where eligible, and consistent treatment of shared costs across awards.

Policies, records and a mock audit

DeliverableWhat it isWhen
Uniform Guidance policy setBoard-ready written policies for each required area, cross-referenced to the 2 CFR 200 sections they satisfyWeeks 3 to 7
Time-and-effort processCertification or activity-report design, templates and a review schedule that fits your payroll cycleWeek 6
Subrecipient monitoring toolkitDetermination checklist, risk evaluation form, monitoring plan and audit follow-up logWeek 7
SEFA checkYour Schedule of Expenditures of Federal Awards compared with the ledger, including assistance listing numbers and pass-through detailsWeek 8
Mock single audit reportFindings from compliance and control testing on your likely major programs, in the format auditors useWeek 11
Readiness readoutBriefing for the executive director, finance committee and board, with a fix list ahead of fieldworkWeek 12

Policies first, then a dress rehearsal

  1. Weeks 1 to 2

    Map the awards

    We list every federal award, direct and pass-through, with its compliance requirements, and estimate which programs are likely to be major.

  2. Weeks 2 to 8

    Write and fix

    We draft the required policies and redesign time-and-effort and subrecipient processes with your program and finance staff.

  3. Weeks 8 to 11

    Mock audit

    We test samples from your likely major programs against the OMB Compliance Supplement, the way a single auditor would.

  4. Week 12

    Readout

    We present findings and fixes to leadership and the board, and leave a calendar of compliance tasks for the year.

Grant files and people we need

  • Award and subaward agreements for every federal award, with budgets and amendments
  • Your current SEFA, or a list of federal expenditures by award for the year
  • Payroll registers, timesheets or effort certifications, and your allocation method
  • Procurement files for a sample of purchases charged to federal awards
  • Your subrecipient list, subaward agreements and any monitoring records
  • Prior audit reports, management letters and corrective action plans

Is this the right fit?

A good fit

  • Nonprofits approaching or crossing $1,000,000 in federal expenditures for the first time
  • Organizations with prior single audit findings on procurement, time and effort or subrecipients
  • Pass-through entities that need a documented subrecipient monitoring process
  • New finance leaders inheriting a grant portfolio without written policies

Not the right fit

  • Organizations looking for the single audit itself; it must be performed by an independent auditor, and we never audit
  • Federal contracts governed by the Federal Acquisition Regulation, which follow different rules

Budgets do not support salary charges

Salaries are often the largest cost on a federal award, and the rule for charging them is strict. Under 2 CFR 200.430, salary charges must rest on records that reflect the work actually performed, cover all of an employee's compensated activity and sit within a system of internal control. Budget estimates may be used for interim charging only if they are reviewed after the fact and adjusted. A program manager whose salary is charged 40% to a grant every month because the budget says 40%, with no one comparing it with what she worked on, is the pattern auditors look for. We design certification or activity-report processes around your payroll cycle, so the review happens as routine.

Subrecipients carry your risk

When you pass federal money to another organization, 2 CFR 200.332 makes you responsible for evaluating each subrecipient's risk of fraud and noncompliance, monitoring its activities and following up on its audit findings. It starts one step earlier, with a written determination of whether the recipient is a subrecipient or a contractor. A subaward signed without a risk evaluation on file fails the requirement from day one. We build a short risk form, a monitoring plan scaled by risk and a log that tracks each subrecipient's single audit status.

The 2024 numbers in one place

ItemRule since 1 October 2024Previous rule
Single audit threshold$1,000,000 in federal expenditures$750,000
Equipment definition$10,000 per unit$5,000 per unit
De minimis indirect rateUp to 15% of modified total direct costs10%

The single audit threshold applies to fiscal years beginning on or after 1 October 2024.

A proposed rewrite, not yet law

OMB's proposed rewrite of May 2026 is not final as of November 2026. We write policies to the rules now in force, note the sections most exposed to change, and recommend reviewing them once a final rule is published. Financial policies outside the grant set, such as card and close procedures, come through our financial policies and procedures work. The single audit readiness checklist lists what to prepare in the meantime, and the first single audit scenario shows the work from start to finish.

What people ask before hiring us

Are we over the $1 million threshold?

It depends on federal expenditures in your fiscal year, not on award size or cash received. Expenditures under direct awards and pass-through awards both count, and loans and loan guarantees can count where applicable. The free single audit threshold checker on this site gives a first answer; your auditor makes the determination.

What about OMB's proposed rewrite of the Uniform Guidance?

OMB proposed a significant rewrite on 29 May 2026, including termination for convenience and recasting the guidance as binding regulation. Comments closed on 13 July 2026. As of November 2026 the rewrite is not final, and a continuing resolution bars finalization through 11 December 2026. We write policies to the 2024 rules now in force and flag the sections most likely to change.

Can you prepare our SEFA?

The SEFA is management's responsibility, and we can help your team build it from the ledger and award records. We do not audit it. Your single auditor reports on it in relation to the financial statements.

When is the single audit due?

The reporting package is due to the Federal Audit Clearinghouse within 30 calendar days after you receive the auditor's report, or nine months after the end of the fiscal year, whichever comes first.

Also in Compliance Documentation

Policies, procedures, codes of conduct and grant documentation written in plain language, matched to your systems, and checked against what the ledger shows.

  • Financial Policies & Procedures

    A six-to-twelve-week project that writes or rewrites your financial policies and procedures around how your systems and people work, checks them against the ledger and gives every document an owner.

  • Code of Conduct & Speak-Up Programs

    An eight-to-twelve-week project that redesigns your code of conduct and builds the reporting channel, triage, investigation protocol and anti-retaliation process behind it.

Related work and reading

Services

  • Controls Health Check

    A three-to-four-week diagnostic of your core money flows that ranks every control gap by consequence and hands you a fix list your team can act on.

  • Training Programs

    Half-day sessions to six-week cohorts for managers, staff and boards, built on your policies, your approval limits and anonymized examples from your own ledger.

Articles and scenarios

Sectors

Tell us what you are seeing

A first conversation is a scoping call: what worries you, what you need to show, and to whom. You leave it with a view on where to start, whether or not you hire us.

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