The Office of Management and Budget (OMB) Circular A-133 requires an annual
external audit of non-profits receiving federal funds. A sample of federal
awards and their direct cost transactions are selected for testing (auditing)
to determine that expenditures and procedures were appropriate, allowable,
and allocable to the award. Specifically, that they were:
In accordance with OMB
A-110 (Administrative Requirements and University Policies)
Non-Federally Sponsored Accounts
Non-federal sponsors will, from time to time, audit sponsored accounts
to ensure that the fiscal requirements they impose on the award are being
adhered to. To ensure compliance you should review and follow the sponsor's
requirements as stipulated in the award.
Importance of Auditing
All federal and increasingly non-federal sponsors look at the A-133 audit
as a "report card" of how Harvard spends its money. Audit findings are
reported to the federal government and become public record; they are
distributed to all federal agencies through the federal
clearinghouse. Each department performing sponsored research must
ensure that the reported expenditures are appropriate for the terms and
conditions of the award, as well as federal cost principles/administrative
requirements and University policies (OMB
A-21 and OMB
A-110)
Audit (Testing) Areas
The following areas are included in these audits:
Direct attributions (linkage
between cost and purpose of the project). This linkage must be established
and demonstrated through supporting documentation.
Relationships between costs and the project. A readily
identifiable casual/beneficial relationship must exist between
costs and the project (e.g., test tubes were purchased for a wet lab
experiment involving fluid analysis).
Consistency. Costs incurred
for the same purpose in like circumstances should be treated consistently
as either direct costs or as facilities and administrative costs.
The annual audit begins in April/May with a planning/audit selection. Orientation
of the parties takes place in June and testing occurs in the summer/fall.
Preliminary findings and draft reports are issued in the fall/winter (the
issue resolution period), and the final report must be issued by the end
of March.