OMB Circular A-133 Audit/Property Guidance

Department of Homeland Security Policy/Guidance

OMB Circular A-133 Audit Applicability to Property/Equipment Assistance Under Grants, Cooperative Agreements and Other Types of Assistance

In compliance with the Single Audit Act of 1984, Single Audit Act Amendment of 1996, and OMB Circular A-133 Audit to States, Local Governments and Non-Profit Organizations, the value of property/equipment must be included in the year it is received to determine if a recipient of Federal funds meets the OMB Circular A-133 Audit expenditure threshold in their fiscal year. If the threshold is met and a Single Audit is required, the property/equipment is subject to all Single Audit requirements.

The following will provide guidance regarding the receipt of property/equipment:

• If a recipient or subrecipient receives a Federal award comprised of only property valued at $500,000 or more (e.g., equipment purchased by the State under the DHS programs) the recipient or subrecipient may be able to elect to perform a program specific audit instead of a single audit. The subrecipient should contact the grantee (pass-through entity) for guidance.
• If a recipient or subrecipient receives Federal awards comprised of both property (e.g., equipment purchased by the State under the DHS programs) and other forms of financial assistance (e.g., funding) from multiple DHS programs and/or from other Federal agencies, the property is subject to the single audit requirement.
• If a recipient or subrecipient receives a Federal award comprised of both property and funding under different Federal programs all of which fall under DHS, then a single audit is required.
• If a recipient or subrecipient receives a Federal award comprised of both property and funds from only one Federal program (e.g., State Homeland Security Program), the subrecipient may be eligible to elect a program specific audit instead of a single audit. The subrecipient should contact the grantee (pass-through entity) for guidance.

NOTE: The guidance provided above applies to equipment retained through web site ordering where payments are made directly to the vendors by the State. Invoices, shipping receipts, or other types of documentation should be available to validate the value and receipt of equipment.