In April of 2024, the Office of Management and Budget (OMB) issued significant revisions to Uniform Guidance, updating several administrative, cost, and audit requirements for recipients of federal awards. Effective for fiscal years starting on or after October 1, 2024, these revisions are intended to reduce administrative burdens on award recipients, align with statutory requirements, clarify certain sections of the guidance, and simplify language to improve readability. This article provides an overview of some of the changes to Uniform Guidance and the Single Audit that school districts should be aware of.
Key Changes to Single Audit Requirements
- Increased Single Audit threshold: The spending threshold for the Single Audit has been raised from $750,000 to $1 million, meaning only school districts that expend $1 million or more in federal funds within the fiscal year will be subject to a Single Audit.
- Revised type A program determination: The threshold for defining “Type A” programs has also been raised from $750,000 to $1 million for entities expending between $1 million and $34 million in federal awards.
- New cybersecurity requirements: Recipients of federal awards must now implement reasonable cybersecurity measures as a part of their internal controls to safeguard sensitive information.
- Increased de minimis indirect cost rate: The de minimis rate for indirect costs has been raised from 10% to 15% of modified total direct costs (MTDC).
- Revised terminology: The term “non-federal entity” has been replaced with the term “recipient” or “subrecipient.”
- Increased subaward threshold: The exclusion threshold of subawards has been raised from $25,000 to $50,000 for modified total direct costs.
- Updated definition of equipment: The capitalization threshold for equipment has been raised from $5,000 to $10,000.
- “Questioned costs” clarification: The definition of “questioned costs” has been revised, with examples added to provide further clarification.
- Explanation required for questioned costs: When there are questioned costs, but the dollar amount is undetermined or not reported, the audit finding must include an explanation describing why the dollar amount is undetermined or not reported.
- Clarified definition of “period of performance”: The definition of “period of performance” has been updated to mean the interval of time between the start and end date of a federal award, which may span multiple budget periods.
What’s Next?
School districts should review and update their internal controls to ensure compliance with the revised Uniform Guidance. For additional assistance in preparing your district for audits and for all of your other accounting needs, please don’t hesitate to reach out to our education accounting team at RBT CPAs. We’re here to ensure your school district stays in compliance with all applicable federal and state requirements and accounting standards. Give us a call today and find out how we can be Remarkably Better Together.




