The Single Audit threshold

If your organisation receives federal money, one number decides whether your year ends with a standard financial statement audit or with a Single Audit: how much you expended in federal awards. That number changed recently, and a lot of published checklists — including, until we corrected it, an example on this very site — still quote the old one.

The current number

Under 2 CFR 200.501(a), a non-federal entity that expends $1,000,000 or more in federal awards during its fiscal year must have a Single Audit — or, where it qualifies, a program-specific audit — conducted for that year.

The threshold was raised from $750,000 by OMB’s April 2024 revision of the Uniform Guidance. The higher figure applies to fiscal years beginning on or after 1 October 2024. For audit periods that began before that date, the old $750,000 threshold still governs — which matters if you are cleaning up a late filing for an earlier year.

Expended, not awarded

This is the distinction that catches people out. The threshold is measured on funds expended during the fiscal year, not funds awarded, obligated, received, or sitting in the bank.

An organisation can hold a $3,000,000 multi-year award and be nowhere near a Single Audit in year one. Another can hold no single large award at all, and cross the threshold because six modest federal grants happened to spend heavily in the same twelve months. Aggregation across awards is what surprises people, not any individual grant.

What counts toward it

Federal award expenditures aggregate across all your federal funding, including money that reaches you indirectly. In broad terms that means:

• Direct federal grants and cooperative agreements
• Pass-through funding — federal money subawarded to you by a state agency, a county, a university, or another nonprofit. It is still federal money, and it still counts
• Federal loan and loan-guarantee programmes, under specific rules in the regulation
• Non-cash assistance such as donated property or commodities, where applicable

The determination is made on your own fiscal year, not the federal one — so an organisation with a June year-end is measuring a different twelve months than the government is.

Knowing before year-end

The expensive version of this is discovering in month eleven that you crossed the threshold in month four. A Single Audit takes procurement, scheduling and auditor availability that you cannot compress, and the submission deadline does not move to accommodate a late start.

The operational fix is unglamorous: track federal expenditure as a running total across all awards, tagged by funding source, and look at it monthly rather than annually. If you can answer “how much federal money have we spent so far this fiscal year, across everything?” in under a minute, you will never be ambushed by this. If answering it requires assembling a spreadsheet from four systems, you will be.

This is one of the things Grantwell tracks continuously rather than at year-end — federal expenditure rolls up across every award in the portfolio, so the threshold is a number you watch approaching rather than one you discover having passed.

Sources

Check these rather than taking this page’s word for it — including this page’s word for the date it was last reviewed.

This guide is general information about how grant compliance work is commonly organised, not legal, audit or accounting advice. Grant rules change, and terms vary by funder and award — always check your own award documents and the current regulation, and talk to your auditor about your specific circumstances.