Guidelines_for_Financial_Audits_Contracted_by_Foreign_Recipients_-_OIG.pdf

OFFICE OF INSPECTOR

GENERAL

GUIDELINES FOR FINANCIAL

AUDITS CONTRACTED BY

FOREIGN

RECIPIENTS

FEBRUARY 2009

TABLE OF CONTENTS

Chapter 1: Purpose of Audit Guidelines

BACKGROUND

APPLICABILITY

RESPONSIBILITIES OF USAID MISSIONS AND THE OIG

AUDIT COSTS AND SANCTIONS

COMPLIANCE WITH AUDITING STANDARDS

MULTIPLE AGREEMENTS AND SUBRECIPIENTS

Chapter 2: Selection of Independent Auditors

AUDIT FIRMS

GOVERNMENT SUPREME AUDIT INSTITUTIONS

Chapter 3: Audit Objectives

AUDIT OF USAID FUNDS

REVIEW OF COST SHARING/COUNTERPART CONTRIBUTIONS SCHEDULE

AUDIT OF GENERAL PURPOSE FINANCIAL STATEMENTS

Chapter 4: Audit Scope

PRE-AUDIT STEPS

FUND ACCOUNTABILITY STATEMENT

COST SHARING/COUNTERPART CONTRIBUTIONS SCHEDULE

AGREEMENT WITH LIFE-OF-PROJECT COST SHARING/COUNTERPART CONTRIBUTION BUDGET

AGREEMENT WITH ANNUAL COST SHARING/COUNTERPART CONTRIBUTION BUDGET

INTERNAL CONTROL

COMPLIANCE WITH AGREEMENT TERMS AND APPLICABLE LAWS AND REGULATIONS

FOLLOW-UP ON PRIOR AUDIT RECOMMENDATIONS

GENERAL PURPOSE FINANCIAL STATEMENTS

INDIRECT COST RATES

OTHER AUDIT RESPONSIBILITIES

REFERENCE MATERIALS

EXAMPLE 4.1 - ILLUSTRATIVE MANAGEMENT REPRESENTATION LETTER

Chapter 5: Audit Reports

Chapter 6: Illustrative Fund Accountability Statement, Cost-Sharing Schedules, and Schedule of Computation of Indirect Cost Rate

EXAMPLE 6.1 - ILLUSTRATIVE FUND ACCOUNTABILITY STATEMENT

EXAMPLE 6.2.A - ILLUSTRATIVE COST SHARING/COUNTERPART CONTRIBUTIONS SCHEDULE

FOR AGREEMENTS WITH LIFE-OF-PROJECT COST SHARING/COUNTERPART CONTRIBUTION

BUDGETS THAT HAVE NOT YET ENDED

EXAMPLE 6.2.B - ILLUSTRATIVE COST SHARING/COUNTERPART CONTRIBUTIONS SCHEDULE

FOR CLOSE-OUT AUDITS OF AWARDS WITH LIFE-OF-PROJECT COST SHARING/COUNTERPART

CONTRIBUTION BUDGETS, AND AUDITS OF AWARDS WITH ANNUAL COST SHARING/COUNTERPART

CONTRIBUTION BUDGETS

EXAMPLE 6.3 - ILLUSTRATIVE SCHEDULE OF COMPUTATION OF INDIRECT COST RATE

Chapter 7: Illustrative Reports

EXAMPLE 7.1.A - ILLUSTRATIVE AUDITOR'S REPORT ON A FUND ACCOUNTABILITY STATEMENT

WITH AN UNQUALIFIED OPINION

EXAMPLE 7.1.B - ILLUSTRATIVE AUDITOR'S REPORT ON A FUND ACCOUNTABILITY STATEMENT

WITH A QUALIFIED OPINION

EXAMPLE 7.2.A - ILLUSTRATIVE AUDITOR'S REPORT ON INTERNAL CONTROL WITH NO SIGNIFICANT

DEFICIENCIES NOTED

EXAMPLE 7.2.B - ILLUSTRATIVE AUDITOR'S REPORT ON INTERNAL CONTROL WITH SIGNIFICANT

DEFICIENCIES NOTED

EXAMPLE 7.3.A - ILLUSTRATIVE AUDITOR'S REPORT ON COMPLIANCE WITH NO MATERIAL

NONCOMPLIANCE NOTED

EXAMPLE 7.3.B - ILLUSTRATIVE AUDITOR'S REPORT ON COMPLIANCE WITH MATERIAL

NONCOMPLIANCE NOTED

EXAMPLE 7.4 – ILLUSTRATIVE REPORT ON SCHEDULE OF COMPUTATION OF INDIRECT COST RATE

EXAMPLE 7.5 – ILLUSTRATIVE UNQUALIFIED OPINION ON THE GENERAL PURPOSE FINANCIAL

STATEMENTS OF THE RECIPIENT ORGANIZATION AS A WHOLE

EXAMPLE 7.6.A - ILLUSTRATIVE AUDITOR’S REPORT ON THE COST SHARING/COUNTERPART

CONTRIBUTIONS SCHEDULE FOR AGREEMENTS WITH LIFE-OF-PROJECT COST SHARING/COUNTERPART

CONTRIBUTION BUDGETS THAT HAVE NOT YET ENDED, WITH NO SIGNIFICANT ISSUES NOTED

EXAMPLE 7.6.B - ILLUSTRATIVE AUDITOR’S REPORT ON THE COST SHARING/COUNTERPART

CONTRIBUTIONS SCHEDULE FOR AGREEMENTS WITH LIFE-OF-PROJECT COST SHARING/COUNTERPART

CONTRIBUTION BUDGETS THAT HAVE NOT YET ENDED, WITH SIGNIFICANT ISSUES NOTED

EXAMPLE 7.6.C - ILLUSTRATIVE AUDITOR’S REPORT ON THE COST SHARING/COUNTERPART

CONTRIBUTIONS SCHEDULE FOR CLOSE-OUT AUDITS OF AGREEMENTS WITH LIFE-OF-PROJECT COST

SHARING/COUNTERPART CONTRIBUTION BUDGETS, AND AUDITS OF AGREEMENTS WITH ANNUAL

COST SHARING/COUNTERPART CONTRIBUTION BUDGETS, WITH NO SIGNIFICANT ISSUES NOTED

EXAMPLE 7.6.D - ILLUSTRATIVE AUDITOR’S REPORT ON THE COST SHARING/COUNTERPART

CONTRIBUTIONS SCHEDULE FOR CLOSE-OUT AUDITS OF AGREEMENTS WITH LIFE-OF-PROJECT

COST SHARING/COUNTERPART CONTRIBUTION BUDGETS, AND AUDITS OF AGREEMENTS WITH

ANNUAL COST SHARING/COUNTERPART CONTRIBUTION BUDGETS, WITH SIGNIFICANT ISSUES NOTED

Chapter 8: Outline of an Illustrative Statement of Work for Recipient Contracted Audits

Chapter 9: Model Audit Agreement with Supreme Audit Institutions

Chapter 10: Request for a Technical Proposal for Qualification of Public Accounting Firms

Chapter 11: USAID Inspector General Contact Information

RIG OFFICES ADDRESSES AND PHONE NUMBERS

WASHINGTON OIG ADDRESS AND PHONE NUMBERS

INSPECTOR GENERAL HOTLINE FOR REPORTING FRAUD, WASTE AND ABUSE

C hapter 1: Purpose of Audit Guidelines

* An asterisk indicates that the adjacent information is new or revised.

Background

1.1 * The U.S. Agency for International Development (USAID) administers foreign economic development and humanitarian assistance programs on behalf of the United States Government.

1.2 * USAID consists of a central headquarters staff in the United States and a number of overseas missions and offices. It provides assistance to both non-U.S. nongovernmental and non-U.S.

governmental organizations through programs managed by its missions (and, on an exception basis, by headquarters offices).

1.3 The Guidelines for Financial Audits Contracted by Foreign Recipients (Guidelines) are to be used by independent auditors in performing recipient-contracted audits required by USAID agreements with non-U.S. recipient organizations. These organizations are referred to as "recipients" or "foreign recipients" throughout these Guidelines. "Agreements" or "awards" are defined as USAID-funded grants, contracts, cooperative agreements, and loans. The Guidelines also provide guidance to recipients in selecting independent auditors to perform the audits.

1.4 USAID agreements with foreign recipients require them to contract independent auditors acceptable to the USAID Office of Inspector General (OIG) to perform financial audits of the funds provided under the agreements. Such audits are in accordance with the Inspector General Act of 1978, as amended. The OIG reserves the right to conduct audits using its own staff, notwithstanding acceptable audits performed by other auditors, in cases where special accountability needs are identified.

Applicability

1.5 * USAID agreements with foreign governments and foreign nonprofit organizations require that a recipient-contracted audit be performed annually in accordance with these Guidelines when the recipient expends $300,000 or more in USAID awards in its fiscal year. USAID missions must assess risk at least annually to determine when financial audits of foreign for profit organizations are required. In addition to these annual audit requirements, a close-out audit must be performed for all awards in excess of $500,000. As a general rule, annual incurred cost audits are acceptable as fulfilling the close-out audit requirement. Even when a recipient-contracted audit is not required, if the mission determines that an audit must be performed, the audit report must be submitted to the cognizant Regional Inspector General (RIG) office for review and issuance.

1.6 For subrecipients expending $300,000 or more in USAID awards in their fiscal year, USAID standard audit provisions require that recipients ensure that audits of subrecipients are performed annually in accordance with these Guidelines.

1.7 Food donation agreements under the U.S. Public Law 480 Title II and Title III programs also require recipient-contracted audits of foreign recipients if the recipient expends $300,000 or more in USAID awards in its fiscal year. In addition, agreements for cash transfers and sector assistance may include recipient-contracted audit requirements. Such audits must be performed in accordance with these Guidelines to the extent that the Guidelines do not conflict with the agreement provisions. Endowment or trust funds created out of USAID awards, fixed-price contracts, and fixed-obligation grants do not require audits under these Guidelines, but may be undertaken at the request of the mission.

Responsibilities of USAID Missions and the OIG

1.8 * USAID missions monitor and ensure submission of required recipient-contracted audit reports.

1.9 The USAID Regional Inspectors General (RIGs) monitor the quality of such audits. Each USAID Regional Inspector General (RIG) must maintain a list of independent auditors eligible to perform audits of USAID agreements.

1.10 * The list of eligible audit firms is divided into two categories: regular and conditional.

1.11 * Firms in the “regular” category are eligible to audit any USAID award.

1.12 * Firms in the “conditional” category are limited to auditing specific awards or recipients, and must comply with any other restrictions imposed by the cognizant RIG. For example, the cognizant RIG may conditionally authorize the use of audit firms that have not developed the capability to fully comply with U.S. Government Auditing Standards, provided that the auditors use other acceptable auditing standards. It is expected that such audit firms will make satisfactory efforts to fully comply with U.S. Government Auditing Standards within a reasonable period of time.

Also, local firms may be conditionally accepted when they are the regular auditors of a recipient's general purpose financial statements and are recommended by the USAID mission. The recommendation may be based on prior experience, other acceptable assurance, or a pre-qualification review by USAID. Conditionally accepted firms must be separately approved for each recipient they audit under these Guidelines.

1.13 * Unless otherwise noted, recipient-contracted audits must be conducted in accordance with Chapters 3, 4, and 5 of U.S. Government Auditing Standards ("Yellow Book"; hereafter referred to as U.S. Government Auditing Standards) issued by the Comptroller General of the United States and generally accepted auditing standards adopted by the American Institute of Certified Public Accountants (AICPA), which have been incorporated into U.S. Government Auditing Standards by reference. If recipient-contracted auditors have questions on audit matters, they should contact the appropriate RIG. If the auditors have questions concerning the program(s) under audit, or need to confirm the amounts disbursed to the recipient by USAID, they should contact the cognizant USAID mission.

1.14 * USAID ensures that audit agreements between recipients and independent auditors contain a standard statement of work containing all the requirements of these Guidelines. Accordingly, recipients must send all draft audit contracts to the cognizant USAID mission for approval prior to finalization. One annual audit must cover all USAID funding to a recipient. Recipients that have funding agreements with more than one USAID mission must send their audit contracts for approval to the nearest USAID mission with which they have an agreement. This USAID mission will act as the designated cognizant mission, unless the recipient is otherwise directed by USAID.

1.15 The draft audit contract submitted by the recipient to the cognizant USAID mission must indicate which USAID agreements will be covered by the audit. The designated cognizant mission will coordinate the audit efforts with any other USAID missions that have agreements with the recipient. The USAID mission will provide the independent auditors with data regarding any USAID direct procurements for use by the recipient and will confirm to the auditors the amounts disbursed

(advances and reimbursements) to the recipient. The cognizant USAID mission will be responsible for distributing audit reports to the other USAID missions and resolving a recipient's organization-wide internal control and compliance deficiencies. Each USAID mission will also be responsible for acting upon findings and recommendations applicable to its agreements with the recipient.

1.16 Recipients must submit final audit reports to the cognizant USAID mission, who will forward final reports to the RIG for review and release. The cognizant RIG must receive the audit report no later than nine months after the end of the audited period.

1.17 The RIG will conduct quality control reviews (QCRs) of the audit documentation for a selected sample of the audits. These reviews will determine whether audit work was performed in accordance with these Guidelines. The RIG will notify USAID, the recipient, and the independent auditors of the results of these reviews.

Audit Costs and Sanctions

1.18 Recipients may charge to the USAID agreements all costs for performing the specific audit of their USAID-funded programs. The costs to be charged to the USAID agreements for auditing the recipient's general purpose financial statements, if requested by USAID, will be a matter for negotiation between USAID and the recipient (see paragraph 3.5 of these Guidelines). As no audit costs may be charged to a USAID agreement if audits are not performed in accordance with these Guidelines, it is incumbent upon the auditor to produce a final product that meets this requirement.

1.19 USAID will consider appropriate sanctions against a recipient in the event of continued inability or unwillingness to have an audit performed in accordance with these Guidelines.

Sanctions could include suspension of disbursements to the recipient until a satisfactory audit is performed. The RIG will refer independent auditors to appropriate regulators, professional authorities, and U.S.-affiliated firms for significant inadequacies or repeated instances of substandard performance. Auditors submitting unacceptable work may be removed from the list of firms that are eligible to perform audits under the recipient-contracted audit program (see paragraph 2.8 of these Guidelines). In addition, audit firms that do not provide timely responses to questions raised by the USAID mission or the RIG may be removed from the list of eligible audit firms.

Compliance with Auditing Standards

1.20 USAID is aware that some independent auditors contracted by foreign recipients initially may not fully comply with these Guidelines because of a lack of technical knowledge and experience in using U.S. Government Auditing Standards. The RIG will assess and consider this lack of institutional capability when accepting or rejecting reports based on QCRs. The RIG may allow exceptions to compliance with U.S. Government Auditing Standards and these Guidelines provided that: (a) audit reports are determined to be reliable, and (b) any deviations from U.S. Government Auditing Standards, such as noncompliance with internal and external quality control review programs and continuing education requirements, are clearly stated in the report as scope limitations (see paragraph 5.1.b.1 and Chapter 7 of these Guidelines).

1.21 Independent auditors are responsible for upgrading their audit capabilities. Nevertheless, USAID missions and the RIG will consider providing technical assistance to independent auditors when requested. The RIG may remove from the list of eligible firms any independent auditors that do not make adequate progress in upgrading their audit capabilities to comply with U.S.

Government Auditing Standards.

Multiple Agreements and Subrecipients

1.22 Some recipients may receive direct assistance funding from USAID under more than one agreement and also indirect assistance from USAID as a subrecipient from either foreign or U.S.

recipients. Under such circumstances, a recipient must have one annual recipient-contracted audit performed that would cover all USAID funding to the recipient from all sources. The recipient should contract only one audit firm to perform the annual audit.

1.23 * A foreign nonprofit organization that is only a subrecipient of a U.S. recipient organization must adhere to the USAID Standard Provisions for Non-U.S. Nongovernmental Grantees, which require annual audits as outlined in paragraph 1.5 above. When a foreign recipient of direct USAID assistance is a subrecipient of a U.S. recipient organization, in addition to receiving funds directly from USAID as a recipient organization, the annual audit performed in accordance with these Guidelines must include the funding passed through by the U.S. recipient organization. If the foreign recipient also receives assistance from other donors, consideration should be given to including the other donors' assistance in the USAID audit, provided an agreement and cost-sharing arrangement can be negotiated with the other donors.

1.24 * A U.S. subrecipient that expends $500,000 or more in USAID awards in its fiscal year is subject to U.S. Office of Management and Budget Circular A-133 audit requirements and will not require a separate recipient-contracted audit.

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C hapter 2: Selection of Independent Auditors

2.1 This chapter provides guidance to recipients for selecting independent auditors acceptable to

USAID.

2.2 Audits of USAID funds provided to nongovernmental recipients are to be performed by independent audit firms in accordance with U.S. Government Auditing Standards. Audits of governmental recipients are to be performed either by independent audit firms in accordance with U.S. Government Auditing Standards or by the government's Supreme Audit Institution (SAI) in accordance with U.S. Government Auditing Standards, auditing standards promulgated by the International Organization of Supreme Audit Institutions (INTOSAI), or auditing guidelines of the International Auditing Practices Committee of the International Federation of Accountants (IFAC).

2.3 Recipients must ensure that all records are available to the independent auditors, all accounting entries and adjustments are made, and all other necessary steps are taken to enable the auditors to complete their work. The cognizant RIG must receive the audit report no later than nine months after the end of the audited period. To this end, interim audit work is likely to be needed except in the case of recipients with few transactions.

2.4 * Audits should begin before the close of a fiscal year, since initiating audits after the close of a fiscal year could hinder timely audit reporting and may restrict the scope of certain audit procedures, leading to additional questioned costs. The OIG recommends that independent audits be contracted well in advance of the fiscal year close so that necessary interim audit work can be performed during the year. This practice could also result in reduced audit costs, to the degree that it helps audit firms accomplish their work more efficiently and distribute their workload throughout the year. Chapter 8 of these Guidelines presents an outline of an illustrative statement of work to be included in recipient-contracted audit agreements.

Audit Firms

2.5 * The cognizant USAID mission must approve the recipient’s selection of an audit firm from the list of eligible audit firms maintained by the cognizant RIG, prior to execution of the audit services contract. The preferred procedure is for the recipient to obtain proposals and select an audit firm from the list of firms determined to be eligible by the RIG. The selection may be based on factors such as firms’ past performance in terms of quality and timeliness (including preparing audit reports in English), independence from the organization to be audited, the experience and credentials of firm staff proposed to participate in the audit, the availability of firm staff to accomplish audits within required timeframes, and cost. However, audit cost cannot be a controlling factor in the selection.

Before selecting an audit firm, the recipient must request references from independent sources that can provide information on firms’ past performance. These sources must include the cognizant USAID mission and RIG. After the recipient selects the audit firm, it must submit a the draft contract to the cognizant USAID mission for approval. The USAID mission will verify that the firm selected is on the list of firms eligible to perform audits of USAID funds and that the statement of work contained in the contract complies with these Guidelines. The mission has the authority to establish a limit on the maximum number of years that a recipient can be audited by the same audit firm. In addition, missions are requested to alert the cognizant RIG immediately if they encounter any indications of a lack of independence on the part of audit firms, or any indications of “opinion shopping” by recipients (i.e., seeking audit firms who will behave in a way that is not completely independent).

2.6 In determining acceptability of proposed audit firms, the RIG will give first priority to firms that have partnership agreements with firms located in the United States. Audit firms who have authority to use the letterhead and sign audit reports in the name of a U.S. audit firm are required to do so. The RIG will give second priority to affiliates or representatives of firms located in the United States that are subject to standard audit quality control procedures and reviews. Local firms that are not affiliated with firms located in the United States may be accepted when there is a high degree of assurance of professional quality based upon prior experience with an international organization or other acceptable assurance. Usually, and at the discretion of the cognizant RIG, the RIG will perform a quality control review (QCR) before the firm is included in the list of eligible firms. If the firm changes its partnership agreement or affiliation, its eligibility to perform USAID audits may need to be reevaluated.

2.7 * All selected audit firms should meet or make satisfactory efforts toward meeting the continuing education requirements (CPE) and internal and external peer review requirements in accordance with U.S. Government Auditing Standards. RIGs may remove firms that fail to meet this objective from the list of auditors eligible to perform audits of USAID agreements. RIGs may periodically remove firms that have not performed any audits under these Guidelines for a period of four years. Inactive firms need to be removed from the list of eligible firms periodically because audit staff, procedures, training programs, and affiliations change over time. However, RIGs will give firms an opportunity to update their information before removing them from the list or give firms an opportunity to update their information to apply to be reinstated on the list.

2.8 It is the responsibility of recipient-contracted audit firms to perform audits pursuant to these Guidelines and to present audit reports in a timely manner. If the RIG returns the work of an audit firm for revision due to noncompliance with these Guidelines, the audit costs may not be charged to USAID until such time as the OIG finds the report to be acceptable. Moreover, audit costs to be paid by USAID are limited to the amount specified in the draft audit contract approved by the USAID mission (see paragraph 1.14) unless USAID subsequently agrees to an increase. Any additional costs incurred in correcting deficient audit reports will not be reimbursed by USAID unless USAID agrees to reimburse additional costs. Should the audit firm fail to make its report acceptable, either a different recipient-contracted audit firm or the RIG must perform another audit.

In such case, the audit firm will not be considered acceptable to perform future audits until the RIG determines that it has undergone an external quality control review, implemented the resultant recommendations, and is capable of substantially improved performance. In addition, at the RIG’s discretion, the RIG might send a letter to the audit regulatory body in the country where the audit was performed.

Government Supreme Audit Institutions

2.9 The recipient country's principal government audit agency, often referred to as its "Supreme Audit Institution" (SAI), may audit governmental recipients under these Guidelines. However, SAIs will only be accepted to audit USAID funds if the RIG determines that the SAI

a. Is in fact and appearance independent of the government recipient organizations to be audited and the executive branch of the government, and substantially meets the independence requirements set forth in U.S. Government Auditing Standards.

b. Does not participate in any way in pre-control, contract or transaction approval, check signing, or other activity that is incompatible with the audit function.

c. Maintains a professionally prepared and competent staff of duly qualified and licensed certified public accountants, or equivalent, experienced in the performance of financial audits and appropriately supervised by more experienced auditors.

d. Complies with U.S. Government Auditing Standards, auditing standards promulgated by the International Organization of Supreme Audit Institutions (INTOSAI), or auditing guidelines of the International Auditing Practices Committee of the International Federation of Accountants

(IFAC).

e. Maintains a continuing program of staff training and professional development for its audit staff.

2.10 The OIG encourages SAIs to develop their own auditing manuals and audit quality control systems and to participate in an external quality control review program. USAID will consider assisting SAIs if they manifest a desire to perform professional quality audits of USAID-financed activities and the recipient government places a high priority upon this function.

2.11 * SAIs that do not fully meet the criteria—described in 2.9.c, 2.9.d, and 2.9.e above—may be accepted by the RIG if they agree to use acceptable auditing standards and to be closely supervised by the RIG, until the RIG believes such supervision is no longer needed. SAIs that are accepted by the USAID mission and the RIG must:

a. Perform audits pursuant to these Guidelines.

b. Present their audit reports in a timely manner.

c. Sign an agreement with the USAID mission and the RIG to perform audits of governmental recipients in accordance with these Guidelines.

2.12 A model audit agreement is presented in Chapter 9 of these Guidelines. This agreement takes the place of a contract that would be signed between an independent audit firm and a recipient. The agreement must include a statement of work that will require the SAI to use specific acceptable auditing standards and to provide the reports required by these Guidelines, including the report on the fund accountability statement for the USAID funds, the report on internal control related to the USAID-funded programs, and the report on compliance with agreement terms and applicable laws and regulations related to the USAID-funded programs.

2.13 In the event that an SAI demonstrates continued inability or unwillingness to perform audit work in compliance with these Guidelines, USAID will not accept its work until the RIG determines that the SAI has undergone an external quality control review, implemented the resultant recommendations, and is capable of substantially improving its performance. If an SAI's audit work is rejected, USAID may require an independent audit by a professional independent audit firm or, at its discretion, make arrangements for its own audit on behalf of the governmental recipient in accordance with the standard audit provisions in the USAID agreements.

2.14 USAID considers accountability over foreign government-owned local currencies generated by or resulting from USAID programs to be the primary responsibility of the government that owns such funds. This is true notwithstanding any agreed-upon conditions for separate deposit, usage, etc. Therefore, USAID expects the SAI of the country to determine, based upon professionally executed audits, whether government-owned local currencies have been deposited, disbursed, recorded, and accounted for in accordance with the agreed upon conditions, and to report this to the cognizant USAID mission. USAID missions are responsible for ensuring the frequency of audits of government-owned local currencies. The RIG may periodically review the quality of such audits.

Chapter 3: Audit Objectives

3.1 * The financial audit must include a specific audit of all the recipient’s USAID-funded programs.

The financial audit should also include an audit of the recipient’s general purpose financial statements on an organization-wide basis (balance sheet, income statement, and cash flow statement) if the recipient has been authorized to use provisional indirect cost rates,1 or if the mission specifically requests such an audit. The fund accountability statement is the basic financial statement to be audited that presents the recipient's revenues, costs incurred, cash balance of funds provided to the recipient by USAID, and commodities directly procured by USAID for the recipient's use. The fund accountability statement should be reconciled to the USAID funds included in the general purpose financial statements by a note to the financial statements or the fund accountability statement. All currency amounts in the fund accountability statement, cost-sharing schedule, and the report findings, if any, must be stated in U.S. dollars. The auditors should indicate the exchange rate(s) used in the notes to the fund accountability statement.

Example 6.1 of these Guidelines illustrates a typical fund accountability statement.

Audit of USAID Funds

3.2 A financial audit of the funds provided by USAID must be performed in accordance with U.S.

Government Auditing Standards, or other approved standards where applicable (see paragraph 2.9.d of these Guidelines), and accordingly includes such tests of the accounting records as deemed necessary under the circumstances. The specific objectives of the audit of the USAID funds are to

a. * Express an opinion on whether the fund accountability statement for the USAID-funded programs presents fairly, in all material respects, revenues received, costs incurred, and commodities directly procured by USAID for the period audited in conformity with the terms of the agreements and generally accepted accounting principles or other comprehensive basis of accounting (including the cash receipts and disbursements basis and modifications of the cash basis).

b. * Evaluate the recipient's internal control related to the USAID-funded programs, assess control risk, and identify significant deficiencies including material weaknesses. This evaluation should include the internal control related to required cost-sharing contributions.

c. Perform tests to determine whether the recipient complied, in all material respects, with agreement terms (including cost sharing/counterpart contributions, if applicable) and applicable laws and regulations related to USAID-funded programs. All material instances of noncompliance and all illegal acts that have occurred or are likely to have occurred should be identified. Such tests should include compliance requirements related to required cost-sharing contributions, if applicable.

d. Perform an audit of the indirect cost rate(s) if the recipient has been authorized to charge indirect costs to USAID using provisional rates and USAID has not yet negotiated final rates with the recipient.

1 Where the recipient has been authorized to use provisional indirect cost rates, an audit of the general purpose financial statements is needed to ensure that all costs have been correctly included in the indirect cost rate calculation.

e. Determine if the recipient has taken adequate corrective action on prior audit report recommendations.

3.3 Auditors must design audit steps and procedures in accordance with U.S. Government Auditing Standards, Chapter 4, to provide reasonable assurance of detecting situations or transactions in which fraud or illegal acts have occurred or are likely to have occurred. If such evidence exists, the auditors must contact the appropriate RIG and should exercise due professional care in pursuing indications of possible fraud and illegal acts so as not to interfere with potential future investigations or legal proceedings.

Review of Cost-Sharing/Counterpart Contributions Schedule

3.4 The audit should determine whether cost sharing/counterpart contributions were provided and accounted for by the recipient in accordance with the terms of the agreements, if applicable. The auditors will review the cost sharing/counterpart contributions schedule to determine if the schedule is fairly presented in accordance with the basis of accounting used by the recipient to prepare the schedule. The auditors should question all cost sharing/counterpart contributions that are either ineligible or unsupported costs. In addition, for audits of agreements that present a cost sharing/counterpart contribution budget on an annual basis and for close-out audits of awards that present cost sharing/counterpart contribution budgets on a life-of-project basis, the auditors will review the cost sharing/counterpart contributions schedule to determine if cost sharing/counterpart contributions were provided by the recipient in accordance with the terms of the agreement.

Audit of General Purpose Financial Statements

3.5 A financial audit of the recipient's general purpose financial statements on an organization-wide basis must be submitted to USAID together with the audit of USAID funds if the recipient has been authorized to charge indirect costs, or if the mission specifically requests such an audit. The audit must be performed in accordance with generally accepted auditing standards of the American Institute of Certified Public Accountants (AICPA), auditing standards that have been prescribed by the laws of the country or adopted by an association of public accountants in the country, or auditing standards promulgated by the International Organization of Supreme Audit Institutions or International Auditing Practices Committee of the International Federation of Accountants. The objective of this audit is to express an opinion on whether those statements present fairly, in all material respects, the recipient's financial position at year-end, and the results of its operations and cash flows for the year then ended, in conformity with generally accepted accounting principles.

Chapter 4: Audit Scope

4.1 The auditors should use the following steps as the basis for preparing audit programs. They are not all-inclusive or restrictive in nature and do not relieve the auditor from exercising due professional care and judgment. The steps should be modified to fit local conditions and specific program design, implementation procedures, and agreement provisions, which may vary from program to program. Any limitations in the scope of work must be communicated as soon as possible to the appropriate RIG.

Pre-Audit Steps

4.2 Following is a list of documents applicable to different USAID programs. The auditors should review the applicable documents considered necessary to perform the audit:

a. The agreements between USAID and the recipient.

b. The subagreements between the recipient and other implementing entities, as applicable.

c. Contracts and subcontracts with third parties, if any.

d. The budgets, implementation letters, and written procedures approved by USAID.

e. USAID Automated Directives System Chapter 636—“Program Funded Advances.”

f. OMB Circular A-122—"Cost Principles for Nonprofit Organizations" (2 CFR Part 230).

g. OMB Circular A-21—"Cost Principles for Educational Institutions" (2 CFR Part 220).

h. Federal Acquisition Regulation (FAR), Part 31—“Contract Cost Principles and Procedures.”

i. USAID Acquisition Regulation (AIDAR), which supplements the FAR.

j. Mandatory Standard Provisions for Non-U.S. Nongovernmental Grantees (USAID Automated Directives System, Chapter 303 Internal Mandatory References).

k. Standard Provisions Annex for Agreements with Foreign Governments (USAID Automated Directives System, Chapter 350).

l. All program financial and progress reports; charts of accounts; organizational charts;

accounting systems descriptions; procurement policies and procedures; and receipt, warehousing and distribution procedures for materials, as necessary, to successfully complete the required work.

m. Any previous audits, financial reviews, etc., that directly relate to the objectives of the audit.

Fund Accountability Statement

4.3 * The auditors must examine the fund accountability statement2 for USAID programs including

2 A “fund accountability statement” is a financial statement that presents a USAID recipient’s revenues, the budgeted amounts by category and major items; the revenues received from USAID for the period covered by the audit; the costs reported by the recipient as incurred during that period; and the commodities directly procured by USAID for the recipient's use. The fund accountability statement must include all USAID assistance funds identified by each specific program or agreement. The revenues received from USAID less the costs incurred, after considering any reconciling items, must reconcile with the balance of cash-on-hand or in bank accounts.3 The fund accountability statement should not include cost-sharing/counterpart contributions provided from the recipient's own funds or in-kind. However, a separate cost sharing/counterpart contributions schedule must be included and reviewed as stated in paragraph 4.8 of these Guidelines.

4.4 The auditors may prepare or assist the recipient in preparing the fund accountability statement from the books and records maintained by the recipient, but the recipient must accept responsibility for the statement's accuracy before the audit commences.

4.5 * The opinion on the fund accountability statement must comply with Statement on Auditing Standard (SAS) No. 62 (AU623). The fund accountability statement must separately identify those revenues and costs applicable to each specific USAID agreement. The audit must evaluate program implementation actions and accomplishments to determine whether specific costs incurred are allowable, allocable, and reasonable under the agreement terms and applicable cost principles, and to identify areas where fraud and illegal acts have occurred or are likely to have occurred as a result of inadequate internal control. At a minimum, the auditors must:

a. Review direct and indirect costs billed to and reimbursed by USAID and costs incurred but pending reimbursement by USAID, identifying and quantifying any questioned costs. All costs that are not supported with adequate documentation or are not in accordance with the agreement terms must be reported as questioned. Questioned costs that are pending reimbursement by USAID must be identified in the notes to the fund accountability statement as not reimbursed by USAID.

a.1 * Questioned costs must be presented in the fund accountability statement in two separate categories. Ineligible costs that are explicitly questioned because they are unreasonable, prohibited by the agreements or applicable laws and regulations, or not program related. In addition, if a recipient was required to place USAID funds in an interest-bearing account but did not, then the imputed interest that would have been earned is also classified as an ineligible cost. Unsupported costs are not supported with adequate documentation or did not have required prior approvals or authorizations. All material questioned costs resulting from instances of noncompliance with agreement terms and applicable laws and regulations must be included as findings in the report on compliance.

Also, the notes to the fund accountability statement must briefly describe both material and immaterial questioned costs and must be cross-referenced to any corresponding findings in the report on compliance.

b. Review general and program ledgers to determine whether costs incurred were properly recorded. Reconcile direct costs billed to, and reimbursed by, USAID to the program and general ledgers.

costs incurred, cash balance of funds (after considering reconciling items), and commodities directly procured by USAID that were provided by USAID agreements.

3 If the recipient does not receive any advances from USAID, i.e., it operates on a reimbursement basis, then the recipient will not hold any balances of USAID funds.

c. Review procedures used to control funds, including their channeling to contracted financial institutions or other implementing entities. Review bank accounts and the controls on those bank accounts. Perform positive confirmation of balances, as necessary.

d. Determine whether advances of funds were justified with documentation, including reconciliations of funds advanced, disbursed, and available. The auditors must ensure that all funding received by the recipient from USAID was appropriately recorded in the recipient's accounting records and that those records were periodically reconciled with information provided by USAID.

e. Determine whether program income was added to funds used to further eligible project or program objectives, to finance the non-federal share of the project or program, or deducted from program costs, in accordance with USAID regulations, other implementing guidance, or the terms and conditions of the award.

f. Review procurement procedures to determine whether sound commercial practices including competition were used, reasonable prices were obtained, and adequate controls were in place over the qualities and quantities received.

g. Review direct salary charges to determine whether salary rates were reasonable for that position, in accordance with those approved by USAID when USAID approval is required, and supported by appropriate payroll records. Determine if overtime was charged to the program and whether it was allowable under the terms of the agreements. Determine whether allowances and fringe benefits received by employees were in accordance with the agreements and applicable laws and regulations. The auditors should question unallowable salary charges in the fund accountability statement.

h. Review travel and transportation charges to determine whether they were adequately supported and approved. Travel charges that are not supported with adequate documentation or not in accordance with agreements and regulations must be questioned in the fund accountability statement.

i. Review commodities (such as supplies, materials, vehicles, equipment, food products, tools, etc.), whether procured by the recipient or directly procured by USAID for the recipient's use.

The auditors should determine whether commodities exist or were used for their intended purposes in accordance with the terms of the agreements, and whether control procedures exist and have been placed in operation to adequately safeguard the commodities. As part of the procedures to determine if commodities were used for intended purposes, the auditors should perform end-use reviews for an appropriate sample of all commodities based on the control risk assessment (see paragraph 4.16.b of these Guidelines). End-use reviews may include site visits to verify that commodities exist or were used for their intended purposes in accordance with the terms of the agreements. The cost of all commodities whose existence or proper use in accordance with the agreements cannot be verified must be questioned in the fund accountability statement. (The auditor should determine the cost of commodities based on supporting documentation available from the recipient or USAID, as appropriate.)

j. * Review technical assistance and services procured by the recipient. The auditors should determine whether technical assistance and services were used for their intended purposes in accordance with the terms of the agreements. The cost of technical assistance and services not properly used in accordance with terms of the agreements must be questioned in the fund accountability statement.

j.1 In addition to the above audit procedures, if technical assistance and services were contracted by the recipient from a non-U.S. contractor, the auditors should perform additional audit steps on the technical assistance and services, unless the recipient has separately contracted for an audit of these costs. When testing for compliance with agreement terms and applicable laws and regulations, the auditors should not only consider agreements between the recipient and USAID, but also agreements between the recipient and the non-U.S. contractors providing technical assistance and services. The agreements between the recipient and non-U.S. contractors should be audited using the same audit steps described in the other paragraphs of this section, including all tests necessary to specifically determine that costs incurred are allowable, allocable, reasonable, and supported under agreement terms.

j.2 * If the technical assistance and services were contracted by the recipient from a U.S.

contractor, the auditors are still responsible for determining whether technical assistance and services were used for their intended purposes in accordance with the terms of the agreements. However, the auditors are not responsible for performing additional audit steps for the costs incurred under the technical assistance and services agreements, since either USAID or a cognizant U.S. Government agency is responsible for contracting for audits of these costs.

k. * When indirect costs are charged to USAID using provisional rates, review the allocation method to determine that the indirect cost pool and distribution base include only allowable items in accordance with agreement terms and regulations. The auditors should be aware that costs that are unallowable as charges to USAID agreements (e.g., fundraising) must be allocated their share of indirect costs if they represent activities that (1) include the salaries of personnel, (2) occupy space, and (3) benefit from the organization’s indirect costs. Indirect cost rates must be calculated after all adjustments have been made to the pool and base.

When indirect costs are charged to USAID using predetermined or fixed rates, verify that the correct rates are applied in accordance with the agreement with USAID.

l. Review unliquidated advances to the recipient and pending reimbursements by USAID when performing final closeout audits. Ensure that the recipient returned any excess cash to USAID.

Also, ensure that all assets (inventories, fixed assets, commodities, etc.) procured with program funds were disposed of in accordance with the terms of the agreements. The auditors should present, as an annex to the fund accountability statement, the balances and details of final inventories of nonexpendable property acquired under the agreements. This inventory should indicate which items were titled to the U.S. Government and which were titled to other entities.

These closeout audit procedures must be performed for any award that expires during the period audited.

4.6 The fund accountability statement included as Example 6.1 of these Guidelines illustrates how to report the results of a single audit that covers more than one USAID agreement. In such cases, the fund accountability statement must separately disclose the financial information (revenues, costs, etc.) for each agreement, and must identify the USAID missions/offices that provided funding for each agreement. Questioned costs, and internal control and compliance findings of any audits of subrecipients must be reported in the recipient’s financial audit using the same treatment and procedures as the recipient’s own questioned costs and findings. This is particularly important in audits of recipients covering agreements from more than one USAID mission. Each mission can identify its agreements in the audit report for resolution of findings and recommendations with the recipient. The same reporting principles apply when only one USAID agreement is covered by the audit.

4.7 The auditors must generally express a single opinion on a fund accountability statement that includes more than one agreement with USAID. Auditors must not express separate opinions on fund accountability statements of each agreement or program unless specifically requested to do so by the USAID mission.

Cost Sharing/Counterpart Contributions Schedule

4.8 USAID agreements may require contributions by the recipient. Most agreements establish a life-of-project budget for such contributions; however, some agreements may establish annual budgets for those contributions. The review of the costs sharing schedule must be approached differently depending on whether the cost sharing/counterpart contribution budget is a life-of project budget or an annual budget. In either case, the review consists principally of inquiries of recipient personnel and analytical procedures applied to financial data supporting the cost sharing/counterpart contributions schedule.

4.9 The auditors may prepare or assist the recipient in preparing the cost sharing/counterpart contributions schedule from the books and records maintained by the recipient. The recipient must, however, accept responsibility for the schedule's accuracy before the review commences.

Agreement with Life-of-Project Cost Sharing/Counterpart Contribution Budget

4.10 For an agreement with a life-of-project budget for cost-sharing/counterpart contributions, it is not possible to determine whether the contributions have been made as required until the agreement ends. Nonetheless, USAID and the recipient need reliable information to monitor actual cost-sharing/counterpart contributions throughout the life of the agreement.

4.11 Thus, for agreements with a life-of-project budget for cost-sharing/counterpart contributions, for each year that an audit is performed in accordance with these Guidelines, the auditors will review the cost sharing/counterpart contributions schedule to determine if the schedule is fairly presented in accordance with the basis of accounting used by the recipient to prepare the schedule. The auditors must question all cost-sharing/counterpart contributions that are either ineligible or unsupported costs. An ineligible cost is unreasonable, prohibited by the agreements or applicable laws and regulations, or not program related. An unsupported cost lacks adequate documentation or does not have required prior approvals or authorizations. All questioned costs must be briefly described in the notes to the cost sharing/counterpart contributions schedule.