U.S. Department of Commerce
U.S. Census Bureau
OMB Information Collection Request
Data Collection Form for Reporting on Audits of States, Local Governments, Indian Tribes, Institutions of Higher Education, and Nonprofit Organizations
OMB Control Number 0607-0518
Justification
Necessity of the Information Collection
The Census Bureau is requesting a reinstatement, with changes, of Form SF-SAC, OMB control number 0607-0518. Prior to the year 1997, the Census Bureau was responsible for the OMB clearance approval process using OMB control number 0607-0518. In 1997, OMB took over the approval process for the Form SF-SAC under OMB control number 0348-0057 (currently expiring June 30, 2019). The Census Bureau is now resuming responsibility for obtaining OMB clearance under the original OMB control number 0607-0518.
Each year, over $700 billion of Federal assistance awards are expended by more than 100,000 non-Federal entities (states, local governments, Indian tribes, institutions of higher education, and nonprofit organizations) throughout the country. To improve business-like practices and provide greater accountability over Federal awards, the Single Audit Act Amendments of 1996 (Public Law 104-156) and the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Part 200, or Uniform Guidance) imposed certain audit reporting and recordkeeping requirements on non-Federal entities/auditees that expend $750,000 or more in Federal awards per year, as well as on their auditors.
Non-Federal entities are required by the Single Audit Act Amendments of 1996 and Uniform Guidance to have audits conducted of their Federal awards and file the resulting reporting packages (Single Audit reports) and data collection forms (Form SF-SAC) with the Federal Audit Clearinghouse (FAC). The Form SF-SAC is Appendix X to 2 CFR Part 200. The Office of Management and Budget (OMB) has designated the Census Bureau as the FAC to serve as the government-wide repository of record for Single Audit reports.
The Single Audit process is a primary method used by Federal agencies and pass-through entities to provide oversight of Federal awards and reduce risk of non-compliance and improper payments. This includes following up on audit findings and questioned costs. The proposed changes explained in the following paragraphs are changes to the Form SF-SAC under OMB control number 0348-0057 approval dated June 30, 2016. These changes include revising some existing data elements and adding data elements that would make the reports easier for Federal agencies, pass-through entities, and the public to use.
The proposed changes mentioned in the pre-submission notice published in the Federal Register on April 3, 2018 are to include the following required elements of the reporting package on the data collection form: the text of the federal award audit findings, the text of the corrective action plan, and the notes to the schedule of expenditures of federal awards (SEFA). There will be a checkbox for each finding text and corrective action plan (CAP) text entered asking the user if there are any charts or tables that could not be copied or pasted to analyze how often this occurs. Additionally, a new yes/no question has been added regarding whether the auditors communicated to the auditee, in a written document, any issues that were not audit findings.
Attachments I, II, III, and VI to this Supporting Statement show the full list of questions the FAC will be collecting. Two additional items not mentioned in the pre-submission notice will be collected in the Web-based collection instrument, the Internet Data Entry System (IDES). These items will collect the date the auditor’s report(s) were received by the auditee, shown in Attachment III, and what items were modified when a revision has been conducted, shown in Attachment VI.
The date the audit was received was not included in the pre-submission notice as logistics were still being discussed about what instructions should accompany this field. This is the date the auditee received the full, complete report from the auditor. This inclusion is to help with the determination of whether the Form SF-SAC and Single Audit report were submitted on time. Per 2 CFR 200.512(a), the Form SF-SAC and Single Audit report shall be submitted within the earlier of 30 days after receipt of the auditor’s report(s), or nine months after the end of the audit period. Collecting this date will allow for tracking of the 30 day deadline, as the FAC already collects the fiscal period ending date to track the nine month deadline.
The list of what items were modified when a revision has been conducted was not included in the pre-submission notice as it was not suggested to the FAC until a meeting with stakeholders that occurred after the pre-submission notice was submitted. Users will select which items changed from the previously submitted version using the preset list of options. Users will be able to check multiple options. This information will be publicly displayed on the FAC website.
After receiving comments in response to the 30-day notice published in the Federal Register on November 6, 2018, the FAC has decided against the inclusion of a number of items. One item that will no longer be included is the yes/no question regarding whether the auditors communicated to the auditee, in a written document, any issues that were not audit findings. This item seemed to create a significant amount of confusion, as the ‘written document’ was hard to define. Requiring an answer to this question may also potentially deter auditors from issuing such communication in the future, which could negatively affect the respondent. A second item that will no longer be included is the date the auditee received the full, complete report from the auditor. Commenters suggested that the definition for this date (defined by the Uniform Guidance) was too vague to be able to answer the question accurately, and that respondents might interpret the definition in several different manners.
Needs and Uses
The information collection provides data about auditees, the Federal awards they expend, and the results of their audits. This information is used by entities responsible for overseeing the funding and administration of Federal awards (e.g., Congress, Federal agencies, and pass-through entities) and entities responsible for administering Federal awards (e.g., state governing officials, county and city councils, board of directors of nonprofit organizations, and senior management of various auditees). The information is used in making better decisions about which Federal awards and recipients to fund in the future, identifying and resolving areas of noncompliance, and improving the administration and delivery of Federal awards.
Reports from auditors to auditees and reports from auditees to the Federal government are used by non-Federal entities, pass-through entities, and Federal agencies to ensure that Federal awards are expended in accordance with applicable laws and regulations. The FAC uses the information on the Form SF-SAC to ensure proper distribution of audit reports to Federal agencies and identify non-Federal entities who have not filed the required reports. The FAC also uses the information on the Form SF-SAC to create a government-wide database, which contains information on audit results. This database is publicly accessible on the Internet at https://harvester.census.gov/facdissem/main.aspx.
The Uniform Guidance indicates that the FAC is authorized to make the reporting package and the Form SF-SAC publicly available on a website. There is an exception for Indian Tribes (2 CFR 200.512(b)(2)). An auditee that is an Indian Tribe (as defined in the Indian Self-Determination, Education and Assistance Act (ISDEAA), 25 U.S.C 5304) may opt not to authorize the FAC to make the reporting package publicly available on a website. For these exempted auditees, the text of the audit findings and the text of the corrective action plan (which are parts included in the reporting package) will not be publicly released on the Form SF-SAC. After reviewing the comments received as a result of this 30-day notice, the FAC has determined that the text provided as part of the Notes to the SEFA section of the form will also be included in the information that will not be publicly released on the Form SF-SAC for the exempted auditees.
The data collected by the FAC is used by Federal agencies, pass-through entities, non-Federal entities, auditors, the Government Accountability Office, OMB and the general public for information about and management of Federal awards and the results of audits.
In addition, this information is essential in developing effective government-wide audit policies over Federal assistance awards. OMB is required by the Single Audit Act (Act) Amendments of 1996 to perform a biennial review of the threshold that triggers an audit requirement, prescribe a risk-based approach to auditing major programs, and provide guidance on other matters necessary to implement the Act. OMB cannot perform its duties required by the Act Amendments or develop effective future audit policies without the information to be provided under this information collection (Form SF-SAC).
Information quality is an integral part of the pre-dissemination review of the information disseminated by the Census Bureau (fully described in the Census Bureau’s Information Quality Guidelines). Information quality is also integral to the information collections conducted by the Census Bureau and is incorporated into the clearance process required by the Paperwork Reduction Act.
Use of Information Technology
All responses are collected electronically.
All data elements are collected via a Web application designed by Census Bureau staff, thus eliminating the need for mass mailings to individual respondents. The FAC consulted with OMB, the Census Bureau processing staff, and the Federal agencies using the data collected for monitoring awards and resolving audit findings, and the decision was made to make submission through a Web-based application mandatory beginning in 2008. This Web application is called the Internet Data Entry System (IDES) and is available at https://harvester.census.gov/facides.
The IDES allows users to self-designate individuals from the auditee and auditor organizations who need to have access to the submission for data entry, review, and/or certification. Respondents start a new submission by entering general information about the auditee organization, such as the fiscal period, employer identification number (EIN), etc. The IDES directs respondents through the data entry form so that they answer questions that pertain to their organization (e.g., if there are audit findings identified on any of the Federal awards entered, the audit findings section will become available). There are also a series of edit checks before the data can be finalized that are run against the data entered to ensure that it is valid according to auditing standards. The IDES allows users to upload the electronic Single Audit report directly into the system. Respondents may enter their data directly into the system and are not required to download any software.
After the Web form is completed and the audit report is uploaded, respondents review, certify, and submit their data, which are then uploaded to Census Bureau secure servers.
The Census Bureau processing staff at the National Processing Center (NPC) use an internal processing system to review the uploaded Single Audit report to ensure all elements required by the Uniform Guidance are included and the report matches the data entered into the IDES Web form. If the NPC staff reject the submission, the auditee and auditor must revise their submission to make any necessary corrections, and then resubmit the Form SF-SAC and Single Audit report as a revision. If the NPC staff accept the submission, the Form SF-SAC and Single Audit report are automatically disseminated (except Indian Tribes that opt not the make the report publicly available) on the FAC Image Management System (IMS), available at https://harvester.census.gov/facdissem/main.aspx.
All users with access to the submission will receive automated progress emails from the IDES throughout the submission process from start to acceptance. Reminder emails are also sent for submissions that have been started but not submitted.
In developing the previous version of the form, OMB identified some potential duplication in the process for reporting the Form SF-SAC and the Schedule of Expenditures of Federal Awards (SEFA). Currently, awardees subject to Single Audit reporting create a SEFA and use it to complete their Form SF-SAC through the FAC. The SEFA and the form contain similar data which is submitted to the FAC in two formats. Therefore, as a part of the DATA Act Section 5 Pilot to Reduce Recipient Reporting Burden, OMB and the Department of Health and Human Services (DATA Act Program Management Office, or DAP) tested a more streamlined process for submitting the SEFA. Under this pilot program, participants were provided the opportunity to use an expanded SF-SAC concept form which included additional information related to the SEFA Notes. The FAC then used the data users entered to generate a customizable SEFA and Notes that a recipient could download, modify, and include in their Single Audit report.
The comments received by DAP were supportive of the inclusion of the piloted features. Based on that feedback, the FAC is allowing all of its respondents the ability to use these features. All respondents may enter their Federal awards and SEFA Notes prior to the end of the auditee’s fiscal period end date, and use the IDES to generate a customizable SEFA and Notes to the SEFA to include in their Single Audit report. This will reduce the duplicative effort of the current process.
The FAC also plans to allow non-Federal entities who did not meet the threshold requiring submission of a Single Audit report to voluntarily notify the FAC that they did not meet the reporting threshold. This information helps the Federal agencies in the review of applicants that fall below the reporting requirements. The FAC plans to put this information on their website.
Efforts to Identify Duplication
There is no known similar information available elsewhere that contains information on, and full copies of, audits of Federal awards on a government-wide basis. Some Federal agencies maintain data on the amount of Federal programs they budget and award, and others maintain data on the audit results of programs they fund, but no Federal agency currently tracks the actual amount of Federal awards expended and the related audit results by auditees for all Federal awards subject to the Uniform Guidance.
The government-wide database maintained by the FAC eliminates the need for individual agencies to independently track this type of information for the Federal awards they fund. It also serves to eliminate duplication in that respondents conduct one Single Audit instead of multiple audits and submit the audit data to a central clearinghouse instead of to multiple grantors.
Minimizing Burden
This information collection will not have a significant economic impact on a substantial number of small entities. A non-Federal entity must have a single or program-specific audit conducted for that year only if the non-Federal entity expends $750,000 or more in Federal awards during their fiscal period (2 CFR 200.501(a)).
Consequences of Less Frequent Collection
The recurring collection of information at the conclusion of each respondent’s fiscal period (ranging from 1 to 24 months) is necessary to meet a statutory requirement under the Single Audit Act Amendments of 1996 (Public Law 104-156); thus, the collection cannot be less frequent. The information is vital to Federal agencies providing these grants, to those in the research community, and to the general public.
Special Circumstances
The Uniform Guidance requires auditees to submit the Form SF-SAC and reporting package within the earlier of 30 calendar days after receipt of the auditor’s report(s) or nine months after the end of the audit period (2 CFR 200.512(a)). No other special circumstances apply to the information collection.
Consultations Outside the Agency
The FAC held teleconferences with volunteer representatives from Federal agencies such as the Department of Health and Human Services (HHS), Environmental Protection Agency (EPA), and National Science Foundation (NSF), and sought input from auditing organizations such as the American Institute of Certified Public Accountants (AICPA) and National Association of State Auditors, Comptrollers and Treasurers (NASACT). Proposed changes were also discussed at stakeholder meetings with other Federal agency representatives and respondents present.
The public was provided 60 days to comment on the proposed form and instructions published in the Federal Register on April 3, 2018 [83 FR 14251], https://www.federalregister.gov/documents/2018/04/03/2018-06705/proposed-information-collection-comment-request-data-collection-form-for-reporting-on-audits-of.
The Census Bureau received 79 distinct comments from 12 commenters relating to the proposed information collection. Some commenters compiled comments from multiple individuals within an agency/organization and submitted as one “commenter”. The comments received and the Census Bureau’s responses are summarized in Attachment IV. The Census Bureau also received 8 comments in support of various aspects of the proposed information collection (i.e., usefulness of information collected, exemptions for Indian Tribes, minimizing burden).
All comments were considered in preparing the Census Bureau’s responses.
Paying Respondents
No payments or gifts are given to respondents of the survey.
Assurance of Confidentiality
Upon receipt of the Federal grant or award, non-Federal entities are informed of the laws, regulations, and statutes required for the grant, as well as the submission requirement to the FAC specified in the Uniform Guidance.
The data collected in this survey is required to be made publicly available due to the requirements set forth in the Uniform Guidance (2 CFR 200.512(d) and (g)) and the Single Audit Act Amendments of 1996 (Public Law 104-156, §7502(h)). Non-Federal entities that expend $750,000 or more in Federal awards during their fiscal period are required to electronically submit the Form SF-SAC and reporting package to the FAC (2 CFR 200.512(d)). There is an exception for Indian Tribes (2 CFR 200.512(b)(2)). An auditee that is an Indian Tribe (as defined in the Indian Self-Determination, Education and Assistance Act (ISDEAA), 25 U.S.C 5304) may opt not to authorize the FAC to make the reporting package publicly available on a website. For these exempted auditees, the text of the audit findings and the text of the corrective action plan (which are included in the reporting package) will not be publicly released on the Form SF-SAC. After reviewing the comments received as a result of this 30-day notice, the FAC has determined that the text provided as part of the Notes to the SEFA section of the form will also be included in the information that will not be publicly released on the Form SF-SAC for the exempted auditees.
Justification for Sensitive Questions
There are no questions in the survey that are commonly considered sensitive.
Estimate of Hour Burden
The Census Bureau estimates approximately 80,000 respondents (40,000 auditees and 40,000 auditors). Auditees and auditors submit a combined response, making the total number of annual submissions 40,000. Each respondent is required to submit the data on Form SF-SAC and the reporting package annually within the earlier of 30 calendar days after receipt of the auditor’s report(s), or nine months after the end of the audit period (2 CFR 200.512(a)). The Uniform Guidance and Single Audit Act Amendments of 1996 only permit biennial audits or stub-audits (fiscal periods that are shorter than a calendar year) in limited circumstances.
The time required to complete this data collection form is estimated to average 100 hours for large auditees (approximately 400 respondents; i.e., auditees most likely to administer a large number of Federal awards) and 21 hours for all other auditees (approximately 79,600 respondents). These amounts reflect estimates of reporting burden on both auditees and auditors individually, meaning 100 or 21 hours for auditees and 100 or 21 hours for auditors. These estimates reflect the burden relating to the Form SF-SAC, including the time to review instructions, obtain the needed data, and complete and review the information. Based on these estimates, the estimated total annual burden is 1,711,600 hours. These estimates were calculated using the estimates from the previous revision of the Form SF-SAC (OMB control number 0348-0057) as a base. The estimated time no longer needed to read and understand the changes from the previous revision was subtracted and the estimated time to complete the new form elements was added.
For the 40,000 respondents that are auditees, the estimated average hours of burden is 100 hours for large auditees (approximately 200) and 21 hours for all other auditees (approximately 39,800). The average hourly wage for a state1, local government2, or nonprofit organization3 employee is approximately $24 per hour. This makes the total annual cost of burden on auditees to be $20.4 million.
For the 40,000 respondents that are auditors, the estimated average hours of burden is 100 hours for large auditees (approximately 200) and 21 hours for all other auditees (approximately 39,800). The cost of their time to respond is calculated prior to contract with the auditee during auditor procurement and is paid for using the funds received through the Federal grant by the auditee. Therefore, it is not calculated here.
Estimate of Cost Burden
We do not expect respondents to incur any costs other than that of their time to respond. The information requested is of the type and scope normally carried in company records and no special hardware or accounting software or system is necessary to provide answers to this information collection. Therefore, respondents are not expected to incur any capital and start-up costs or system maintenance costs in responding. Further, purchasing of outside accounting or information collection services, if performed by the respondent, is part of usual and customary business practices and not specifically required for this information collection.
Cost to Federal Government
The total cost to the Federal Government is expected to be relatively fixed over the upcoming three years at approximately $3.9 million. The cost is to be covered by appropriations from interagency agreements with the General Services Administration, Department of Health and Human Services, Department of Education, Department of Agriculture, Department of Housing and Urban Development, Department of Transportation, Department of Justice, Department of Homeland Security, Department of Defense, National Science Foundation, Department of Labor, Department of the Interior, Environmental Protection Agency, Department of Energy, Department of Commerce, National Aeronautics & Space Administration, and Corporation for National & Community Service, prorated by the percentage of all submissions that had funding from the respective agency from the previous audit year. The budget breakouts are approved by OMB. This estimate includes the cost for such things as data collection, processing, dissemination, overhead, support staff, website maintenance, etc.
Reason for Change in Burden
The increase in burden is attributable to the information collection being submitted as a reinstatement.
Project Schedule
The Census Bureau projects it will begin collecting data from respondents in January of 2019 for fiscal periods ending in 2019, 2020, and 2021. The data collection will be ongoing, as submission deadlines are dependent on the auditee’s fiscal period.
The IDES is accessible 24/7 and allows users to submit the Form SF-SAC and Single Audit report for the current fiscal period and the five preceding fiscal periods. This means users have the ability to submit their data any time, any day, over the course of six years from when the FAC makes the form available.
Request to Not Display Expiration Date
The expiration date will appear in the upper right corner of the login screen to the IDES.
Exceptions to the Certification
There are no exceptions to the certification.
1 https://data.bls.gov/cew/apps/table_maker/v4/table_maker.htm#type=11&year=2016&qtr=A&own=2&area=US000&supp=1
2 https://data.bls.gov/cew/apps/table_maker/v4/table_maker.htm#type=11&year=2016&qtr=A&own=3&area=US000&supp=1
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| Author | Hannah Marie Puisto (CENSUS/ERD FED) |
| File Modified | 0000-00-00 |
| File Created | 2021-01-20 |