Yes. LSC OIG has elected to adopt Code of Federal Regulations, Title 2, Subtitle A, Chapter II, Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) for audits of LSC grant recipients, subject to modification in accordance with LSC OIG guidance.
No. Uniform Guidance increased the threshold for a Single Audit to $1,000,000 of federal awards expended. LSC Appropriations Acts of 1996 and 1997 require an audit regardless of grant amount and take precedence over the Uniform Guidance audit requirements. Accordingly, the increased audit threshold specified does not apply to recipients of LSC funds. There is no change in audit requirements for recipients of LSC funds. The applicability of the requirements of the Audit Guide for Recipients and Auditors specified in paragraph 1-3 remains unchanged.
Subrecipient audit requirements are addressed in the subgrant agreements. Please do not arrange for, or submit, an audit of a subrecipient of LSC funds that does not comply with the executed subgrant agreement, unless you have received express approval from the OIG. In the absence of guidance in the subgrant agreement, subgranted LSC funds are subject to the audit and financial requirements of the Audit Guide for Recipients and Auditors and the Accounting Guide for LSC Recipients.
The LSC OIG is the cognizant agency and audit oversight agency for recipients and subrecipients of LSC funds.
The OMB Compliance Supplement does not apply to LSC funds. The Compliance Supplement for Audits of LSC Recipients which is Appendix A of the Audit Guide for Recipients and Auditors, identifies the laws and regulations that apply to LSC funds under an OMB Uniform Guidance audit. IPAs are expected to cite the Compliance Supplement for Audits of LSC Recipients in their reports on Compliance with Requirements applicable to Major Programs and Internal Controls over Compliance in accordance with the Uniform Guidance. IPAs should be aware that if non-LSC funds (Federal or state) of a recipient are subject to consideration under an OMB Uniform Guidance audit, the OMB Compliance Supplement may otherwise apply to those funds.
Yes. A close-out audit consists of the financial statements and compliance reports, prepared according to LSC OIG guidance, for the final period in which the auditee received direct LSC funds. It is a close-out audit if it is the last financial accounting for an auditee as a separate entity even if that auditee is merging into another LSC-funded entity in the next reporting period.
No. Subrecipient agreements and contracts with private attorneys for legal representation of clients are not related-party transactions.
Yes. Per the LSC Financial Guide, section 3.6.1 Capitalized Assets, "Recipients are required to report in their financial statements the value of LSC-funded vs. non-LSC funded property and equipment, including accumulated depreciation."