Common Subrecipient Annual Report (SAR) Questions

The following are common questions regarding submission of the Subrecipient Annual Report.

  1. How do I know if I need a Single Audit?
  2. Why did I get a letter from the Department of Finance & Management?
  3. Why did I get this letter now when my fiscal year ended several months ago?
  4. My organization gets an audit every year.  Is that a Single Audit?
  5. What is a subrecipient?
  6. If I have a loan am I a subrecipient?
  7. How do I find out whether or not my grant contains federal funds?
  8. When do I file the Subrecipient Annual Report?  Do I have to remember to do it each year?
  9. I need a single audit this year, but my expenses are not yet final and I don't know what to report in Section III.  Do I have to complete this section?
  10. What are the consequences for not filing the Subrecipient Annual Report when it is due?
  11. My organization needs to have a Single Audit.  What do I do next?
  12. I haven't been reimbursed for a grant yet.  Do I need to file the Subrecipient Annual Report?
  13. You listed a grant in the letter that I spent last year.  Can I disregard your letter, or should I report it again?
  14. I don't recognize a grant on your list.  How do I find out more information about it?
  15. How much should I report for my FEMA grant?
  16. I have food program grants from the Agency of Education and I spent more than you list in your letter.  What should I report?
  17. What do I do if I have additional questions about the Subrecipient Annual Report?

1.  How do I know if I need a Single Audit?
Your organization is required to have a single audit if it expends $750,000 or more in federal grant assistance during its fiscal year. This grant assistance may come directly from the Federal government, from the State of Vermont, or from another organization such as a non-profit organization, a university, a local Supervisory Union, etc. Your business manager, controller, treasurer or other financial official should compile federal expenditures from all sources and determine if you exceed the $750,000 threshold. It is for this reason that the Subrecipient Annual Report must be completed by the financial official in your organization who has access to grant information for the entire organization.

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2.  Why did I get a letter from the Department of Finance & Management?
Your organization has an open grant or loan from the State of Vermont that contains federal funds. You are therefore considered a “subrecipient” of the State of Vermont, and as a condition of your grant agreement, you must report whether or not your organization requires a Single Audit to the Department of Finance and Management annually. This letter is notice of that requirement, and is timed to coincide with the end of your fiscal year.

Per federal regulations (Uniform Guidance), if your organization requires a single audit, the granting agency of the State of Vermont must review your audit report to determine if it contains audit findings that affect the federal funds passed through the State. If the audit report does contain findings, these regulations require the State to review how you will resolve the findings and to issue a Management Decision Letter to you within 6 months after the audit report was published.

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3.  Why did I get this letter now when my fiscal year ended several months ago?
When your grant award was issued, your fiscal year period was entered in the State's grants database by the granting agency. The annual letter is generated from this data and you should receive it within 2 weeks after your fiscal year ends. If you get a letter at a different time of year, it is likely that the fiscal year information is incorrect in the database and must be updated.  If your fiscal year period has recently changed, this also needs to be updated in our database.  Please call or email the Finance & Management contact person named in the letter and they will update the State’s records and determine what, if anything, is due from you at this time.

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4.  My organization gets an audit every year.  Is that a Single Audit?
Not necessarily. A Single Audit is specifically related to federal programs and must be conducted by a qualified auditor in accordance with federal regulations (Uniform Guidance) and Generally Accepted Government Auditing Standards. The work involved in a single audit is in addition to that of a typical financial statement audit, though it may occur simultaneously. The auditor will often issue a separate single audit report, or will create a separate section of the financial statement audit report for the single audit portion. The single audit report will include a Schedule of Expenditure of Federal Assistance which summarizes all of your organization’s federal funds by CFDA# and also indicates the source of the federal funds. If your organization does not typically exceed the $750,000 single audit threshold ($500,000 prior to 12/31/2015), chances are you have a financial statement audit each year, and not a single audit.

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5.  What is a subrecipient?
A Subrecipient is an organization who receives a grant or loan of federal funds from a non-federal organization, such as the State of Vermont. Subrecipients are also referred to as grant recipients or as grantees.

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6.  I have a loan, not a grant.  Am I a subrecipient?
Yes. Per federal regulations, expenditures for projects covered by a federal loan are reportable in the same way as a grant.

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7.  How do I find out whether or not my grant from the State of Vermont is federal?
If your grant came to you from a State of Vermont granting agency, Part 1 of your grant award document should disclose the source of funds. All federal grant awards issued from the State of Vermont must disclose the Catalog of Federal Domestic Assistance (CFDA) number, federal agency, etc. in accordance with Agency of Administration Bulletin 5 and federal regulations. All grants listed at the end of Finance & Management’s annual letter to you are considered federal grants by the State of Vermont granting agency. If your grant award document contains CFDA information, it is considered a federally funded grant.  If after checking the grant award document you still have questions, please contact your granting agency directly.

If your grant came to you from another entity, such as a non-profit organization or an educational institution, you should review the grant agreement document.  If you have questions about grants from non-State of Vermont granting agencies, you must contact the granting agency directly since the State of Vermont has no record of these awards and is unable to provide information about them.

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8.  When do I file the Subrecipient Annual Report?  Do I have to remember to do it each year?
The report is due annually within 45 days after your fiscal year ends. Shortly after your fiscal year ends, you will get a letter from the Department of Finance & Management requesting that you submit the report. The letter contains a list of all federal grants/loans from a State of Vermont agency with an open grant period for all or part of your most recently completed fiscal year and a blank copy of the report.

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9.  I need a single audit this year but my expenses aren't yet final and I don't know what to enter in Section III.  Do I have to complete this section?
Section III is optional when a Single Audit is required (YES is checked in Section II).  We appreciate reviewing estimated expenditures in this section for our planning purposes, but it is optional. 

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10.  What are the consequences for not filing the Subrecipient Annual Report when it is due?
Timely filing of these reports is a condition of your grant award and failure to do so will put you out of compliance with the terms of your grant agreement.  If the report is not received by the Department of Finance & Management by the due date, your organization will be placed in a delinquent status. Once in a delinquent status your organization is ineligible to receive future grant agreements until the delinquency has been resolved.  Failure to comply with the requirement could result in additional sanctions such as a hold on future grant payments to your organization, a request for repayment of the grant, etc. 

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11.  My organization needs to have a Single Audit.  What do I do next?
Subrecipient Annual Report and return it to the Department of Finance and Management within 45 days after the end of your fiscal year.  You also must hire a qualified auditing firm to conduct your audit and you must ensure that the audit report is issued and submitted to the Federal Audit Clearinghouse within 9 months after your fiscal year ended.  You can find more information about single audit requirements on the FAQ page of the Federal Audit Clearinghouse
 
Note:  On March 22, 2010, OMB issued a memorandum that restricts the ability of federal agencies to grant extensions of the 9-month single audit report submission due date.  It also requires that grantee organizations meet all audit requirements, including timely submission of their single audit report, in order to maintain a low-risk auditee standing.

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12.  I haven't been reimbursed for a grant yet.  Do I need to file the Subrecipient Annual Report?
Yes.  You should report the expenditures you incurred during your fiscal year, whether or not you have been reimbursed.  Due to timing differences, your expenditures may not be the same as the amount you were reimbursed.

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13.  You listed a grant in the letter that I spent last year.  Can I disregard your letter, or should I report it again?
Do not disregard the letter!  If you have only one grant in the grants list, you should contact Finance & Management using the contact information in the letter and they will confirm that the grant was reported as fully expended in the prior year.  Otherwise, you should submit the report, listing the grant in Section III of the SAR, but entering $0 in the Expenditures column.

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 14.  I don't recognize a grant on your list.  How do I find out more information about it?
A brief description is included in the grants list of the letter you received.  If you need additional information, you should contact that department who granted the funds to you.  You may also contact Finance & Management using the contact information in the letter and they may be able to provide more information, or provide you with a contact person at the department who issued the grant.

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  15.  What should I report for my FEMA grant?
The letter from Finance & Management includes special instructions for FEMA grant reporting:  According to the August 6, 2013 memo from the US Department of Homeland Security titled, “Audit of Eligible Stafford Act Claimed Costs,” the recording of expenditures related to Stafford Act funds should be based on when the funds are approved (i.e., approval of the Award Worksheet) since that is when FEMA actually obligates funds to such recipient.  Refer directly to the DHS memo for further guidance.

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16.  I have food program grants from the Agency of Education and I spent more than you list in your letter.  What should I report?
Food program participants typically incur costs that exceed the amount of federal reimbursement they receive.  You should report on the SAR only the portion that was, or will be, reimbursed with federal funds.  The Agency of Education typically enters into the State's grants database the federal share of the claims they authorized for the months of July through May and this is what appears on the letter from Finance & Management.  On your SAR you should report the federal share of the amount you expended for your fiscal year period, which may vary from the amount that appears on the letter from Finance & Management.  You should review your claims reimbursements for each month and report the total in Section III of the SAR.  If you have questions about your reimbursements, you should contact the Agency of Education directly.

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17.  What do I do if I have additional questions about the Subrecipient Annual Report?
In addition to the common questions and answers on this page, instructions for each section are found on the back of the  Subrecipient Annual Report.  If you need more help, please call or email the Finance & Management contact person listed on the letter you received.

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