CGMS 100%

Study grouping: Fiscal Management

Lesson 7: Recordkeeping and audit readiness

How long to keep records, and what triggers a Single Audit · 14 practice questions

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Reading

Fiscal Management is one of the four CGMS exam domains, and this course groups two related topics under it: how long records have to be kept, and when an organization crosses the line into needing a Single Audit. Both rules exist for the same reason, a federal award's paper trail has to survive long enough, and be complete enough, for someone to check the government's money was spent as promised, potentially years after the work itself is finished.

The basic record retention rule: three years

2 CFR 200.334 sets the baseline: a recipient or subrecipient must retain all federal award records for three years from the date it submits its final financial report. For an award with recurring quarterly or annual reports rather than one final report, the clock resets with each report, three years from the submission of each one. Three years is a floor, not a ceiling, several situations extend it.

What extends the retention period beyond three years

If litigation, a claim, or an audit is started before the three-year period expires, records must be kept until that matter is finally resolved, however much longer than three years that takes. Records for property or equipment purchased with federal funds must be kept for three years after the property's final disposition, not three years from the award's end. If an organization earns program income after its period of performance ends, and the federal agency requires records of it, those records are kept three years from the end of the fiscal year in which that income was earned. And indirect cost rate proposals and cost allocation plans have their own timeline depending on whether they were actually submitted for negotiation. A federal agency, pass-through entity, or cognizant agency for audit or indirect costs can also extend the retention period further by notifying the organization in writing (200.334(b)), for a pending review, for instance. Outside the exceptions listed in 200.334, agencies and pass-through entities may not impose other retention requirements, and the three-year requirement does not apply to records that have been transferred to or are maintained by the federal agency.

The Single Audit: what it is and who needs one

A Single Audit (governed by 2 CFR 200 Subpart F, sections 200.501 and following) is an organization-wide audit of a non-federal entity that expends federal awards at or above a certain dollar threshold in its fiscal year, covering both its financial statements and its compliance with federal award requirements, in place of doing a separate audit for every individual federal program. It replaces what would otherwise be a patchwork of program-specific federal audits with one audit covering everything, hence "single."

The threshold, and a number that changed recently

Under the 2024 revision to the Uniform Guidance, effective for fiscal years beginning on or after October 1, 2024, the Single Audit threshold is $1,000,000 or more in federal awards expended during the fiscal year (200.501), raised from the prior threshold of $750,000. This is a number worth getting exactly right, since older materials, older training, and some still-uncorrected web pages continue to cite the $750,000 figure that no longer applies to current fiscal years. An organization expending less than the threshold in a given fiscal year is exempt from the Single Audit requirement for that year, though it still has to keep its records available for review.

When the Single Audit report is due

2 CFR 200.512 sets the submission deadline for the Single Audit reporting package (submitted to the Federal Audit Clearinghouse) as whichever comes first of two triggers: 30 days after the organization receives the auditor's report, or nine months after the end of its fiscal year. This "earlier of" structure means an organization cannot simply wait for the nine-month mark if its auditor's report comes back sooner, and it cannot use a late-arriving auditor's report as an excuse to blow past the nine-month deadline either. The cognizant or oversight agency for audit may authorize an extension when the nine-month timeframe would place an undue burden on the auditee, and a due date that falls on a weekend or federal holiday moves to the next business day. The Federal Audit Clearinghouse (FAC) is the repository of record, and the data collection form is submitted there along with the audit and reporting package.

Why this connects back to subrecipient monitoring

Lesson 6 covered a pass-through entity's duty to verify that its subrecipients are audited as required and to follow up on audit findings that relate to the subaward. That duty only makes sense once the Single Audit threshold, retention rules, and submission deadlines covered here are understood, a pass-through entity cannot meaningfully review a subrecipient's Single Audit report if it does not know when that report is due, what threshold triggered the requirement, or how long the underlying records have to be available for its own review.

Record retention and the Single Audit threshold A timeline showing the three-year baseline retention period from final report submission, with branches for exceptions (litigation, property disposition, program income), alongside a separate box showing the Single Audit threshold of $1,000,000 or more in federal awards expended per fiscal year, effective for fiscal years beginning on or after October 1, 2024, with the submission deadline of 30 days after the auditor's report or 9 months after fiscal year end, whichever is first. Baseline: 3 years From submission of final financial report (or each recurring report, individually) Extends beyond 3 years if: litigation/audit started before expiry (until resolved); property records (3 yrs after final disposition); program income (3 yrs from that fiscal year end); or agency written extension Single Audit threshold $1,000,000 expended in federal awards per fiscal year (up from $750,000) FYs beginning on/after Oct 1, 2024 Submission deadline Earlier of: 30 days after auditor's report, or 9 months after fiscal year end
Two related but separate clocks: how long records must survive, and when a Single Audit is triggered and due.

Practice questions

1. Under 2 CFR 200.334, what is the baseline record retention period, and from what starting point?

  1. Five years from the award start date, or until the next audit is completed, whichever comes first
  2. One year from the award end date, unless the agency asks for the records sooner
  3. Three years from the date the final financial report is submitted
  4. Indefinitely, since records may never be destroyed under any federal award

2. If litigation or an audit begins before the three-year retention period expires, how long must records be kept?

  1. Exactly three years regardless, since litigation does not extend the retention period at all
  2. Until the litigation, claim, or audit is finally resolved, however long that takes
  3. An additional fixed one year only, counted from the date the case or audit is opened
  4. Records may be destroyed once litigation is filed, as the court then holds the originals

3. How long must records for property purchased with federal funds be retained?

  1. Three years after the property's final disposition
  2. Three years from the award start date only, the same as all other award records
  3. One year after purchase, once the item has been inventoried and tagged
  4. Property records need not be retained at all once the period of performance ends

4. As of fiscal years beginning on or after October 1, 2024, what is the Single Audit threshold?

  1. $500,000
  2. $750,000
  3. $1,000,000
  4. $2,000,000

5. What was the Single Audit threshold before the 2024 revision?

  1. $1,000,000
  2. $500,000
  3. $250,000
  4. $750,000

6. What does a Single Audit cover, and why is it called "single"?

  1. It covers only one specific federal program, chosen at random
  2. It is one organization-wide audit covering financial statements and compliance across all federal programs, replacing separate audits for each individual program
  3. It is conducted by a single auditor working alone with no firm behind them
  4. It only applies once in an organization's lifetime

7. Under 2 CFR 200.512, when is the Single Audit reporting package due?

  1. Always exactly 12 months after fiscal year end, with no possibility of an earlier deadline
  2. Always exactly 30 days after fiscal year end, regardless of when the auditor's report arrives
  3. The earlier of 30 days after receiving the auditor's report or 9 months after fiscal year end
  4. There is no fixed deadline; each pass-through entity sets the date through its own written policy

8. GCHS's auditor delivers its report 5 months after fiscal year end. When is the Single Audit reporting package due?

  1. 30 days after receiving the report (6 months after fiscal year end), since that is earlier than the 9-month mark
  2. 9 months after fiscal year end regardless of when the report arrived
  3. Immediately upon receipt, with no 30-day allowance
  4. There is no deadline once the auditor's report is late

9. Where is the Single Audit reporting package submitted?

  1. Directly to NGMA
  2. The Federal Audit Clearinghouse
  3. The Internal Revenue Service
  4. It is not submitted anywhere; it is kept internally only

10. An organization has an award with recurring quarterly financial reports rather than one final report. How does the three-year retention clock apply?

  1. Retention starts only once, at the award's very start, and runs three years from that single date
  2. Retention never applies to recurring-report awards, because each report replaces the last
  3. The clock resets with each report, three years from each individual report's submission date
  4. Only the final quarterly report matters; earlier ones can be discarded as soon as they are filed

11. Can a federal agency or pass-through entity require records to be kept longer than the standard three years?

  1. Yes, by notifying the organization in writing to extend the retention period, as 200.334(b) allows
  2. No, three years is an absolute maximum in every case, even during pending litigation or an audit
  3. Only NGMA can extend a retention period, by sending written notice to the organization's board
  4. Only a court order can extend retention, never a written notice from an agency or a pass-through entity

12. If GCHS expends $900,000 in federal awards in a fiscal year beginning after October 1, 2024, is a Single Audit required for that year?

  1. Yes, because $900,000 exceeds the old $750,000 threshold
  2. No, because $900,000 is below the current $1,000,000 threshold
  3. Yes, all organizations receiving any federal funds must have a Single Audit every year
  4. Only NGMA can determine this

13. Why does understanding record retention and Single Audit rules matter for reviewing a subrecipient's compliance, as covered in lesson 6?

  1. It doesn't connect; subrecipient monitoring and audit rules are unrelated
  2. Because subrecipients are exempt from Single Audit rules entirely
  3. Because NGMA requires it as a membership condition
  4. A pass-through entity cannot meaningfully review a subrecipient's Single Audit report without knowing the threshold that triggered it, the deadline it was due by, and how long underlying records must be available

14. In this course's grouping of topics under NGMA's four domains, where do record retention and Single Audit compliance belong?

  1. Grant Guidance
  2. Fiscal Management
  3. Program Management only
  4. Grant Award only

Glossary

2 CFR 200.334
The Uniform Guidance section setting the three-year baseline record retention period and its exceptions.
Single Audit
An organization-wide audit of financial statements and federal compliance, required when federal awards expended reach the threshold ($1,000,000 or more for fiscal years beginning on or after October 1, 2024) in a fiscal year.
2 CFR 200.512
The Uniform Guidance section setting the Single Audit reporting package submission deadline: the earlier of 30 days after the auditor's report or 9 months after fiscal year end.
Federal Audit Clearinghouse
The federal repository of record where Single Audit reporting packages and the data collection form are submitted (FAC.gov).