[Federal Register Volume 73, Number 116 (Monday, June 16, 2008)]
[Notices]
[Pages 34056-34058]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: E8-13385]


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OFFICE OF MANAGEMENT AND BUDGET


OMB Circular A-133 Information Collection under OMB Review

AGENCY: Office of Management and Budget.

ACTION: Notice of Submission for OMB Review, Comment Request.

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SUMMARY: In accordance with the Paperwork Reduction Act of 1980, as 
amended (44 U.S.C. 3501 et seq.), this notice announces that an 
information collection request was submitted to the Office of 
Management and Budget's (OMB) Office of Information and Regulatory 
Affairs (OIRA) for processing under 5 CFR 1320.10. The first notice of 
this information collection request, as required by the Paperwork 
Reduction Act, was published in the Federal Register on December 5, 
2007 [72 FR 68608]. The information collection request involves two 
proposed information collections from two types of entities: (1) 
Reports from auditors to auditees concerning audit results, audit 
findings, and questioned costs; and (2) reports from auditees to the 
Federal Government providing information about the auditees, the awards 
they administer, and the audit results. These collection efforts are 
required by the Single Audit Act Amendments of 1996 (31 U.S.C. 7501 et 
seq.) and OMB Circular A-133, ``Audits of States, Local Governments, 
and Non-Profit Organizations.'' Circular A-133's information collection 
requirements apply to approximately 36,000 States, local governments, 
and non-profit organizations on an annual basis.

DATES: Submit comments on or before July 16, 2008. Late comments will 
be considered to the extent practicable.

ADDRESSES: Due to potential delays in OMB's receipt and processing of 
mail sent through the U.S. Postal Service, we encourage respondents to 
submit comments electronically to ensure timely receipt. We cannot 
guarantee that comments mailed will be received before the comment 
closing date.
    Electronic mail comments may be submitted via the Internet to 
[email protected]. Please include ``Form SF-SAC Comments'' in the 
subject line and the full body of your comments in the text of the 
electronic message and not as an attachment. Please include your name, 
title, organization, postal address, telephone number and E-mail 
address in the text of the message. You may also submit comments via 
Facsimile to (202-395-7285).
    Comments may be mailed to Alexander Hunt, Office of Information and 
Regulatory Affairs, OMB, 725 17th Street, NW., Room 10236, Washington, 
DC 20503.
    Comments may also be sent to via http://www.regulations.gov--a 
Federal E-Government Web site that allows the public to find, review, 
and submit comments on documents that agencies have published in the 
Federal Register and that are open for comment. Simply type ``Form SF-
SAC Comments'' (in quotes) in the Comment or Submission search box, 
click Go, and follow the instructions for submitting comments. Comments 
received by the date specified above will be included as part of the 
official record.

FOR FURTHER INFORMATION CONTACT: For further information, contact 
Gilbert Tran, Office of Federal Financial Management, Office of 
Management and Budget, 202-395-3052 and via e-mail: [email protected]. The data collection form, SF-SAC, and its 
instructions can be obtained by contacting the Office of Federal 
Financial Management, as indicated above or by download from the OMB 
Grants Management home page on the Internet at http://www.whitehouse.gov/omb/grants/grants_forms.html.

SUPPLEMENTARY INFORMATION:

A. Background

    OMB Control No.: 0348-0057.
    Title: Data Collection Form.
    Form No: SF-SAC.
    Type of Review: Reinstatement with change.
    Respondents: States, local governments, non-profit organizations 
(Non-Federal entities) and their auditors.
    Estimated Number of Respondents: 72,000 (36, 000 from auditors and 
36,000 from auditees). The respondents' information is collected by the 
Federal Audit Clearinghouse (Maintained by the U.S. Bureau of Census).
    Estimated Time per Respondent: 59 hours for each of 400 large 
respondents and 17 hours for each of 71,600 small respondents for 
estimated annual burden hours of 1,240,800.
    Estimated Number of Responses per Respondent: 1.
    Frequency of Response: Annually.
    Needs and Uses: 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 Federal Audit Clearinghouse (FAC) (maintained by the U.S. Census 
Bureau) uses the information on the SF-SAC to ensure proper 
distribution of audit reports to Federal agencies and to identify non-
Federal entities who have not filed the required reports. The FAC also 
uses the information on the SF-SAC to create a government-wide database 
which contains information on audit results. This database is publicly 
accessible on the Internet at http://harvester.census.gov/fac/. It is 
used by Federal agencies, pass-through entities, non-Federal entities, 
auditors, the General Accounting Office, OMB, and the general public 
for management and information about Federal awards and the results of 
audits.

B. Public Comments and Responses

    Pursuant to the December 5, 2007, Federal Register notice, OMB 
received 44 comments from 7 commenters relating to the proposed 
revision to the information collection. Letters came from State 
governments (including State auditors), the American Institute of 
Certified Public Accountants, certified public accountants (CPAs), and 
Federal agencies. The comments received relating to the information 
collection and OMB's responses are summarized below.

[[Page 34057]]

General

    Comments: All commenters, except one, supported the proposed 
revisions to both the Form and related instructions. The one commenter 
suggested a delayed implementation for electronic filing (see response 
in the ``Electronic Filing'' section). Some requested clarifications on 
the Form's instructions.

Terminology Changes

    Comments: All commenters supported the terminology from 
``Reportable Conditions'' to reflect ``Significant Deficiencies'' and 
the definition change for ``Material Weaknesses'' in line with changes 
in A-133 due to AICPA's Statement on Auditing Standard (SAS) No. 112, 
``Communicating Internal Control Related Matters Identified in an 
Audit.''

Electronic Filing

    Comments: All commenters, except one, supported the proposal to 
require all-electronic filing. The one commenter felt it is too early 
to put the requirement in place due to inadequate Internet access and 
computer savvy among many local government and non-profit auditees.
    Response: OMB feels the requirement will prompt most auditees and 
auditors to make the minor technological improvements needed to comply. 
Currently, 87% of the SF-SAC Forms are filled out on-line. Only 2% of 
those contained errors relating to signatures and dates. The proposed 
electronic submission will eliminate signature errors. Of the remaining 
13% of the forms that were filled out manually, 25% of those contained 
errors that would not otherwise occur with Forms created on-line. The 
proposed electronic submission will eliminate form and signature 
errors. On-line submissions will include a mandatory checklist for all 
required audit components. This is expected to make a marked reduction 
in the nearly 11,000 submissions received each year missing audit 
components or data collection forms.
    Comments: One commenter requested more clarification regarding the 
electronic submission process.
    Response: Agreed. More details are added in the Form's 
instructions. OMB and the FAC are pursuing the best practices for 
implementing the technological changes and will implement improvements 
as needed. The FAC will use the mandatory e-mail address from the 
auditee and the auditor responsible for signing and certifying the Form 
SF-SAC as part of a form certification process. These e-mails will not 
be posted on the Web site unless they are also entered in the Part I, 
Item 6(f) and 7(f) of the form. When an auditee or auditor is ready to 
sign their on-line Form SF-SAC, they will initiate the certification 
process. Once the certification process has been initiated, the FAC 
Internet Data Entry System (IDES) will send an email to the auditee's 
and auditor's certifying officials. Each certifying official will be 
given a unique number in the e-mail to serve as a signature code. 
Instead of signing the form SF-SAC, the certifying officials will enter 
their unique signature code instead of a signature.

Size of PDF Files and Links to Audits

    Comments: In order to minimize the size of the attachments, one 
commenter offered an alternative proposal to allow for the submission 
of Web site location(s) of the required audit reports to the Federal 
Audit Clearinghouse. The Federal Audit Clearinghouse processors would 
click the link and save the required files to their network.
    Response: The FAC estimates an average file size of 1.65 MB for an 
OMB Circular A-133 reporting package. Based on this average file size, 
the FAC does not believe a large amount of time will be needed to 
upload a reporting package to the FAC Internet Data Entry System. The 
size of PDF files is not an issue due to the significant advances in 
electronic file storage capacity and costs.
    The on-line electronic submission process requires the auditee to 
submit the reporting package in a consistent format over a secure 
server. Currently, the audits available on Web sites do not offer the 
required electronic file consistency or security needed for processing 
thousands of submissions. Most audits on Web sites do not include all 
of the required audit components in a single document as required.

Form SF-SAC and Instructions

    Comments: Several commenters offered suggestions to improve 
formatting and wording of the Form SF-SC and Instructions.
    Response: Agreed. Most formatting suggestions were accepted and the 
problems were fixed. A few other suggestions were not needed, or were 
not feasible.
    Comments: One commenter recommended adding instructions to the Data 
Collection Form (DCF) that outline the procedures for unlocking, 
revising and re-submitting a revised DCF.
    Response: Agreed. The FAC enhanced the written instructions to 
include instructions for on-line submissions and revisions. Detailed 
instructions will be available on the Web site.
    Comments: One commenter noted confusion regarding the previously 
proposed Form SF-SAC Instructions regarding including the HUD project 
number with the auditee name.
    Response: The HUD number is not a requirement, but may be included 
to supplement the project name in the Auditee name field. The Form SF-
SAC instructions were revised to make this distinction clearer.
    Comments: There are instances where multiple auditors are engaged 
to conduct an audit, OMB should add continuation sheet similar to the 
Part I, Item 5 sheet to provide the ability to capture additional 
auditor information.
    Response: Agreed. OMB changed the proposed 2008 Form SF-SAC to 
allow for the inclusion of additional auditors contact information. One 
primary auditor is still required. The additional auditors will be 
considered secondary auditors for the purposes of the Single Audit.
    Comments: One commenter expressed concern about how indirect awards 
are required to be reported in the Federal Awards Expended During 
Fiscal Year table. The commenter recommends that OMB clarify whether 
the reporting for indirect awards must be at the same level of detail 
as the Scheduled of Expenditures of Federal Awards (SEFA). If so, the 
OMB should consider how and whether this information is being used in 
practice and whether it should continue to be required in such detail.
    Response: No change. In order to manage the Federal programs, 
Federal Agencies continue to need the list of CFDAs on the Form SF-SAC 
in the same detail as shown on the SEFAS. The Federal agencies need to 
see the sources of separate programs even if they have the same CFDA 
number.
    Comments: In regards to Part III, Item 9 column (d)--Name of 
Federal Program, one commenter suggested clarification if column 9d of 
Part III needs to include pass through entity name and pass-through 
award number, particularly for the R&D Cluster. That information is 
required on the Schedule of Expenditures of Federal Awards and can be 
looked up by any federal agency for which there is a finding listed for 
a pass-through award. Practice varies and enforcement by agencies is 
inconsistent.
    Response: Agreed. The Form instructions are revised to read that 
the pass-through entity name is not required.
    Comments: In regards to Part III, Item 9 column (e), one commenter 
suggested clarifying the instructions in relation to loan programs not 
receiving any new

[[Page 34058]]

federal dollars, particularly Perkins, but are continuing to lend money 
from funds generated from repayments. The current instructions are not 
clear on how to report under these circumstances.
    Response: Agreed. The Form SF-SAC Instructions are revised to refer 
the question of Federal loans or loan guarantees as expenditures to the 
OMB Circular A-133 Compliance Supplement or the Federal oversight (or 
cognizant) agency for determination.
    Comments: One commenter suggested improving the Form SF-SAC 
Instructions by referencing the June 26, 2007, Federal Register notice 
that changed the number of copies of the reporting package to submit to 
the FAC (from several to one).
    Response: Electronic submissions make the number of copies of the 
reporting package unnecessary (i.e., submission of hard copy of the 
reporting package is no longer needed). The reference was removed from 
instructions.
    Comments: One commenter suggest considering if the addition of the 
additional data elements such as ``Total Revenue'' would be useful.
    Response: This data element is a major change/addition to the 
proposed form. Adding new Form elements such as ``Total Revenue'' as 
well as others will be considered further for possible inclusion into 
future versions of the Form SF-SAC.

Danny Werfel,
Deputy Controller.
 [FR Doc. E8-13385 Filed 6-13-08; 8:45 am]
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