The number that decides whether your organization owes a single audit just changed, and a lot of grant budgets are still built around the old one. As of the 2024 revision to the Uniform Guidance, a single audit is triggered when a non-federal entity expends $1,000,000 or more in federal awards during its fiscal year — up from the $750,000 line that had stood since 2003. The trigger is written into 2 CFR 200.501, and the way most grantees read it is exactly where they get into trouble. Understanding the single audit requirements is less about knowing the dollar figure and more about knowing which dollars count.

The $1M Trigger Is About What You Spent, Not What You Won

The most expensive misreading of the single audit requirements is treating the threshold as a measure of money awarded or money in the bank. It is neither. The regulation keys on federal awards expended during your fiscal year, which means a $2 million grant you were awarded but have barely drawn down does not trigger an audit, while several smaller grants you spent down aggressively might. The federal government’s own guidance is blunt about it: the U.S. Department of Health and Human Services Office of Inspector General notes that the single audit covers a non-federal entity’s expenditures of federal awards, and that the threshold rose to $1,000,000 for periods beginning on or after October 1, 2024.

Two more details inside that word “expended” trip people up. First, expenditures include the indirect costs you charged to federal grants, not just the direct program spending. Second, the total is aggregated across all of your federal funding, not measured grant by grant. Spend $600,000 from one federal grant and $500,000 from another in the same year and you are at $1.1 million combined — over the line, even though no single award reached it. The document that drives this calculation is your Schedule of Expenditures of Federal Awards (SEFA), which is exactly why finance teams sitting near the threshold need a clean SEFA before fieldwork, not after.

Who Just Fell Off the Hook — and Who Newly Landed on It

Raising the threshold by $250,000 created a band of organizations that were audited under the old rule and are not under the new one. If your federal expenditures cleared $750,000 but stay under $1,000,000 in a fiscal year, you no longer trigger a single audit under Subpart F. For a small nonprofit, that can remove a five-figure annual expense and weeks of staff time. That “donut hole” between the old and new thresholds is the single biggest practical effect of the 2024 change, and it is the part most checklists still get wrong because they were written against the $750,000 number. We mapped this alongside the other dollar shifts in our nonprofit grant writing compliance checklist, where the audit line is one of seven gates that moved in the same revision.

Falling below the line does not mean falling out of scrutiny

Being under $1M removes the federal single audit obligation — it does not make your federal money invisible. The same regulation that exempts sub-threshold entities also states that your records must remain available for review or audit by the federal agency, the pass-through entity, and the Government Accountability Office. Most foundation and state funders also still expect an independent financial review regardless of where you land against the federal number, so organizations managing a mix of federal grant funding and private dollars rarely escape audit-ready bookkeeping entirely. The savings are real, but they are a reduction in one specific compliance expense, not a license to loosen internal controls.

The Program-Specific Audit: The Cheaper Path Most Grantees Miss

When organizations cross $1M, they assume a full single audit is the only option. It often is — but not always. Under 2 CFR 200.507, an entity that expends federal awards under a single program (and is not required by that program to have a financial statement audit) may elect a program-specific audit instead. A program-specific audit reviews compliance for that one program rather than auditing the entity’s full financial statements and every federal stream, which can meaningfully reduce cost and scope for a tightly focused grantee — think a clinic running one large HRSA award and little else.

The submission mechanics are nearly identical to a single audit, which is why the choice is easy to overlook. Either way, the reporting package goes to the Federal Audit Clearinghouse, and the clearinghouse itself confirms it accepts both single audits and program-specific audits. The deadline is the same too: the earlier of 30 calendar days after you receive the auditor’s report, or nine months after your fiscal year-end. For a June 30 year-end, that puts the hard deadline at March 31. Picking the right audit type early — before you engage a firm — is one of the few levers that changes the bill.

The Threshold Move You Did Not Notice: Type A Programs

Even organizations that still need a full single audit are affected by a second dollar change in the same revision. The Type A program threshold — the cutoff that determines which of your federal programs are large enough to be tested as “major” — also rose from $750,000 to $1,000,000 for entities with total federal expenditures under roughly $34 million. Accounting firm BDO flagged this as one of the two most notable changes in the 2024 guidance, sitting in 2 CFR 200.518 right alongside the headline audit threshold.

The practical effect: even if your audit is still required, fewer of your programs may get pulled in for detailed compliance testing, which can shorten fieldwork. The flip side hits pass-through entities. If you sub-grant federal dollars and historically relied on collecting a subrecipient’s single audit report to satisfy your monitoring duty, a subrecipient that now falls under $1M may no longer produce one. That forces you to revisit your subrecipient risk assessment and monitoring approach, and to update any subaward agreements that still reference the old $750,000 figure. For organizations building a federal funding pipeline that includes sub-awards, that is a real change to post-award workflow, not a footnote.

What Actually Changes in Your Compliance Calendar

The effective date matters as much as the number. The new threshold applies to fiscal years beginning on or after October 1, 2024 — in practice, years ending September 30, 2025 or later. A calendar-year organization first applies the $1M trigger to the fiscal year that began January 1, 2025, and federal agencies were explicitly barred from early-adopting the audit provisions. So if you are closing out an earlier fiscal year, the $750,000 line may still govern that audit even though the regulation now reads $1,000,000.

The National Council of Nonprofits frames the post-2024 rule cleanly: any non-federal entity that expends $1 million or more in federal funds in a fiscal year must obtain a single audit (or a program-specific audit, if applicable), and the package must reach the Federal Audit Clearinghouse on that 30-day-or-nine-month clock. Note the order of operations for next year’s budget: estimate expenditures, not awards; aggregate across every federal source including pass-throughs; and decide single versus program-specific before you shop for an auditor. Nonprofits managing this against a wider grant portfolio can pressure-test their numbers using OpenGrants’ nonprofit grant resources to see which awards actually count toward the line.

Frequently Asked Questions

What are the single audit requirements in plain terms?

A single audit is a combined audit of your organization’s financial statements and your compliance with federal award rules, required when you expend $1,000,000 or more in federal awards in a fiscal year. It is governed by 2 CFR Part 200, Subpart F, conducted by an independent auditor under government auditing standards, and submitted to the Federal Audit Clearinghouse. It is broader than an ordinary financial statement audit because it specifically tests how you spent and managed federal money.

Is the threshold based on money awarded or money spent?

Money spent. The single audit requirements key on federal awards expended during your fiscal year, aggregated across all federal programs, and including indirect costs charged to those grants. A large award you have not drawn down does not trigger an audit; several smaller grants you spent down to a combined $1 million or more does. Your Schedule of Expenditures of Federal Awards is the document that settles the question.

If I spend under $1 million, am I completely off the hook?

You are exempt from the federal single audit requirement for that year, but not from everything. Your records must stay available for review by the awarding agency, any pass-through entity, and the GAO, and many state and foundation funders still require an independent financial review. If you sit between $750,000 and $1,000,000, you fell out of the federal audit requirement under the 2024 change but should keep your bookkeeping audit-ready.

When did the new $1 million threshold take effect?

It applies to non-federal entity fiscal years beginning on or after October 1, 2024 — effectively years ending September 30, 2025 or later. Calendar-year organizations apply it starting with the fiscal year that began January 1, 2025. Federal agencies could not adopt the audit provisions early, so earlier fiscal years may still be governed by the $750,000 threshold.

What is a program-specific audit and when can I use it?

A program-specific audit reviews compliance for a single federal program rather than auditing your entire entity and all federal streams. Under 2 CFR 200.507, you may elect one if you expend federal awards under just one program and that program does not require a financial statement audit. It typically costs less and is narrower in scope, with the same Federal Audit Clearinghouse submission deadline as a single audit.

Bottom Line: Run the Expended Math Before You Budget

The single audit requirements did not just get easier — they got more conditional. The headline is a higher trigger at $1 million, but the decisions that actually control your cost and risk are underneath it: whether you measure expended dollars instead of awarded ones, whether you are aggregating every federal source correctly, whether a program-specific audit fits, and whether the Type A shift changes what gets tested or what your subrecipients now owe you.

If your federal expenditures are anywhere near the line, the move this quarter is to build a draft SEFA now and pin down your single-versus-program-specific path before fiscal year-end, not after the auditor quotes you. Organizations that want a second set of eyes on which awards count and how to keep post-award compliance clean can lean on OpenGrants’ grant writing and compliance support to map their federal spend against the new threshold — and avoid paying for an audit they no longer trigger, or missing one they now do.