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Schedule of Expenditures of Federal Awards: How to Prepare the SEFA

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The schedule of expenditures of federal awards, or SEFA, is a supplementary schedule that lists every federal program a non-federal entity expended funds under during the fiscal year. It is the foundational document for a single audit: auditors use it to identify which programs are major, plan their testing scope, and assess whether federal award activity is completely and accurately reported. A well-prepared SEFA reduces audit friction and protects your organization from findings related to completeness and accuracy.

What Is the SEFA in a Single Audit?

The SEFA is a required schedule prepared by management under 2 CFR 200.510. It summarizes federal award expenditures for the fiscal year, organized by federal awarding agency and Assistance Listing Number (ALN), formerly known as the CFDA number. Auditors rely on the SEFA to determine which federal programs meet the dollar thresholds for major program testing and to confirm that no programs were omitted. The schedule is audited, not merely reviewed, and any material misstatement or omission can result in a finding.

Who Must Have a Single Audit and SEFA

Under 2 CFR 200.501, any non-federal entity that expends $1,000,000 or more in federal awards during a fiscal year must have a single audit. This threshold applies to fiscal years beginning on or after October 1, 2024. For fiscal years that began before that date, the prior $750,000 threshold still applies.

Non-federal entities include states, local governments, Indian tribes, institutions of higher education, and nonprofit organizations. For-profit entities typically fall under program-specific audit requirements rather than the Uniform Guidance single audit framework. If your organization receives federal funds through a pass-through entity, those indirect awards count toward your expenditure total the same as direct awards.

Determining whether you meet the threshold

Add up every dollar your organization expended on federal programs during the fiscal year, including:

  • Direct federal grants and cooperative agreements
  • Federal cost-reimbursement contracts
  • Indirect (pass-through) awards from state or local governments acting as pass-through entities
  • Non-cash assistance such as surplus commodities or donated property
  • Loans and loan guarantees, recognized under special rules in 2 CFR 200.502

Note that Medicare payments to a provider for patient care services are not considered federal awards expended. Medicaid payments to a provider are also excluded unless a state requires the funds to be treated as a federal award expended because reimbursement is made on a cost basis.

The result is your total federal award expenditures for the year. If it reaches $1,000,000, you need a single audit and a SEFA.

What the Schedule of Expenditures of Federal Awards Must Include

The content requirements for the SEFA come from 2 CFR 200.510(b). At a minimum, the schedule must show:

  • The name of each federal program and the federal awarding agency
  • The Assistance Listing Number (ALN) for each program, in XX.XXX format
  • The total expenditures for each federal program for the fiscal year
  • The cluster name for any program that belongs to a cluster of programs (such as the Student Financial Assistance Cluster)
  • For pass-through awards, the name of the pass-through entity and any identifying number assigned by that entity
  • Amounts passed through to subrecipients, broken out by program
  • Notes to the SEFA disclosing the basis of accounting used, whether the entity elected to use the de minimis indirect cost rate of up to 15 percent under 2 CFR 200.414, and, for loan and loan guarantee programs, the balances outstanding at the end of the audit period

Research and development (R&D) programs may be shown either by individual federal award or by federal awarding agency and major subdivision within the agency, which simplifies the schedule for institutions managing dozens of individual research awards from a single agency.

The ALN: getting it right

The ALN (formerly CFDA number) is the identifier that links each line of the SEFA to a specific federal assistance program in SAM.gov. It uses an XX.XXX format, in which the two-digit prefix identifies the awarding agency and the three-digit suffix identifies the program. Using an incorrect or outdated ALN is one of the most common SEFA errors. Pass-through entities sometimes transmit the wrong ALN in award documents, so management should verify each number directly in SAM.gov Assistance Listings rather than relying solely on the award letter.

When Is a Federal Award Expended?

This is one of the most misunderstood points in SEFA preparation. Under 2 CFR 200.502, an expenditure is recognized when the activity related to the federal award occurs, not when the funds are received or when a reimbursement request is submitted. For most cost-reimbursement grants, that means the SEFA should reflect costs incurred during the fiscal year, regardless of when the sponsoring agency actually sends the cash.

The practical consequence: if your organization incurred $800,000 in allowable costs on a federal grant by June 30 but did not submit the final reimbursement request until July, all $800,000 belongs on the SEFA for the year ended June 30. Reporting only the amounts actually received is a common error that understates federal expenditures and can leave major programs untested.

Special recognition rules apply to:

  • Loans and loan guarantees. New loans made during the year are counted, plus prior-year balances outstanding where continuing compliance requirements exist, plus any interest subsidies and administrative cost allowances. A special exception lets certain institutions of higher education count only loans made during the current period when the institution has no continuing compliance obligations.
  • Endowments. The cumulative balance of federally restricted endowment funds is treated as expended for each period the restrictions remain in place.
  • Non-cash assistance. Fair market value at the time of receipt, or the assessed value provided by the federal agency, is the measure.
  • Free rent. Free rent on its own is not treated as a federal award. It is included only when the entity receives it as part of a federal program.

Reconciling the SEFA to Your Financial Statements

Before handing the SEFA to your auditors, reconcile it to the general ledger and, where applicable, to amounts reported in the financial statements. Federal award expenditures typically appear as grant expenses, program service costs, or capital outlays depending on how your chart of accounts is structured. A SEFA that cannot be tied back to the books is an immediate audit flag and often leads to expanded testing.

A practical reconciliation approach:

  1. Pull every grant or contract coded as federal from your accounting system for the fiscal year.
  2. Map each award to its ALN and federal agency.
  3. Confirm that the total ties to the SEFA line by line.
  4. Investigate any variance and document the resolution.

The notes to the SEFA must disclose the basis of accounting (cash or accrual) used to prepare the schedule. If your financial statements are prepared on the accrual basis but your grant tracking system runs on a cash basis, you will need a bridge to reconcile the two before the SEFA is complete.

The Schedule of Expenditures of Federal Awards and Major Program Determination

Auditors use the SEFA as the starting point for determining which programs are major programs, which must receive specific audit procedures beyond the basic financial statement audit. The major program determination follows a risk-based model under 2 CFR 200.518:

  • Step 1: Identify Type A programs using the threshold table in 2 CFR 200.518. For an entity with total federal awards expended of $34 million or less, the Type A threshold is $1,000,000; the threshold rises for entities with larger federal portfolios.
  • Step 2: Assess risk for each Type A program.
  • Step 3: Identify high-risk Type B programs.
  • Step 4: Determine which programs must be audited as major, ensuring that auditors cover at least 40 percent of total federal awards expended (20 percent for low-risk auditees).

The 2024 revision to the Uniform Guidance rebuilt this table. The entry-level Type A threshold doubled from $500,000 to $1,000,000, and the underlying total-expenditures band rose from $25 million to $34 million, both for fiscal years beginning on or after October 1, 2024.

A SEFA that omits programs or understates expenditures can shift programs in or out of major status. That misstates audit scope and, in some cases, means a program that should have received compliance testing is never tested at all. Federal agencies and inspectors general look hard at completeness when reviewing single audit results.

Common SEFA Errors to Avoid

Organizations with limited grant accounting resources make the same errors repeatedly. Watch for these:

Omitting indirect federal awards. If your state agency passed federal Community Development Block Grant money through to your organization, that award must appear on your SEFA with both the federal ALN and the pass-through entity name. Many organizations track only direct federal awards and miss passthrough amounts entirely.

Reporting receipts instead of expenditures. The SEFA captures costs incurred, not cash received. If your ledger shows $1.2 million in federal grant receipts but $1.4 million in expenses charged to federal programs, the SEFA should show $1.4 million.

Using stale ALNs. ALNs occasionally change when programs are restructured. Verify each number in SAM.gov at least annually.

Missing non-cash assistance. Food commodities, donated personal property, and similar in-kind federal assistance must appear on the SEFA at fair value even though no cash changes hands.

Incorrect cluster assignments. Programs that belong to a defined cluster must be grouped together. Presenting a cluster program as a standalone program affects major program determination.

Submitting the Single Audit Reporting Package

Once the audit is complete, the auditee must submit the reporting package, including the SEFA, to the Federal Audit Clearinghouse (FAC) at fac.gov. Under 2 CFR 200.512, the deadline is the earlier of 30 days after the auditor’s report date or 9 months after the fiscal year-end. For a June 30 fiscal year-end, the backstop falls on March 31. For a December 31 year-end, the backstop falls on September 30.

Late submissions are publicly visible in the FAC database and can affect your organization’s risk rating for future federal awards. Building SEFA preparation into your year-end close process, rather than treating it as an afterthought once audit fieldwork begins, is the most reliable way to stay on schedule.

Working with Your Auditors

The SEFA is a management-prepared schedule, which means the responsibility for completeness and accuracy sits with your finance team, not with your auditors. Auditors express an opinion on the SEFA as part of the single audit, but they are not responsible for preparing it. Misunderstanding that responsibility leads to last-minute scrambles and, sometimes, to audit findings that could have been avoided.

The most productive approach is to bring a complete, reconciled draft SEFA to the auditors at the start of fieldwork, along with supporting documentation for each program: award agreements, final drawdown reports, and a reconciliation to the general ledger. Firms like Modus that use source-linked workpapers can tie each SEFA line to supporting documentation in real time, reducing the back-and-forth that extends timelines on single audits for nonprofits and other organizations managing large federal portfolios.

Frequently Asked Questions

What is the SEFA in a single audit?

The SEFA, or schedule of expenditures of federal awards, is a management-prepared supplementary schedule that lists all federal programs a non-federal entity expended funds under during the fiscal year. It is required by 2 CFR 200.510 and is audited as part of the single audit. Auditors use it to plan the scope of compliance testing and to identify which programs are major.

What is the single audit threshold for 2025?

For fiscal years beginning on or after October 1, 2024, the single audit threshold is $1,000,000 in federal award expenditures. Organizations with fiscal years that began before October 1, 2024 are still subject to the prior $750,000 threshold. This change was made by OMB’s April 2024 revision to the Uniform Guidance (2 CFR Part 200).

What must be included on the SEFA?

The SEFA must list each federal program by awarding agency and Assistance Listing Number (ALN), show total expenditures for each program, identify cluster memberships, disclose amounts passed to subrecipients, and identify the pass-through entity name and award number for indirect awards. Notes to the SEFA must disclose the basis of accounting and any election of the de minimis indirect cost rate.

Does the SEFA report expenditures or cash receipts?

The SEFA reports expenditures, meaning costs incurred based on when the activity related to the federal award occurs, not when cash is received. This is governed by 2 CFR 200.502. Reporting cash receipts instead of expenditures is one of the most common SEFA errors and can lead to audit findings.

What is the deadline to submit a single audit to the Federal Audit Clearinghouse?

Under 2 CFR 200.512, the auditee must submit the complete reporting package to the FAC at fac.gov within the earlier of 30 days after receiving the auditor’s report or 9 months after the fiscal year-end. Late submissions are publicly visible and can affect how federal agencies assess risk when awarding future grants.

What happens if programs are missing from the SEFA?

Omitting programs from the SEFA understates total federal expenditures, which can cause programs that should be tested as major to fall below the major program threshold and avoid compliance testing. Auditors who identify omissions during fieldwork will expand testing scope, and the finding will be reported in the single audit report. Repeated material omissions can result in a qualified or adverse opinion on federal award compliance.

Filed under: Single Audit & Government Nonprofit