CBA Quality Assurance & Compliance 3 — Questions and Answers
Question 1: Which OMB circular establishes requirements for grants management and single audits of non-federal entities receiving federal funds?
- OMB Circular A-11
- OMB Circular A-94
- 2 CFR Part 200 (Uniform Guidance) (Correct answer)
- OMB Circular A-76
Correct answer: 2 CFR Part 200 (Uniform Guidance)
2 CFR Part 200, known as the Uniform Guidance, consolidates federal grant requirements and establishes the single audit threshold and requirements for non-federal entities.
Question 2: What is the single audit threshold under the Uniform Guidance (2 CFR Part 200) that triggers audit requirements for non-federal entities?
- $500,000 in federal expenditures per year
- $750,000 in federal expenditures per year (Correct answer)
- $1,000,000 in federal expenditures per year
- $250,000 in federal expenditures per year
Correct answer: $750,000 in federal expenditures per year
Non-federal entities that expend $750,000 or more in federal awards during a fiscal year are required to obtain a single audit or program-specific audit.
Question 3: In the context of federal budget compliance, what does 'bona fide need' doctrine require?
- All purchases must be competitively bid
- Funds may only be obligated for needs arising within the period of availability (Correct answer)
- Agencies must document cost-benefit analyses for all expenditures
- Contractors must prove financial solvency before award
Correct answer: Funds may only be obligated for needs arising within the period of availability
The bona fide need rule requires that appropriations be used only for needs that exist during the period for which they were appropriated, preventing agencies from obligating funds for future-year needs.
Question 4: Which document serves as the primary vehicle for agencies to communicate budget execution data to OMB on a monthly basis?
- SF-132 Apportionment and Reapportionment Schedule
- SF-133 Report on Budget Execution and Budgetary Resources (Correct answer)
- SF-1081 Voucher and Schedule of Withdrawals
- DD-1414 Base for Reprogramming Actions
Correct answer: SF-133 Report on Budget Execution and Budgetary Resources
The SF-133 is the standard form agencies use to report monthly budget execution data to OMB, showing status of budgetary resources.
Question 5: A 'continuing resolution' that limits agency spending to the prior year's rate means an agency receives which type of apportionment?
- Time-based apportionment at a pro-rated share of prior year enacted levels (Correct answer)
- Full-year apportionment based on the President's budget request
- Category B apportionment by program activity
- No apportionment until the CR expires
Correct answer: Time-based apportionment at a pro-rated share of prior year enacted levels
Under a continuing resolution, agencies typically receive time-based apportionments that limit spending to a prorated portion of the prior year's enacted appropriation.
Question 6: Which federal law prohibits agencies from making or authorizing expenditures exceeding available appropriations?
- Federal Acquisition Regulation (FAR)
- Budget and Accounting Act of 1921
- Antideficiency Act (31 U.S.C. §§ 1341-1342) (Correct answer)
- Improper Payments Elimination and Recovery Act
Correct answer: Antideficiency Act (31 U.S.C. §§ 1341-1342)
The Antideficiency Act (31 U.S.C. §§ 1341-1342) prohibits federal officers and employees from making expenditures or incurring obligations exceeding amounts available in appropriations.
Question 7: What is the purpose of an 'obligation freeze' during the fourth quarter of the fiscal year?
- To prevent agencies from exceeding their annual budget authority
- To ensure year-end spending aligns with mission needs and avoids year-end spending sprees (Correct answer)
- To allow OMB to recapture unspent funds for reallocation
- To satisfy GAO reporting requirements for end-of-year reviews
Correct answer: To ensure year-end spending aligns with mission needs and avoids year-end spending sprees
Obligation freezes help agencies avoid improper year-end spending sprees where funds are obligated hastily rather than for genuine mission needs, ensuring compliance with bona fide need requirements.
CBA Quality Assurance & Compliance 3
Which OMB circular establishes requirements for grants management and single audits of non-federal entities receiving federal funds?