How to Prepare the Schedule of Expenditures of Federal Awards (SEFA)

To prepare a Schedule of Expenditures of Federal Awards, list every federal program your organization spent money on during the fiscal year, group the programs by federal agency, report the required data for each one, add the required footnotes, and reconcile the total to your general ledger before it goes into your single audit package. The schedule is required for any non-federal entity that spent $1,000,000 or more in federal awards during a fiscal year beginning on or after October 1, 2024.¹²

Confirm You Have to File One

The threshold is based on federal funds actually spent during the fiscal year, not funds awarded or received. An organization awarded $2 million that only spent $800,000 within the fiscal year does not trigger the requirement. Spending across many small grants from different agencies still counts toward the threshold, so tracking cumulative federal spending throughout the year is the only reliable way to know whether a single audit is coming.

The requirement applies to state and local governments, federally recognized Indian Tribes, institutions of higher education, and nonprofit organizations.³ Organizations that spend less than $1,000,000 in federal awards are exempt from single audit requirements for that year but must still keep records available for review by federal agencies, pass-through entities, and the Government Accountability Office.²

Counting Non-Cash Awards

Federal assistance does not always arrive as cash. Food commodities, donated property, surplus property, free rent tied to a federal program, and insurance coverage all count as federal awards and contribute to the threshold. Non-cash assistance is valued at fair market value at the time of receipt, unless the federal agency assigns a different value, in which case use the agency’s figure.⁴ Free rent by itself does not count; free rent received as part of a federal program does.

Counting Loans and Loan Guarantees

Because the federal government remains at risk until the debt is repaid, loan programs are reported at more than the new money received during the year. The value of a federal loan program on the schedule equals the value of loans made or received during the audit period, plus the beginning-of-year balance of prior-year loans where the federal government still imposes compliance requirements, plus any interest subsidy, cash, or administrative cost allowance received.⁴ Loans from prior years where the only remaining requirement is repayment are excluded entirely.

An exception applies to student loans at institutions of higher education. If the school does not make the loans itself, such as Direct Loans where the school only certifies eligibility, only the new loans made during the audit period are counted. Prior-year balances stay off the schedule because the lender tracks them.⁴

Data Required for Each Program Line

The regulation at 2 CFR 200.510(b) spells out what has to appear on the schedule. Programs are organized by federal agency, and each program gets its own line with the following information:⁵

The name of the federal agency that originated the funding, even if the money reached you through an intermediary.
The Assistance Listing number and title (formerly the CFDA number).
Total federal expenditures for that program during the fiscal year.
If the award came through a pass-through entity, the entity’s name and the identifying number it assigned to the award.
The total amount your organization passed along to subrecipients under that program.

Pass-Through Awards Run Both Ways

If your organization received federal funds through a state agency, university, or other intermediary, the schedule has to identify that pass-through entity by name and include the identifying number it assigned. Without that number, auditors and federal agencies cannot trace the money from its source to you.

The obligation runs the other direction too. If your organization is a primary recipient that passes federal funds down to subrecipients, you must report the total distributed to subrecipients under each federal program.⁶ Leaving that column blank when you did distribute funds downstream is a compliance failure auditors specifically look for.

Clusters

Some federal programs are grouped into clusters, sets of closely related programs that share compliance requirements. The OMB Compliance Supplement defines them, and the two most common are Research and Development (R&D) and Student Financial Assistance (SFA).⁷ Report a cluster as a group under the relevant federal agency, but still break out each component program within it. Auditors treat the whole cluster as one program for major program determination, so accurate grouping matters.

Required Footnote Disclosures

The schedule is not just a table of numbers. It requires accompanying notes that, at a minimum, describe the significant accounting policies used to prepare it.⁵ That means stating whether the schedule uses the accrual, modified accrual, or cash basis of accounting, along with any other policies that affect how expenditures are recognized.

If your organization elected the 10 percent de minimis indirect cost rate allowed under 2 CFR 200.414(f), the election has to be disclosed in the notes.⁸ The FAC’s SF-SAC workbook has a specific field asking whether you used the de minimis rate, a different negotiated rate, or a combination. Missing this disclosure is a common audit finding.

Reconcile and Review Before Submission

The most frequent errors on the schedule are not exotic accounting problems. They are data entry and reconciliation errors that a careful review would catch.

Reconcile the schedule to the general ledger. Total federal expenditures on the schedule must tie to the accounting records. If the schedule shows $1.2 million and the general ledger shows $1.15 million, the auditor will flag the discrepancy and you will need a corrective action plan to explain it.

Check every Assistance Listing number against sam.gov. The GAO identified multiple types of formatting errors in FAC data spanning several years, including numbers that did not correspond to any actual federal program.⁹ Confirm the accounting policy note and, if applicable, the de minimis rate disclosure are both present. Verify that each pass-through award carries the intermediary’s name and the identifying number it assigned; keep a running list of those numbers as awards come in rather than trying to reconstruct them at year-end. Confirm that every program line with subrecipient distributions shows the total passed through.

Submitting the Schedule With the Audit Package

The completed schedule is one piece of the reporting package submitted to the Federal Audit Clearinghouse at fac.gov. The package also includes the financial statements, the auditor’s reports, a summary schedule of prior audit findings, and a corrective action plan for any current findings.¹⁰ The SF-SAC data collection form goes in as well, using the Excel workbook templates the FAC provides.¹¹ The full audit report is uploaded as a PDF, and the SF-SAC workbooks are uploaded as Excel files. Both the auditor certifying official and the auditee certifying official need Login.gov accounts, and certification happens in that order: auditor first, auditee second.¹²

Deadline

The reporting package must reach the FAC within 30 calendar days after the auditee receives the auditor’s report, or nine months after the end of the audit period, whichever comes first.¹⁰ If the deadline falls on a Saturday, Sunday, or federal holiday, the package is due the next business day. For a June 30 fiscal year end, the nine-month window closes March 31 of the following year; if the auditor delivers the report on January 15, the 30-day window closes February 14, and the earlier date is the actual deadline.

The cognizant or oversight agency for audit may authorize an extension when the nine-month timeframe would create an undue burden, but the FAC help center notes that federal agencies no longer grant general extensions for single audit submissions. An organization may still contact its cognizant or oversight agency to discuss a late filing.¹³

What Happens If the Schedule Is Wrong or Late

Missing the deadline or filing an inaccurate schedule can trigger real consequences. Under 2 CFR 200.339, a federal agency or pass-through entity may withhold payments until corrective action is taken, disallow costs (which can mean repaying the agency), suspend or terminate the award, initiate suspension or debarment proceedings, or block new awards and continuation funding.¹⁴

Late submissions also affect future audits. An organization that misses its deadline may be classified as a high-risk auditee, which means more programs tested, more documentation required, and a more expensive audit.

1
U.S. Election Assistance Commission. 2024 Uniform Guidance Revisions
2
eCFR. 2 CFR Part 200 Subpart F – Audit Requirements
3
eCFR. 2 CFR 200.1 – Definitions
4
GovInfo. 2 CFR 200.502 – Basis for Determining Federal Awards Expended
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eCFR. 2 CFR 200.510 – Financial Statements
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eCFR. 2 CFR 200.510 – Financial Statements
7
Office of Management and Budget. Compliance Supplement 2024 – Part 5 Clusters of Programs
8
Federal Audit Clearinghouse. SF-SAC Section 2 – Notes to SEFA
9
United States Government Accountability Office. Single Audits – Improving Federal Audit Clearinghouse Information and Usability Could Strengthen Federal Award Oversight
10
eCFR. 2 CFR 200.512 – Report Submission
11
Federal Audit Clearinghouse. SF-SAC Workbooks
12
FAC Help Center. How Do I Submit an Audit to the FAC
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FAC Help Center. How Do I Request an Extension on the Due Date
14
eCFR. 2 CFR 200.339 – Remedies for Noncompliance