Do non-federal audit requirements for commercial organizations apply only to HHS grants?
No. Per the regulations, a commercial organization is subject to audit requirements for a non-federal audit if, during its fiscal year, it expended $500,000* or more under HHS awards and at least one award is an HHS grant or subgrant. Therefore, the organization must have one grant or subgrant in order to be required to obtain a non-federal audit, but other HHS awards are included in the threshold calculations and the scope of the audit. (See threshold calculation examples.) [* Note: The threshold was $300,000 for audits of fiscal years ending before January 1, 2004.
