PF 2025-02 Class Deviation to 2 CFR 910.501 Audit Requirements for For-Profit Organizations

DATE: October 2, 2024

SUBJECT: Class Deviation to 2 CFR 910.501 Audit Requirements for For-Profit Organizations

TO: HCAs/Procurement Directors/Contracting Officers
FROM: Director, Contract and Financial Assistance Policy Division, Office of Policy, Office of Acquisition Management

SUMMARY: In the recent update to 2 CFR 200, OMB raised the threshold for the single audit requirement in 2 CFR 200 Subpart F from $750,000 of expenditures in federal funds to $1,000,000. The Single Audit Act and its requirements in 2 CFR 200 Subpart F do not apply to for-profit organizations, however DOE determined the need to apply the principles of the Single Audit Act to for-profit organizations and included similar audit requirements in 2 CFR 910 Subpart F. 

The update for 2 CFR 910 Subpart F to increase the threshold requires a rulemaking with notice to and the opportunity for comment from interested parties. DOE was unable to complete the rulemaking by October 1, 2024. The class deviation increases the audit requirement threshold for for-profit organizations until the completion of the rulemaking. 

Questions concerning the policy flash should be directed to the Contract and Financial Assistance Policy Division, Office of Policy in the Office of Acquisition Management at DOE_oapmpolicy@hq.doe.gov.