Grant Compliance Audit & AUP Services for DC, Maryland & Virginia Nonprofits

What is a grant compliance audit and when is it required?

A grant compliance audit verifies that an organization spent grant funds according to the funder's requirements, applicable regulations, and the grant agreement. Funders may require a full compliance audit or an agreed-upon procedures (AUP) report — a narrower, less expensive engagement. Federal grants over $1,000,000 (raised from $750,000 effective for fiscal years beginning on or after October 1, 2024) trigger a Single Audit under 2 CFR 200. State, foundation, and corporate grants vary by funder.

Why Nonprofits Need Grant Compliance Help

Our city grant requires a compliance report but we can't afford a full audit

Agreed-upon procedures (AUP) engagements perform specific compliance tests the funder specifies, at a fraction of a full audit's cost. Many funders accept AUPs for grants under $500,000.

We received a federal sub-award and don't know our compliance obligations

As a sub-recipient of federal funds, you inherit all the compliance requirements of the prime recipient. If the prime expended $1M+, you may be subject to Single Audit monitoring even if your sub-award is small.

Our procurement documentation failed a site visit and the funder wants a corrective plan

Federal procurement rules (requiring competitive bids for purchases over $10,000) are the most violated compliance requirement. A compliance review identifies and remediates these issues before they become findings.

We can't properly document time and effort for grant-funded staff

Time and effort (T&E) documentation — contemporaneous records showing what percentage of each employee's time was charged to each grant — is required for salary allocations. Reconstructed records are generally not acceptable.

A foundation funder asked for a report showing how we spent their grant

Many foundations require a grant expenditure report with third-party verification. An agreed-upon procedures engagement provides this verification efficiently.

Grant Compliance Engagements — No Surprises

Key Grant Compliance Terms

Agreed-Upon Procedures (AUP): An attestation engagement where a CPA performs specific procedures agreed upon by the client and a specified party (funder, grantor, or regulator), then reports factual findings. Unlike an audit, the CPA issues no opinion — only a report of what was found. AUPs are commonly required by federal sub-award agreements, city/county grants, and foundation funders.

Sub-recipient Monitoring: The process by which a pass-through entity (prime recipient) monitors organizations it has awarded federal sub-grants to ensure they comply with federal program requirements. Pass-through entities must assess sub-recipient risk, provide technical assistance, review financial and performance reports, and conduct site visits for high-risk sub-recipients.

Grant Compliance Engagement Options

Feature	AUP Report	Full Grant Audit	Single Audit (2 CFR 200)
Scope	Specific procedures only	Comprehensive program compliance	All federal programs + FS
Assurance	Findings only (no opinion)	Reasonable assurance	Reasonable assurance + compliance
Fees	Fee quoted upfront — narrowest scope	Fee quoted upfront	Fee quoted upfront — reflects number of federal programs
Timing	Set by the procedures agreed	Set by program scope and records	Set by the number of major programs and records
Required when	Funder specifies AUP	Funder requires full audit	$1M+ federal awards

Grant Compliance Services We Provide

Agreed-upon procedures (AUP) engagements for foundation and government grants

Federal grant compliance audits (2 CFR 200 / Uniform Guidance)

Single Audit compliance testing for major programs

Procurement documentation review and gap analysis

Time and effort documentation assessment

Sub-recipient monitoring procedures review

Corrective action plan (CAP) drafting

Multi-grant AUP engagements (combined scope)

Our Grant Compliance Process

Grant Agreement Review

We review your grant agreement, applicable regulations (2 CFR 200, program-specific requirements, state rules), and the funder's audit/AUP requirements to define the exact scope.

Compliance Testing

We test allowable costs (are expenditures within the grant budget and applicable cost principles?), procurement compliance (competitive bidding), time and effort documentation, reporting accuracy, and any program-specific requirements.

Sub-recipient Review (if applicable)

If you pass through funds to sub-recipients, we assess your monitoring procedures, review sub-recipient reports, and confirm required oversight is documented.

Report Issuance

We issue the compliance report (AUP findings report, compliance audit opinion, or Single Audit compliance opinion as required) within the deadline specified by the funder or grant agreement.

DC, Maryland & Virginia Grant Compliance Specifics

Washington DC

DC organizations receiving grants from the DC Office of Grants Management, DC DHHS, or DC Department of Housing are typically subject to grant-specific compliance requirements, often including AUP engagements as a condition of award.

Maryland

Maryland Department of Housing and Community Development grants require compliance audits for housing programs. Maryland DHHS sub-awards carry federal compliance requirements that flow through to sub-recipients.

Virginia

Virginia Department of Social Services sub-awards require sub-recipient monitoring documentation by prime recipients. VDSS site visits are common for human services nonprofits receiving significant state/federal pass-through awards.

Related Nonprofit Services

Nonprofit Audit Hub →Single Audit →Attestation Services →Audit Readiness →

Grant Compliance Frequently Asked Questions

A compliance audit provides an opinion — the auditor concludes whether the organization complied with grant requirements. An AUP provides only factual findings — the CPA reports what was observed without drawing conclusions. AUPs are narrower, faster, and less expensive. Many funders accept AUPs for smaller grants.

Standard compliance testing covers: allowable costs (are expenditures permitted under the grant?), allowable activities (do activities match grant scope?), eligibility (do beneficiaries qualify?), procurement (competitive bidding documentation), cash management (drawdown timing), reporting (accuracy of performance and financial reports), and special tests specific to the program.

Check the audit clause in your grant agreement. It typically specifies: (1) whether an audit or AUP is required, (2) the standard to be used (GAAS, GAGAS, AUP), (3) the deadline for submission, and (4) which party receives the report. If the clause is unclear, we can review it and advise.

Time and effort documentation failures account for roughly 40% of all grant compliance findings nationally. Federal regulations require contemporaneous documentation of the time grant-funded employees spend on each specific grant. Year-end reconstructions or percentage allocations without underlying records are generally not acceptable.

Yes — we can scope an AUP to cover multiple grants simultaneously, using shared procedures where grant requirements overlap. This significantly reduces the cost per grant compared to separate engagements.

Findings are reported in writing to management and, depending on your grant terms, may be shared with the funder. The organization is typically given an opportunity to submit a corrective action plan (CAP). Minor findings (comments) rarely jeopardize grants; material findings (questioned costs above $25,000) may result in cost disallowances.

As a sub-recipient, you must comply with all federal requirements that apply to the prime award, including allowable cost principles, procurement standards, and reporting. The prime recipient is required to monitor your compliance. You should maintain documentation as if you were subject to direct federal oversight — because effective monitoring means you are.

Yes — AUP reports are written for the specified parties (typically the funder and the organization). The report is not generally released to the public and is not filed with any government clearinghouse (unlike Single Audit reports).

Protect Your Grants with Expert Compliance Support

Clearly-priced AUP and compliance audit engagements. Licensed CPAs serving DC, Maryland, and Virginia.