Home / Resources / 2 CFR 200.501 explained
Updated August 2026
The regulation that decides whether your organization needs a single audit this year, translated out of regulation-speak.
§200.501 says one thing that matters to most nonprofits: if you expend $1,000,000 or more in federal awards in your fiscal year, you must have a single audit. Under that, you are exempt. The word doing the work is expend, not receive.
2 CFR Part 200 is the Uniform Guidance, the rulebook for federal awards to states, local governments and nonprofits. Subpart F is the audit subpart, and §200.501 is its front door: it decides who is in and who is out. If you land inside it, the rest of Subpart F applies to you. If you don't, almost none of it does.
“A non-Federal entity that expends $1,000,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single or program-specific audit conducted for that year in accordance with the provisions of this part.”
And the other side of it:
“A non-Federal entity that expends less than $1,000,000 in Federal awards during its fiscal year is exempt from Federal audit requirements for that year, except as noted in §200.503.”
Exempt from the audit requirement, not from the rules. Your records must still be available for review, and every other part of the Uniform Guidance you agreed to still binds you.
The threshold is not about how much you were awarded, how much sits in your bank account, or how much a multi-year grant is worth in total. It is about activity in one fiscal year. §200.502 sets the test:
“The determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs.”
Things that count toward the total, from §200.502:
Two that often surprise people: free rent on its own does not count, but it does when you receive it as part of a federal program award; and Medicare and Medicaid payments generally do not count, though a state may require Medicaid to be treated as expended on a cost-reimbursement basis.
§200.501(e). Keep your records available. Note that a funder or a state can still require an audit by contract, which is a separate obligation from this one.
§200.501(c) allows it when you expend awards under only one federal program, excluding research and development, and neither the program's rules nor your award terms require a financial statement audit.
§200.501(b). Conducted under §200.514.
“An auditee may simultaneously be a recipient, a subrecipient, and a contractor. Unless a program is exempt by Federal statute, Federal awards expended as a recipient or a subrecipient are subject to audit under this part.”
This is the paragraph that catches small organizations. A federal grant you received through a state agency, a city, or a larger nonprofit is still a federal award, and it still counts toward your threshold. Many organizations that think they have no federal funding are subrecipients and have not connected the two.
Money you received as a contractor is different. §200.501(h) puts the compliance responsibility for contractors on the auditee's procurement process, and payments to contractors are not federal awards expended by the contractor. The distinction between subrecipient and contractor is set out in §200.331, and it is decided by the substance of the relationship, not by what the agreement is called.
Keep a running total of federal awards expended, by program, updated monthly, using the §200.502 definition rather than a cash figure. If it is heading anywhere near $1,000,000, talk to an auditor early. If it is comfortably under, you still need the records, and you still need the compensation documentation at §200.430 if you pay anyone from a grant.
This is general information, not legal or accounting advice. Federal grant rules change and are applied differently by different agencies and auditors. Check with your auditor, your grant officer, or an attorney before relying on any of it.
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A non-Federal entity that expends $1,000,000 or more in Federal awards during its fiscal year must have a single or program-specific audit. It was $750,000 before the Uniform Guidance revision effective 1 October 2024.
Spent. 2 CFR 200.502 bases it on when the activity related to the Federal award occurs, not when you were awarded the money or when it arrived.
Yes. Under 200.501(g), Federal awards expended as a subrecipient are subject to audit under this part, so pass-through funds count toward your threshold.
Under 200.501(e) you are exempt from Federal audit requirements for that year, though your records must remain available for review and a funder or state may still require an audit by contract.
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Sources: 2 CFR Part 200 (eCFR), §200.501 and §200.502. Verified August 2026. Read the sections themselves before relying on any summary.