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The Schedule of Expenditures of Federal Awards (SEFA) is the schedule your organization — not your auditor — prepares to list every federal award it expended during the audit period. It is required by 2 CFR 200.510, and it is the document a Single Audit’s compliance testing is actually built on: get it wrong and the error follows through every major-program determination downstream. This guide walks through building it line by line: what counts as an expenditure and when, how to number and cluster programs, how to identify pass-through funds, how to handle loans and noncash assistance, how the total ties back to your financial statements, and what the notes to the schedule must say.
This guide assumes you already know whether a Single Audit applies to your organization. For the $1,000,000 expenditure threshold, major-program selection, and the audit process itself, see the CASRAI guide to the Single Audit under 2 CFR 200 Subpart F. This page is about constructing the schedule, not about who has to have one.
Step 1: Determine what counts as a federal award “expended”
The most common preparation error is treating the SEFA as a cash-receipts report. It isn’t. Under 2 CFR 200.502(a), the determination of when a federal award is expended is based on when the activity related to the award occurs — not when cash arrives. That activity includes, per 200.502(a): expenditure or expense transactions associated with grants, cost-reimbursement contracts, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under a loan or loan guarantee program; the receipt of property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the entity to an interest subsidy; and the period of insurance coverage under a federal insurance program.
Several categories have their own recognition rules, and each is a place a preparer can misstate the schedule if the rule is skipped:
- Loans and loan guarantees (200.502(b)): the amount expended is the value of new loans made or received during the audit period, plus the balance of loans from prior years for which the federal government still imposes continuing compliance requirements, plus any interest subsidy, cash, or administrative cost allowance received.
- Student loans at institutions of higher education (200.502(c)): an exception to the above — where the federal government imposes no continuing compliance requirements on the outstanding balance beyond repayment, only the value of loans made during the audit period counts as expended, not the accumulated back balance.
- Prior-year loan balances with no continuing compliance requirement (200.502(d)): loans received and expended in a prior year, where the only remaining federal requirement is repayment, are not federal awards expended in the current period at all.
- Endowment funds (200.502(e)): the cumulative balance of a federally restricted endowment fund is considered expended in each audit period the restriction remains in force.
- Free rent (200.502(f)): free rent received on its own is not a federal award expended. Free rent received as part of a federal award to carry out a federal program must be included in the expended total and is subject to audit.
- Noncash assistance (200.502(g)): covered separately below, since it has its own valuation rule.
- Named exclusions: Medicare payments for patient care services (200.502(h)) are not federal awards expended by the provider; most Medicaid payments to a subrecipient are excluded unless a state specifically requires cost-reimbursement treatment (200.502(i)); and loans from the National Credit Union Administration’s Share Insurance Fund or Central Liquidity Facility are excluded outright (200.502(j)).
Step 2: List each program by Assistance Listing number
Per 200.510(b)(1), the SEFA must list individual federal programs by federal awarding agency, using the applicable Assistance Listing number for each — the identifier formerly issued as a CFDA number, now maintained on SAM.gov. Where a program has no assigned Assistance Listing number, the schedule identifies it using another identifying number and discloses that no listing number is available. Every program line needs this identifier; a SEFA that groups spending only by agency name, with no listing number, does not meet 200.510(b) as written.
Step 3: Determine which programs form a cluster
Some programs cannot be listed as standalone lines — they must be reported together as a cluster. 2 CFR 200.1 defines a cluster of programs as “a grouping of closely related programs that share common compliance requirements,” and names three types:
- Research and development (R&D) — always treated as a cluster. Under 200.510(b)(3), R&D awards may be shown on the SEFA either by individual award or aggregated by federal agency and major subdivision within the agency, but they are reported as the R&D cluster for major-program determination regardless of how the schedule presents the dollar totals.
- Student financial aid (SFA) — the programs that make up federal student aid.
- Other clusters — combinations of programs that OMB designates in the annual Compliance Supplement (or that a state separately designates), because those specific programs share compliance requirements even though they aren’t R&D or SFA.
The consequence that actually matters for your SEFA and your audit: per 200.1, a cluster must be considered one program when major programs are selected under 200.518, not several. Report a cluster on the SEFA under its cluster name, with each individual program within it listed underneath, each carrying its own Assistance Listing number and awarding agency (200.510(b)(2)). Which specific programs are clustered under “other clusters” is not fixed from year to year — it is set in whichever edition of the Compliance Supplement covers your audit period, so confirm current-year clustering against that year’s supplement (see the CASRAI OMB Compliance Supplement entry) rather than carrying forward last year’s grouping by assumption.
Step 4: Identify pass-through funds and the pass-through entity
If your organization received any federal award as a subrecipient rather than directly from a federal agency, 200.510(b)(4) requires the SEFA to name the pass-through entity and include the identifying number that pass-through entity assigned to your subaward. Separately, 200.510(b)(4) also requires you to disclose the total amount you yourself provided to your own subrecipients from each federal program, if you passed funds further down the chain. A single organization can owe both disclosures in the same schedule — the pass-through-entity name/ID for funds it received, and the subrecipient total for funds it distributed — and they are not the same line. See the CASRAI dictionary entries for pass-through entity and subaward for how the roles are defined.
Step 5: Value noncash assistance
Federal noncash assistance — free rent received as part of an award, donated property, donated surplus property, or food commodities — is not omitted from the SEFA just because no cash changed hands. Per 200.502(g), it “must be valued at fair market value at the time of receipt or the assessed value provided by the federal agency” and included in the total federal awards expended. Document which of the two valuation bases you used and keep the support for it; an unsupported noncash valuation is exactly the kind of item an auditor will ask to trace.
Step 6: Disclose loan and loan-guarantee balances in the notes
For loan and loan-guarantee programs, 200.510(b)(5) requires the SEFA’s notes — not the summary table — to disclose the balances of loans outstanding at the end of the audit period, in addition to the current-period expended amount calculated under 200.502(b) above. A loan program can therefore appear on the SEFA with a modest in-period expenditure figure while its notes disclose a much larger outstanding balance still subject to federal continuing compliance requirements; both figures are required, and they answer different questions.
Step 7: Reconcile the total to your financial statements
The SEFA does not exist in isolation from your audited financial statements, and the connection is not optional: under 2 CFR 200.514(b), the auditor “must also determine whether the schedule of expenditures of Federal awards is stated fairly in all material respects in relation to the auditee’s financial statements as a whole.” An auditor cannot issue that opinion if nobody has reconciled the two.
In practice, the reconciliation works back from the federal revenue or federal-award expense line(s) in your financial statements to the SEFA’s grand total, and accounts for the differences a straight comparison will surface: timing differences between when revenue is recognized in the financial statements and when 200.502’s activity-based test recognizes an expenditure; program income netted against expenditures on one document but shown gross on the other; noncash assistance and loan-related amounts (Steps 5 and 6) that flow through the SEFA under their own recognition rules rather than through ordinary revenue recognition; and any federal amounts your financial statements combine with non-federal activity that the SEFA must break out separately. Keep the reconciliation as workpaper support — it is what lets you, not just the auditor, explain a total that will not otherwise match a general-ledger federal-revenue balance on its face.
Step 8: Write the notes to the SEFA
200.510(b)(6) requires the schedule to include notes describing the significant accounting policies used to prepare it — at minimum, the basis of accounting used (for example, cash or accrual) — and to state whether the entity elected to use the de minimis indirect cost rate, which OMB’s 2024 revision to the Uniform Guidance set at up to 15 percent of modified total direct costs, published in the Federal Register at 89 FR 30046. See the CASRAI guide to negotiated indirect cost rate agreements for how that election interacts with a negotiated rate. Combined with Step 6’s loan-balance disclosure, the notes typically carry: the accounting basis statement, the de minimis election statement (or the negotiated rate in use instead), and the loan/loan-guarantee outstanding-balance disclosure for any programs that have one.
A worked example
A simplified, illustrative SEFA excerpt showing how the elements above come together on the page (figures are constructed for illustration, not a real organization’s data):
| Federal agency / cluster | Program | Assistance Listing # | Pass-through entity (if any) | Federal expenditures | Passed through to subrecipients |
|---|---|---|---|---|---|
| U.S. Department of Health and Human Services — Research and Development Cluster | NIH Research Project Grants | 93.859 | Direct award | $1,240,000 | $180,000 |
| National Science Foundation | Direct award, non-clustered program | 47.049 | Direct award | $412,500 | $0 |
| U.S. Department of Education | Subaward under a state pass-through program | 84.031 | State Department of Education (award #SDE-2026-0417) | $96,300 | $0 |
Notes accompanying this excerpt would state the accounting basis used, confirm (or deny) the de minimis rate election, and, if any row above were a loan or loan-guarantee program, disclose its outstanding balance at period end — none of which belongs in the summary table itself.
What this page cannot tell you
Three things decide the specifics of your own SEFA, and none of them are answered by a general guide, because they are specific to your award and your institution:
- Which “other cluster” designations apply to your specific programs this year — that is set in the current edition of the Compliance Supplement, not in the regulation itself, and it changes.
- Whether your organization’s accounting basis for the SEFA matches or must be reconciled against your financial statements’ basis — a question your auditor and your controller need to agree on before the schedule is finalized.
- Whether a specific noncash item or loan balance you’re holding falls inside 200.502’s recognition rules at all — the rules above cover the common cases, not every edge case a real portfolio of awards can produce.
Checking this against the current guidance
The Compliance Supplement’s cluster designations are reissued annually, and which programs fall under “other clusters” for your audit period is exactly the kind of detail that a general guide like this one cannot freeze in place. The answer depends on which year’s Compliance Supplement covers your audit period.
It searches CASRAI’s indexed corpus of research-administration guidance and cites the passage behind each claim, so you can open the source and check it rather than take its word — and it says so when the corpus does not cover something instead of guessing. Two questions a day are free while you are signed out, no account and no card. Everything CASRAI publishes stays free to read. Your first free question is the one in that link; save the second for whichever of the three institution-specific items above actually applies to your award.
Where each of these requirements is written down
| Requirement | Authority | Where to read it |
|---|---|---|
| SEFA required contents (programs, Assistance Listing numbers, clusters, pass-through IDs, subrecipient amounts, loan-balance notes, accounting-policy notes) | 2 CFR 200.510(b) | Cornell LII, 2 CFR 200.510 |
| Basis for determining a federal award “expended” (activity-based recognition, loans, student loans, endowments, free rent, noncash, exclusions) | 2 CFR 200.502(a)–(j) | Cornell LII, 2 CFR 200.502 |
| Definition of “cluster of programs” and its effect on major-program determination | 2 CFR 200.1 | Cornell LII, 2 CFR 200.1 |
| Auditor’s requirement to opine on the SEFA in relation to the financial statements as a whole | 2 CFR 200.514(b) | Cornell LII, 2 CFR 200.514 |
| De minimis indirect cost rate raised to up to 15% of MTDC | OMB revision to 2 CFR 200, effective for fiscal years beginning on/after Oct. 1, 2024 | 89 FR 30046 |
Frequently asked questions
How do we know whether two federal programs we received should be reported as a single cluster on our SEFA, or as two separate program lines, and where do we check for the current year?
Research and development awards are always clustered, and student financial aid is always clustered. Beyond those two, whether any other specific pair or group of programs counts as an “other cluster” is decided by OMB in that year’s Compliance Supplement (or, separately, by a state), not by the regulation text itself — so the answer can change from one audit period to the next and has to be checked against the current-year supplement rather than assumed from a prior year’s schedule.
Who is responsible for preparing the SEFA — the entity or the auditor?
The entity (the auditee) prepares the SEFA as part of management’s responsibilities. The independent auditor’s role, under 2 CFR 200.514(b), is to determine whether the completed schedule is fairly stated in relation to the entity’s financial statements as a whole — a review-and-opinion function, not a preparation function.
Does the SEFA have to use the same basis of accounting as the financial statements?
2 CFR 200.510(b)(6) requires the notes to the SEFA to describe the accounting basis used to prepare it, which tells you a basis must be chosen and disclosed — but whether that basis matches your financial statements’ basis, or is separately reconciled to it, is a decision for your organization and your auditor to document, not something the regulation dictates in the abstract.
What happens if a program has no Assistance Listing number?
2 CFR 200.510(b)(1) still requires the program to be identified using another identifying number, with a note that no Assistance Listing number is available for that program — the absence of a listing number is not a reason to omit the program from the schedule.
Is noncash assistance actually required to appear on the SEFA?
Yes. Under 2 CFR 200.502(g), federal noncash assistance received as part of an award to carry out a federal program — free rent, donated property, donated surplus property, food commodities — must be valued at fair market value at the time of receipt or the value the federal agency assigns, and included in the total federal awards expended.
Related CASRAI resources
- The Single Audit (2 CFR 200 Subpart F): Requirements and Thresholds — the $1,000,000 expenditure threshold, major-program selection, and the audit process the SEFA feeds into.
- Single Audit Report Example: Inside a Reporting Package’s Structure — where the SEFA sits alongside the auditor’s opinions and the schedule of findings in the full reporting package submitted to the FAC.
- NICRA: Negotiated Indirect Cost Rate Agreements Explained — how a negotiated rate interacts with the de minimis election disclosed in the SEFA’s notes.
- Subrecipient Monitoring Checklist — the pass-through entity’s ongoing obligations once a subaward is identified on the SEFA.
- Dictionary: Single Audit (US)
- Dictionary: Catalog of Federal Domestic Assistance (CFDA) — the predecessor identifier to today’s Assistance Listing number.
- Dictionary: OMB Compliance Supplement — the annual publication that sets current-year “other cluster” designations.
Accuracy note: This guide reflects 2 CFR 200 as currently in effect, cited to the Cornell Legal Information Institute’s mirror of the eCFR text and to the Federal Register. Confirm current-year clustering designations against that year’s OMB Compliance Supplement, and confirm section numbers and figures against the current eCFR text of 2 CFR 200 Subpart D and Subpart F before relying on this guide for a specific SEFA preparation decision.
