Sub-recipient Audit Approach

The audit of UNDP Sub-recipients (SRs) of Global Fund-financed projects are managed and commissioned by each UNDP Country Office (CO) following a risk-based audit plan that, after consultation with the UNDP Global Fund Partnership and Health Systems Team, is reviewed and validated by the UNDP Office of Audit and Investigations (OAI).  Once the audit of SRs is completed, the COs upload the final audit reports to OAI’s CARDS system for the OAI’s review and assessment.

Pursuant to Art. 7d(i) of the UNDP-Global Fund Framework Agreement, UNDP shall plan for the audit of SRs and will consult with the Global Fund to this effect.  The audit of the SRs shall take place in accordance with this plan. Upon request, UNDP must furnish the Global Fund with a copy of SR audit reports. 

Importantly, when the SR is a UN agency, it is not audited by UNDP, but instead is subject to its own oversight and control framework. However, UNDP has an obligation to provide the Global Fund with a copy of financial expenditure reports issued by UN SRs, see Art. 7d(ii) of the UNDP-Global Fund Framework Agreement. 

As per UNDP Financial Regulations and Rules audits of NGO-implemented and nationally implemented (NIM) projects are carried out to provide assurance to UNDP senior management as to the proper use of resources by SRs. Audit is an integral part of sound financial and administrative management, and part of the UNDP accountability system. Though currently exempt from the HACT (Harmonized Approach to Cash Transfers) framework, SRs – government and civil society organizations (CSOs) – who are entrusted with Global Fund resources must still be audited.

Please note that the guidance provided in this section of the Manual pertains to the audit of UNDP SRs of Global Fund-financed projects only. For guidance on the HACT audit of UNDP partners for non-Global Fund projects, please refer to the OAI Call Letter for HACT Audit Plans.

In early 2013, the UNDP Global Fund Partnership and Health Systems Team worked with OAI to define a new approach and process for audit of UNDP SRs of Global Fund projects. This was done to further enhance the management of SRs, as this area was identified as a high-risk area in the implementation of Global Fund projects.

The approach features several components, including long-term agreements (LTAs) with selected audit firms and expansion of the audit terms of reference (TORs) to include the following:  1) financial audit (Deliverable 1); 2) audit of SR internal controls and systems (Deliverable 2); and consolidated report of all key SR audit findings (Deliverable 3). Two audit firms are designated for each country, based on region. Depending on the region and country, however, it may be that only one firm is available to submit a bid and participate in the audit. 

In some exceptional circumstances, including country context and audit firm registration limitations, a CO may choose to work with a local audit firm instead of one of the firms under LTA. Local firms are still required to adhere to the expanded SR audit terms of reference. The CO should, at the start of the SR audit process, discuss with the UNDP Global Fund Partnership and Health Systems Team this, or any other foreseen deviation from the approach for audit of UNDP SRs for projects financed by the Global Fund.  

Exceptions to audit deliverable requirements:

1. Financial audit (Deliverable 1) is not required for SRs with which UNDP is engaged using the Direct Implementation Modality (DIM). Expenditure under this modality falls within the scope of the DIM audit regime.
2. Audit of SR internal controls and systems (Deliverable 2) is not required for grants that are closing due to UNDP exiting (e.g. transition to the national Principal Recipient or transition from the Global Fund financing) in the year the audit is scheduled. In addition, Delivery 2 will not be a requirement in case of transition between Implementation periods for Sub-recipients not continuing in the next implementation period if such information available. A financial audit, however, remains a requirement if any of the criteria detailed in the annual OAI Call Letter for HACT Audit Plans are met.
3. The consolidated report (Deliverable 3), which is designed to provide a consolidated summary of audit findings and trends across multiple SRs and grants is not necessary if only one SR is being audited.