It is the contractor's responsibility to ensure that all names and FIN's it uses have complied with the DHS contract audit requirements.

Often times a contractor will use different names and different FIN's on DHS contracts. DHS will expect an audit response from subrecipients for each name and FIN it uses on each contract. If a contractor uses multiple names and/or FIN's, the contractor must identify these multiple names and FIN's to DHS.

When multiple names and FIN's are used, the contractor must ensure that the contracted audit requirements are met for each name and FIN. This must be done by providing one of the two different types of Audit Letters: Audit Letter-Single Audit Required if the Single Audit is required or, Audit Letter-No Single Audit Required if the Single Audit is not required.

An example of this would be when a contractor enters into three contracts with DHS. The contractor uses its corporate name and FIN on two of the contracts. However, on the third contract the contractor uses the name of the facility in which the program is administered. At year end, the contractor submits to DHS an audit report using the corporate name.

On DHS books, the contractor has not complied with the audit requirements of the third contract (the contract under the name of the facility). This is true even if the information of the third contract is included in the audit report under the corporate name. It is the contractor's responsibility to identify the audit that contains the contractor's name and FIN.

To remedy this situation, the contractor should have submitted an Audit Letter with the audit report identifying all the contractor's names that the audit includes.