We are a small non- profit  research institution and are a sub-recipient =
for all our federal awards.  We are trying to define *major programs* for =
audit purposes  in our setting.  Our total award expenditures for all =
awards combined fall into the =24300,000 to =24430,000 range.  Our =
pass-thru contractor does not define major program in our subcontracts.

In the past, our external auditor has grouped all our federal awards =
together - awards from three federal agencies NIH, NASA, Army - and called =
them one major program the combined award amount was =24430,000.   With =
this definition of all our grants as one major program then the auditors =
are testing at 100%.

With the new A-133 regulations, we are requesting that they do a risk =
assessment and redefine our major programs into the separate grants.  =
Because we have had no material findings and no increased risk factors, =
for the next audit, we are trying to get a low risk status so that the =
auditors will be testing at 25%. =20

Does anyone have an opinion if our request is reasonable?  If you say yes, =
then can you give citations (from A-133)  that you would use to argue this =
with the auditor.=20

Thank you all in advance for your advise.