Presenter Kelly Berger-Davis Quality Assurance & Technical - - PDF document
4/8/2015 Changes to Federal Grants & Single Audits (A-87, A-21, A-122, A-102, A-110, A-89, A-133 & A-50) The New OMB Uniform Guidance Presenter Kelly Berger-Davis Quality Assurance & Technical Specialist Center for Audit
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(A-87, A-21, A-122, A-102, A-110, A-89, A-133 & A-50)
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– “The
Single Audit Act
1984” (Public Law 98-502) established requirements for certain governments that administer Federal financial assistance programs.
– OMB Circular A-128 (Audits of States, Local Governments), issued in 1985 to help auditors and recipients implement the new Single Audit Act.
Education & Other Non-Profit Organizations), issued in 1990, where OMB extended the single audit process to non-profits. – A-133 requirements amended in 2003 & 2007 – Modified/included in Uniform Guidance in 2014
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– Each year, OMB issues an updated version
assist auditors in performing the required audits. – In addition, the AICPA maintains a guide titled Government Auditing Standards and Circular A-133 Audits which gives a basic description
the procedures auditors should perform and the reports they should issue for single audits.
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– Non-Federal entities that expend $500,000 or more in a year in Federal awards shall have a single or program-specific audit conducted for that year in accordance with the provisions of this part.
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– The audit shall be completed and the reporting required by paragraph (c)(2)or (c)(3) of this section submitted within the earlier of 30 days after receipt of the auditor's report(s), or nine months after the end of the audit period.
and submitted by 9/30/15.
and submitted by 3/31/16.
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meet the A-133 deadline, fails to comply with regulations, etc. there are several possible consequences a Federal awarding agency or Pass-through
entity may take: – Impose additional conditions – Temporarily withhold cash payments – Disallow all or part of the cost of the activity not in compliance – Suspend or terminate the Federal award – Initiate suspension or debarment proceedings – Withhold further Federal awards for the program – Other remedies legally available
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Reform (COFAR)
October 27, 2011 to provide recommendations to OMB
policies and actions necessary to effectively deliver, oversee, and report on grants and cooperative agreements. – In addition to other items, COFAR was also tasked with streamlining and simplifying the financial assistance process by eliminating unnecessary regulatory, reporting, and grant-agreement requirements and by increasing flexibilities for satisfying grant requirements.
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“Advance Notice of Grants Reform”
2012
“Proposed OMB Uniform Guidance”
2013 Final “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards”
26, 2013
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Frequently Asked Questions
Joint Interim Final Rule “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards”
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– Yes – if you receive or audit ANY federal grants!
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Federal Agencies
Not-for- Profits Indian Tribes Higher Education
Local Governments
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– Federal Agencies were required to adopt the guidance and implement the requirements to be effective by 12/26/14
the guidance in unison to provide for a smooth transition for entities that are required to comply
published on 12/19/14
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– Non-Federal entities: Administrative requirements and cost principles apply to new awards and to additional funding to existing awards (funding increments) made after 12/26/14
conditions for funds a non-Federal entity already received prior to that date
Federal awards will continue to be governed by the terms and conditions of the Federal award
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– Non-Federal Entities - Audit Requirements are effective for fiscal years beginning on or after 12/26/14
be effective for the 1/1/15 – 12/31/15 fiscal year
be effective for the 7/1/15 – 6/30/16 fiscal year
requirements cannot be early implemented
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– 6/30/14, 9/30/14, & 12/31/14 FYE’s – No impact – 3/31/15, 6/30/15, & 9/30/15 FYE’s –
cost principles apply to new federal awards and additional funding to existing awards
and single audit requirements all apply
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the effective date for non-federal entities to comply with the new procurement standards.
entity must document this decision in their internal procurement policies.
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Federal awards made prior to 12/26/14 when some subawards are made prior to 12/26/14 and others are made after 12/26/14?
subawards is the same as the effective date of the federal award from which the subaward is made. The requirements for a subaward, no matter when made, flow from the requirements of the original Federal award from the Federal awarding agency.
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– OMB clarified in their Feb. 2014 FAQ’s:
would anticipate that for many
the changes, non-federal entities with both old and new awards may make changes to their entity- wide policies (for example to payroll
procurement systems).
wide system changes to comply with the uniform guidance after the effective date of 12/26/14 will not be penalized for doing so.
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– OMB clarified in their August 2014 (and updated in
apply to new Federal awards made after December 26, 2014 and, if a Federal awarding agency considers its incremental funding actions to be
to change terms and conditions on previously made awards, the new guidance will apply to that Federal awarding agency’s incremental funding actions also.
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– This guidance makes grant requirements similar across all types of grant recipients and all federal agencies. – Aims to eliminate duplicative language, and to clarify where grant policies are different across entity types.
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– .100 Purpose – .105 Definitions
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– .300 Auditee responsibilities – .305 Auditor selection – .310 Financial statements – .315 Audit findings follow-up – .320 Report submission
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– .500 Scope of audit – .505 Audit reporting – .510 Audit findings – .515 Audit working papers – .520 Major program determination – .525 Criteria for Federal program risk – .530 Criteria for a low-risk auditee
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– Appendix A - General Principles for Determining Allowable Costs – Appendix B - Selected Items of Cost – Appendix C - State/Local-Wide Central Service Cost Allocation Plans – Appendix D - Public Assistance Cost Allocation Plans – Appendix E - State and Local Indirect Cost Rate Proposals
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listing
US Dept’s is available at http://www.whitehouse.gov/omb/grants_chart
– Section 1 – Pre-Award Policies – Section 2 - Post-Award Policies – Section 3 – After-The-Grant Policies
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Audit Requirements Audit Requirements Cost Principles Cost Principles Administrative Requirements Administrative Requirements
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– Chapter II – OMB Guidance
– Subpart A – 200.0 – 200.99 - Acronyms & Definitions – Subpart B – 200.100 – 200.113 - General Provisions » i.e. authorities, effective/applicability date, conflict of interest – Subpart C – 200.200 – 200.211 - Pre-Federal Award Requirements and Contents of Federal Awards » i.e. use
grant agreements, cooperative agreements and contracts, special conditions, public access to federal award information
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– Chapter II – OMB Guidance
– Subpart D – 200.301 – 200.345 - Post Federal Award Requirements » i.e. standards for financial and program management; property standards; procurement standards; performance and financial monitoring and reporting; subrecipient monitoring and management; record retention and access; remedies for noncompliance; closeout; post- closeout adjustments and continuing responsibilities; collection of amounts due
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– Chapter II – OMB Guidance
– Subpart E – 200.400 – 200.475 - Cost Principles » Formerly A-87 (A-21 and A-122) » i.e. general provisions; basic considerations; direct and indirect costs; special considerations for local gov’s; general provisions for selected items of cost – Subpart F – 200.500 – 200.521 - Audit Requirements » i.e. auditee responsibilities; federal agency responsibilities; auditor responsibilities; management decisions
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– Chapter II – OMB Guidance
– Appendix I – Full Text of Notice of Funding Opportunity – Appendix II – Contract Provisions for Non-Federal Entity Contracts Under Federal Awards – Appendix III
(F&A) Costs Identification and Assignment, and Rate Determination for Institutions of Higher Education (IHEs) – Appendix IV
(F&A) Costs Identification and Assignment, and Rate Determination for Nonprofit Organizations
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– Chapter II – OMB Guidance
– Appendix V – State/Local Governmentwide Central Service Cost Allocation Plans – Appendix VI - Public Assistance Cost Allocation Plans – Appendix VII – States and Local Government and Indian Tribe Indirect Cost Proposals – Appendix VIII - Nonprofit Organizations Exempted From Subpart E—Cost Principles of Part 200 – Appendix IX - Hospital Cost Principles – Appendix X – Data Collection Form – Appendix XI - Compliance Supplement
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Subpart A – 200.0 – 200.99 - Acronyms & Definitions
OLD (current) NEW Uniform Guidance Uniform Guidance Section
Circular A-133 Compliance Supplement Compliance Supplement 200.21 Vendor Contractor 200.23 n/a Personally Identifiable Information (PII) 200.79 n/a Protected Personally Identifiable Information 200.82 n/a Program Income 200.80
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Subpart B – 200.100 – 200.113 - General Provisions
Clarifies that the terms and conditions
federal awards flow down to subrecipients unless the Uniform Grant Guidance or the terms and conditions specifically indicate
Federal agencies must not impose additional
inconsistent requirements, except as provided in 200.102 and 200.210.
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Subpart B – 200.100 – 200.113 - General Provisions
Conflict of Interest
interest policies for their federal awards
potential conflict of interest to the Federal awarding agency (or pass-through entity) in accordance with the federal awarding agency policy
Mandatory Disclosures
Federal criminal law involving fraud, bribery, or gratuity violations potentially affecting the Federal award
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Subpart C – 200.200 – 200.211
Award Requirements and Contents of Federal Awards
Streamlined guidance to federal agencies on information required to be provided to non-federal entities
Determining the instrument to be used
Standard formats to announce funding
Fed’s required to consider risk posed by each applicant prior to making award
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Subpart D – 200.301 – 200.345 - Post Federal Award Requirements
GAO’s Green Book GAO’s Green Book COSO’s Internal Control Framework COSO’s Internal Control Framework Compliance Supplement, Part 6 Internal Control Compliance Supplement, Part 6 Internal Control Requires non-Federal entities to have effective internal controls over federal awards and mentions 3 best practices:
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Subpart D – 200.301 – 200.345 - Post Federal Award Requirements (cont’d)
Explicit information on what info must be included by a pass- through entity in its subawards at the time subaward is made
Pass-through entity’s responsibility to evaluate each subrecipients risk and develop appropriate subrecipient monitoring in response to the assessed risk
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Subpart D – 200.301 – 200.345 - Post Federal Award Requirements (cont’d)
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Subpart D – 200.301 – 200.345 - Post Federal Award Requirements (cont’d)
Federal entities adopt the majority of the language used from Circular A-102.
to determine the impact
your procurement procedures.
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Subpart D – 200.301 – 200.345 - Post Federal Award Requirements (cont’d)
acquisition of supplies or services if aggregate amount does not exceed $3,000
threshold is set by the Federal Acquisition Regulation, and therefore may change.
competitive quotations if the non-Federal entity considers the cost to be reasonable.
distribute these purchases among qualified suppliers.
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Subpart E – 200.400 – 200.475 - Cost Principles
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– Standards for Documentation
Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
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Subpart E – 200.400 – 200.475 - Cost Principles
clerical staff may be treated as direct costs if:
activity
individuals involved can be identified as specifically with the project
budget
have the prior written approval
the federal awarding agency, AND
costs
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Subpart E – 200.400 – 200.475 - Cost Principles
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Subpart E – 200.400 – 200.475 - Cost Principles
federally negotiated indirect cost rate may apply for a one-time extension of the rates in that agreement for a period of up to four years.
entity may not request a rate review until the extension period ends.
Federal entity must re-apply to negotiate a
to four years) are permitted if a renegotiation is completed between each extension request.
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Subpart E – 200.400 – 200.475 - Cost Principles
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Subpart E – 200.400 – 200.475 - Cost Principles
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– Non-Federal entities that are able to allocate and charge 100% of their costs directly may continue to do so – Claiming reimbursement for indirect costs is never mandatory – Entities will not be forced to establish an indirect cost rate if they feel it is not necessary
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– It also is not permissible for pass-through entities to force or entice a proposed subrecipient without a negotiated rate to accept less than the de minimis rate. – The 10% de minimis rate is not available to entities who receive more than $35 million in direct Federal funding
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Subpart E – 200.400 – 200.475 - Cost Principles
entities need to seek prior approval from the Federal awarding agency including:
program income to meet a cost sharing or matching requirement
in scope
a project/program
previously approved
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Subpart E – 200.400 – 200.475 - Cost Principles
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Subpart E – 200.400 – 200.475 - Cost Principles
Friendly Policies
care costs above and beyond regular dependent care that directly results from travel to conferences is allowable provided that: ⎯ The costs are a direct result of the individuals travel for the federal award; ⎯ The costs are consistent with the non-Federal entity’s documented travel policy for all entity travel; ⎯ Are only temporary during the travel period.
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Subpart E – 200.400 – 200.475 - Cost Principles
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Subpart F – 200.500 – 200.521 - Audit Requirements
Maintains
the dollars currently subject to Single Audit Reduces audit burden for approximately 5,000 entities
Increase in Single Audit Threshold
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3818 2832 2380 2357 2335 1830 1663 1458 1347 1141 1112 1035 1007 986 962 928 905 861 754 749 682 677 673 669 647 642 623 589 565 533 526 507 469 465 394 390 388 388 328 326 300 300 290 278 273 255 249 226 203 190 174 100 21 13 10 8 CA NY OH P A T X I L MI F L MA NJ MN MO W I W A NC I N GA V A K Y LA OK T N A L A Z I A A R OR MD CO MS S C CT DC K S W V NE ME NM MT A K P R V T S D NH UT I D RI ND NV HI W Y DE V I GU MP F M
NUMBER OF SINGLE AUDITS BY STATE
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$138,400,762,620 $134,670,138,495 $101,373,205,414 $98,777,195,641 $50,422,481,747 $46,687,356,248 $42,388,942,591 $41,497,029,671 $35,634,147,779 $35,602,716,862 $33,024,997,583 $30,665,337,847 $30,008,272,274 $23,794,530,573 $22,560,689,495 $22,538,873,999 $21,414,592,447 $21,158,549,843 $20,806,415,872 $19,771,240,617 $19,403,729,257 $18,145,911,284 $16,039,666,956 $15,404,054,689 $15,059,606,561 $14,879,486,221 $13,752,729,752 $13,458,844,907 $13,031,639,546 $13,013,321,660 $12,877,783,924 $12,243,384,286 $11,289,990,710 $10,590,752,025 $9,106,018,084 $8,693,875,703 $7,605,533,896 $7,398,655,281 $7,270,848,155 $7,055,661,487 $6,524,493,440 $6,285,028,107 $5,956,690,870 $5,639,386,491 $5,458,505,683 $5,415,238,050 $4,726,107,555 $4,571,905,306 $3,776,406,818 $3,038,606,074 $2,252,590,391 $1,161,858,385 $549,725,805 $404,001,061 $161,852,277 $161,182,594 NY CA T X P A F L I L OH NC MI MA NJ T N GA MO W A V A MD LA A Z I N W I MN CO K Y OR A L S C DC OK I A CT MS A R NM P R UT K S W V ND NV RI I D ME NE NH A K V T HI S D DE W Y MT GU V I MP F M
TOTAL DOLLARS COVERED BY SINGLE AUDITS FOR EACH STATE
Total
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87.79% 86.69% 86.89% 85.91% 85.61% 83.99% 83.58% 86.69% 87.82% 86.87% 84.22% 88.03% 89.09% 82.42% 83.02% 85.88% 86.41% 88.50% 84.91% 83.95% 87.52% 85.65% 83.46% 80.06% 84.74% 86.20% 86.42% 77.59% 84.07% 88.02% 86.87% 87.18% 86.99% 73.98% 86.86% 83.76% 82.47% 77.44% 93.00% 81.71% 81.60% 83.79% 80.33% 86.81% 81.65% 86.27% 86.75% 82.74% 79.80% 80.00% 80.46% 80.00% 85.71% 92.31% 90.00% 87.50% 12.21% 13.31% 13.11% 14.09% 14.39% 16.01% 16.42% 13.31% 12.18% 13.13% 15.78% 11.97% 10.91% 17.58% 16.98% 14.12% 13.59% 11.50% 15.09% 16.05% 12.48% 14.35% 16.54% 19.94% 15.26% 13.80% 13.58% 22.41% 15.93% 11.98% 13.13% 12.82% 13.01% 26.02% 13.14% 16.24% 17.53% 22.56% 7.00% 18.29% 18.40% 16.21% 19.67% 13.19% 18.35% 13.73% 13.25% 17.26% 20.20% 20.00% 19.54% 20.00% 14.29% 7.69% 10.00% 12.50% CA NY OH P A T X I L MI F L MA MN NJ W A NC MO W I I N GA V A LA K Y A L A Z T N OK A R OR MD I A CO S C MS CT DC K S NM W V ME NE P R MT A K S D V T UT NH I D RI ND NV HI W Y DE V I GU MP F M Over Under
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99.83% 99.79% 99.79% 99.79% 99.76% 99.62% 99.54% 99.84% 99.71% 99.52% 99.67% 99.77% 99.75% 99.53% 99.67% 99.73% 99.77% 99.67% 99.71% 99.59% 99.46% 99.50% 99.65% 99.51% 99.64% 99.64% 99.72% 99.71% 99.36% 99.31% 99.68% 99.65% 99.45% 99.70% 99.85% 99.74% 99.04% 99.47% 99.68% 99.64% 99.67% 99.64% 99.29% 99.04% 99.42% 99.31% 99.22% 99.49% 99.24% 99.58% 99.10% 96.84% 99.88% 99.56% 99.56% 99.56% 0.17% 0.21% 0.21% 0.21% 0.24% 0.38% 0.46% 0.16% 0.29% 0.48% 0.33% 0.23% 0.25% 0.47% 0.33% 0.27% 0.23% 0.33% 0.29% 0.41% 0.54% 0.50% 0.35% 0.49% 0.36% 0.36% 0.28% 0.29% 0.64% 0.69% 0.32% 0.35% 0.55% 0.30% 0.15% 0.26% 0.96% 0.53% 0.32% 0.36% 0.33% 0.36% 0.71% 0.96% 0.58% 0.69% 0.78% 0.51% 0.76% 0.42% 0.90% 3.16% 0.12% 0.44% 0.44% 0.44% NY CA T X P A F L I L OH NC MA MI NJ T N GA MO W A V A MD LA A Z I N W I MN CO K Y OR A L S C DC OK I A CT MS A R NM P R UT K S W V ND NV RI I D ME NE NH A K V T HI S D DE W Y MT GU V I MP F M Over Under
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Subpart F – 200.500 – 200.521 - Audit Requirements
Explicitly stated that the Federal Audit Clearinghouse is the authoritative source for single audit reports
Audit reports will be publically available on the FAC website
Federal agencies, pass-through entities, and others interested in obtaining audit reports must obtain it by accessing the clearinghouse, rather than requesting it from the non-federal entity
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Subpart F – 200.500 – 200.521 - Audit Requirements
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Subpart F – 200.500 – 200.521 - Audit Requirements
not report a substantial doubt about the auditee’s ability to continue as a going concern.
In the prior 2 audit periods, the auditor’s opinion on whether the financial statements were prepared in accordance with GAAP, or a basis of accounting required by state law, and the auditor’s in- relation-to opinion on the SEFA were unmodified.
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– (C) Local public
that use the "Uniform Accounting Network" shall file their annual financial reports in accordance with the guidelines established by the "Uniform Accounting Network." – (D) All other local public offices who do not prepare their annual reports using generally accepted accounting principles shall file their annual financial reports on the forms provided by the auditor of state. If the auditor of state has not prescribed an annual financial reporting format for a type of local public
annually with the auditor of state, using the format used by the local public office.
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Subpart F – 200.500 – 200.521 - Audit Requirements
Not Low-Risk Auditee Old (Current) 50% New 40% Low-Risk Auditee Old (Current) 25% New 20%
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Subpart F – 200.500 – 200.521 - Audit Requirements
period, did the program have ANY audit findings.
finding:
expenditures
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Subpart F – 200.500 – 200.521 - Audit Requirements
(OLD) – There were 2 Type B risk assessment options.
high-risk Type B programs have been identifies up to at least 1/4th of number of low-risk Type A programs
programs that do not exceed 25% of Type A threshold
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Subpart F – 200.500 – 200.521 - Audit Requirements
guidance
determining Type A programs.
revised Type A threshold calculation, a cluster of programs is not considered a loan program if the individual loan programs within the cluster comprise less than 50% of the total expenditures of the cluster.
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Subpart F – 200.500 – 200.521 - Audit Requirements
in the notes to the SEFA loan balances outstanding at the end of the audit period
expended for loan or loan guarantees in the SEFA
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Subpart F – 200.500 – 200.521 - Audit Requirements
federal entity elected to use the 10% de minimis cost rate
provided to subrecipients from each Federal program
practical”
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Subpart F – 200.500 – 200.521 - Audit Requirements
repeat from the immediately prior audit, and if so, the prior year audit finding number.
finding numbers must be in the format prescribed by the DCF (ie. 2014-001; NOT 2014-01,
sample
applicable award number.
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Subpart F – 200.500 – 200.521 - Audit Requirements
auditor)
status of any prior audit finding, it would be reported as an audit finding in the Schedule of Findings
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Subpart F – 200.500 – 200.521 - Audit Requirements
SEFA and the DCF
to combine the SEFA with the DCF to reduce duplication and improve accuracy of FAC data.
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Subpart F – 200.500 – 200.521 - Audit Requirements
include protected personally identifiable information (PII) and sign a statement stating such
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Subpart F – 200.500 – 200.521 - Audit Requirements
A persons first name, or first initial & last name in combination with:
SS #
Passport # Clearances Bank Numbers Biometrics Date and Place
Mothers Maiden Name
Criminal, Medical, & Financial Records
Educational Transcripts Credit Card # This does NOT include PII that is required by law to be disclosed.
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an unresolved FFR database, accessible to the public
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an auditee’s indirect cost proposal or cost allocation plan (CAP), that same auditor may not be hired to perform its single audit if the auditee’s indirect costs recovered during the prior year exceeded $1 million.
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Best Practices Recommended Approaches
“Should”
Requirements
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– (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” [Green Book] issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
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– (b) Comply with Federal statutes, regulations, and the terms and conditions of the Federal awards. – (c) Evaluate and monitor the non-Federal entity's compliance with statute, regulations and the terms and conditions of Federal awards. – (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. – (e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive
the non-Federal entity considers sensitive consistent with applicable Federal, state and local laws regarding privacy and obligations of confidentiality.
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–FAC has recently added a new pdf validator to ‘test upload’ your audit report prior to the actual upload to check whether it will pass the unlocked/unencrypted requirements.
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incremental funding actions that are subject to the new Uniform Guidance, non- federal entities are not obligated to segregate
but may do so at their discretion.
FAQ 200.110-7 if you run into this situation for further guidance.
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CFR (http://www.gpo.gov/fdsys/ )
http://www.whitehouse.gov/omb/grants_circulars for grants that still fall under it
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Single audit reporting deadline (currently 9 months) Reducing # of compliance requirements in Compliance Supplement
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that are applicable to your entity/entities you audit
the Uniform Guidance
into 1 document)
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from Predominant Source in Existing Guidance
to Predominant Source in Existing Guidance
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dates
effort, indirect costs, procurement, internal control, subrecipient monitoring)
process to update local policies and regulations on federal grants and internal controls
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88 E. Broad St. Columbus, Ohio 43215 Phone: (800) 282‐0370 Fax: (614) 466‐4490 E‐mail: ContactUs@OhioAuditor.gov
www.OhioAuditor.gov