Author Archives: Connor Walker

Reviewing Changes Under Uniform Guidance

pointing handWith many changes coming to the Single Audit under the new Uniform Guidance, Aronson has outlined some of the major changes to help ease the transition to the updated Federal Grant and Single Audit Compliance Requirements.

 

Major Changes

  1. Threshold Changes:
    1. Non-federal entities expending $750K or more of federal funds during one fiscal year are subject to an audit under the Uniform Guidance.
    2. The threshold to determine Type A versus Type B programs has been raised to $750K.
    3. The threshold for reporting questioned costs had been increased to $25,000.
  2. Be wary that a133 has not simply been replaced by the Uniform Guidance. Federal awards made before December 26, 2014 still fall under a133.
  3. The new guidance is codified under 2 CFR Part 200 aka “Uniform Guidance” (sometimes referred to as the Super Circular). Visit http://www.ecfr.gov/cgi-bin/text-idx?tpl=/ecfrbrowse/Title02/2cfr200_main_02.tpl for greater detail.
  4. Changes are effective for years beginning after December 26, 2014.
  5. Uniform Guidance may also apply to incremental funding made after December 26, 2014 if the incremental funding changes the award’s terms and conditions. If unclear, inquire of your grantor’s representative to determine whether incremental funding is subject to the Uniform Guidance.

Subrecipient Changes

  1. Monitoring of subrecipients must now be “robust” and follow a system. Subrecipients are subject to the same procurement rules as federal awardees.
  2. Pass-through entities must evaluate each subrecipient’s risk of noncompliance for purposes of determining appropriate subrecipient monitoring.
  3. Subrecipients are no longer required to submit their reporting package directly to a pass-through entity.

Reporting Changes

  1. Changes to the Schedule of Expenditures of Federal Funds (SEFA):
    1. All expenditures of federal awards, including non-cash assistance and loan programs, must be presented on the face of the SEFA.
    2. The face of the SEFA must also include total expenditures for a cluster of programs and the total amount provided to subrecipients for each federal program.
  2. The Summary Schedule of Prior Audit Findings must now describe the reason for the recurrence of a prior year finding. All findings not fully corrected will need to be described in this manner.
  3. The Single Audit report, including the Schedule of Expenditures of Federal Awards and the Schedule of Findings and Questioned Costs, will be available to the public via the Federal Audit Clearinghouse (FAC) website.
  4. Specific Agency changes:
    1. Appendix VII of the Compliance Supplement states that effective for grants and cooperative agreements with budget periods beginning on or after December 26, 2014, and awards that receive supplemental funding on or after December 26, 2014, ALL awards issued by NIH meet the definition of “Research and Development”
    2. Effective for proposals due on or after January 14, 2013, ALL awards issued by the NSF meet the definition of “Research and Development”
  5. Section 200.24(b) states that when no CFDA number is assigned, all Federal awards to non-federal entities from the SAME agency made for the SAME purpose must be combined and considered one program

Grab Bag

  1. Conflict of interest now extends to the organizational level, meaning that any unequal access to information has to be disclosed to the federal agency.
  2. Employee morale is no longer an allowed cost.
  3. Period of Availability is now referred to as Period of Performance.
  4. The detailed specifics about internal controls are gone, which will allow nonprofits to create their own controls specific to their operations.
  5. Many agencies have codified the “Common Rule” A-110 Uniform Administrative Requirements with their own specific requirements. Be sure to check the CFR for agency specific requirements.
  6. To ensure that controls over compliance are sufficient in protecting federal fund expenditures, internal controls should assure 3 primary objectives:
    1. Reasonable assurance of effectiveness and efficiency of operations
    2. Reliable reporting
    3. Compliance with laws and regulations

Reviewing New Procurement Standards Under Uniform Guidance

Procurement guidelines had several changes that came with the codification of A-133 into the new Uniform Guidance.

  1. “Micro purchases” of less than $3,000 do not need competitive bids or price analysis.
  2. “Small” purchases are purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold ($150K). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources.
  3. If an agreement of $150K or more is reached with a contractor, the actual profit point worked into that agreement has to be negotiated separately.
  4. MBE/WBE (Minority Owned Business/Woman Owned Business) language that used to say to use these businesses “whenever possible” now says “must take all necessary steps.”
  5. Important: There is a one-year grace period for non-federal entities to implement changes to their procurement policies and procedures.
  6. Refer to the Bear Claw from COFAR:

bear-claw-1

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