Tag Archives: Federal grants and contracts

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 Be wary that a133 has not simply been replaced by the Uniform Guidance.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

Updates to A-133 and the Single Audit

checklistAs I’m sure you’ve all been hearing, there have been some changes to A-133 and the Single Audit environment. Some of it is confusing and some raise more questions than they answer. Undoubtedly, more will be revealed as more trainings and more guidance becomes available. In the meanwhile, here is some key information to know:

  • The OMB Circulars have been codified and are now all included in 2 CFR Part 200.
  • The short-hand to refer to this is “Super Circular” but we’ll see if that sticks or if we just keep calling it A-133.
  • The changes are effective for years *beginning* after December 15, 2014.
  • The changes apply to new grants after that time. Continuing grants that cross that threshold fall under the old guidelines.
  • The threshold for needing to obtain a Single Audit is increasing from $500K to $750K.
  • The threshold for determining Type A vs. Type B programs is increasing from $300K to $750K.
  • The Single Audit report – including the Schedule of Expenditures of Federal Awards and the Schedule of Findings and Questioned Costs is available to the public now through a searchable database on the Federal Audit Clearinghouse website located here: https://harvester.census.gov/fac/dissem/accessoptions.html
  • There will be an option to go with a flat 10% indirect rate instead of negotiating a rate.
  • The term “vendor” has gone away and has been replaced by “contractor” to hopefully reduce confusion about what applies to who in the vendor vs. contractor debate.
  • Procurement documentation is more stringent – the wiggle room of only seeking competition “to the maximum extent practical” has gone away and the threshold for needing to document price comparisons is now $3,000. “Micro-purchases” of less than $3K don’t need competitive bids or price analysis. This particular point has raised a lot of questions and hopefully there will be more explicit instructions available on this.
  • The 14 areas of compliance will be whittled down to 13. The Real Property and Equipment section will be removed but likely the points will be included elsewhere.
  • The best place to see the compliance requirements is still the compliance supplement available at http://www.whitehouse.gov/omb/circulars/a133_compliance_supplement_2014

If you’d like to hear more about these points and more on general compliance, check out my latest webinar available on-demand at http://www.lorman.com/bookstore/393861EAU?discount_code=X2993284&p=13389

 

 

The New Single Audit Threshold, Just In Time for the Holidays

00022583We’ve been keeping an eye on the OMB Circular A-133 reform and it has finally moved from “in the pipeline” to “actually published”. On December 26, 2013, most of you certainly had Single Audit thresholds foremost in mind as the Office of Management and Budget (OMB) published its final revised grant rules.  A key change that will impact a number of you, is the change to the threshold determining who must undergo an A-133 audit. Currently, if the organization expends $500,000 or more in federal funding (cumulative of all federal grants awarded), it must obtain a Single Audit. The new rules increase that threshold so that now an organization must expend $750,000 or more in federal funding before being required to undergo a Single Audit. The new rule will be effective for fiscal years starting January 1, 2015 and after, meaning December 31, 2015 will be the first of the year ends to qualify for the change.

 

2013 Data Collection Form Status

For those of you with fiscal year ends that are already needing to process your Data Collection Form, you may calendarhave noticed that the 2013 form is not available yet. The Governmental Audit Quality Center (GAQC) has addressed some concerns in an email blast this morning. Perhaps most importantly – there is a submission date waiver for when auditees have to have their form processed. The rules are the lesser of 30 days since the date of the audit opinion or within the first 9 months after the organization’s year end. Without having a 2013 form available, many organizations are edging or past that 30 day mark as using an earlier version is not allowed. From the email:

“DCF Submission Date Waiver.  The FAC has extended the 2013 DCF submission waiver language that is posted on its Web site through January 31, 2014.  The extension language appearing on the FAC Web site is now as follows:  ‘If a single audit for a fiscal period ending in 2013 is due before the 2013 Form is available, auditees will not be able to meet the 30 day or 9 month deadlines for submission prescribed by OMB Circular A-133 §_.320(a). Therefore, OMB has granted an extension until January 31, 2014. The extension is automatic and there is no approval required. The extension applies only to single audits for the fiscal periods ending in 2013.'”

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