Transcript NEW!

What are the Changes in the Uniform Administrative, Cost Principles and Audit Requirements and How Might This Impact Your Organization ?

Deirdre M. Joseph City of Tampa

If you don’t like something change it; if you can’t change it, change the way you think about it.~ Mary Engelbreit

Who, What, When,



2009 – Executive Order to Reduce Improper Payments 2011 Presidential Memo on Administrative Flexibility, Lower Costs 2011 COFAR established to coordinate improvements

Reduce Paperwork Standardization Reduce Waste, Fraud, Abuse Flexibility





When, Why?

A50 A87 A122 A133 A110 A89 A102

• •


, What, When, Why?

Federal Agencies Recipient and Sub-Recipient Non-Federal Agencies

* States, Local Governments, Indian Tribes

• •

Institutions of Higher Learning Auditors

Who, What,


, Why?

December 26, 2014

Where Do I Find It?

• • • • • • Subpart A: Acronyms and Definitions Subpart B (100): General C (200): Pre-Award D (300): Post-Award E (400): Cost Principles F (500): Audit Appendices


Categorize, Cross-Reference & Consult Procurement ~ Documentation ~ Inventory ~ Allowability Category


OMB Requirement

200.113 - Mandatory Disclosure:

Requires disclosure, in writing, of

City of Tampa Compliance

The City of Tampa's procurement policy requires review vendors the City is unable to conduct business; grant requires review any violations of Federal criminal law involving fraud, of Excluded Party List bribery, or gratuity violations affecting the Federal award.


*Consider adding review of the State's convicted vendor list to Purchasing manual *Formal bid language may be expanded *Agreements may be impacted.

Legal ~ Human Resources ~ Internal Audit ~ Purchasing ~ Finance

Focus Now

Performance over Compliance

– Pre-Award Review – Clear milestones identified in agreements •

Strengthened Accountability

– Earlier communication of audit findings

Terminology Must



(Required) (Best Practice)

Audit Threshold


Single Audit Threshold = $750,000

Old = $500,000 New = $750,000

Get All Departments Engaged

200. 447 Insurance & Indemnification

“ Deletes policy requirement that Federal government will participate in actual losses of a self-insurance fund that are in excess of reserves.”


Involve Legal, Risk Management and Purchasing

200.206: Collection of Standardized Information on Applications

Grant Intake Information Form Grant Title:____ Granting Agency:____ Description_________ Contract#: _____ CFDA#:_______ Pass Through Entity:______ Federal Funding: $________ Period of Performance: State Funding: $________ Start Date:_____ End Date:______ Local Match: $________ Grant Type:

City’s Match: $________  Financial Reporting Schedule: _______ Progress Reporting ______

• •

200.203 Notice of Funding Opportunities


Notices must remain open for at least 30 days!


Standardizes information to be provided in Summary

• • • • • Federal Awarding Agency Name/Funding Opportunity Title/ Announcement Type (initial or modification) Funding Opportunity Number Catalog of Federal Financial Assistance (CFDA) Numbers Key Dates (due dates for applications or submissions and intent) • (C)

Full Text of Funding Summary

– Summary Information

200.207: Specific Conditions

• • Applicants or Recipients who have a history of ‘failure to comply” with general or specific terms and conditions or failure to meet expect performance goals


– Awarding agency may impose additional specific award conditions

Example: Requiring payments as reimbursements rather than advance payments

Fixed Amount Awards

• • • 200.201


Allow for ‘Fixed Amount’ awards

Awards rely more on Performance than Compliance • Payments are based on specific requirements such as performance, milestone and results

Grant Agreements

• •


Subpart D- Post Federal Award Requirements


inclusion of performance goals in award’s terms and conditions, as a programmatic requirements.

200.301 Performance Measurement

Federal Agencies


include performance goals aligned with program goals in notice • Entities


relate financial data to performance accomplishment

Goal = Response $100K purchase of Interoperable Communications 1 st quarter + 30% of our State can now Respond

• •

Cost Sharing or Match



Voluntary committed cost sharing is


expected and

cannot be used as a factor

during the merit review of applications or proposals.

• • • • •

CONSIDER Criteria for Cost Share/Match: Verifiable in records Not included in any other Federal award Necessary and reasonable to accomplish program Not paid by Federal Government Allowable in Subpart E


• • 200.317

States may use their own written procurement policies and procedures

• Open Competition • • Ensure Most Economical Purchase Conflict of Interest • • Mandatory Disclosures Must perform cost analysis on all non competitive contracts • All contracts must include required clauses

Review of Risk of Applicants

• • 200.205

An evaluation framework must be in place (e.g. Do Not Pay) • Where necessary, specific conditions must be imposed to mitigate potential risk

200.333 Record Retention


– Files must be maintained for 3 years from the date of FINAL Expenditure Report

Family Friendly Policies Encouraged NEW!

Cost of identifying locally available child care resource is allowable.


Allows temporary dependent care cost that meet specified standards for travel


Allows family leave as a fringe benefit

TIP: Review existing policies with Human Resources

Pass Through Entity Requirements

• • • • • 200.331

Sub Awards must be clearly identified Risk Evaluation of sub-recipient’s Verify compliance to audit requirements May impose specific sub-award conditions – – – –

Withhold cash Disallow cost Terminate (or temporary suspend) award Suspension and Debarment

Indirect Cost Rates

• • Must accept approved negotiated rate Pass-through entities must provide an indirect cost rate for sub-awards • If no Negotiated Rate; then 10% rate in effect

Merit Review Proposal

200.204 –


Must have a merit review process


• • 200.313

The State can follow their own equipment standards •


Computing Devices with a value of $5,000 or less will be considered supplies


• • 200.313 (continued) CLARIFICATION on SHARED USE. Allowed if such use will not ‘interfere” 1 st – Projects supported by federal agency 2 nd – Projects funded by other federal agencies 3 rd - Use for non-federally funded programs

Methods of Collection Transmission & Storage of Information

• • 200.335


Electronic, open, machine readable information is preferable to paper

(with appropriate internal controls to safeguard alteration of records)

• Can substitute electronic versions for original paper provided certain conditions

Required Certifications

• 200.415


Must certify on annual and fiscal reports or vouchers requesting payment:

“By signing this report, I certify to the best of my knowledge and belief that the report is true, complete and accurate and expenditures, disbursements and cash receipts are for the purpose and objectives set forth in the terms and conditions of the federal award. I am aware that any false, fictitious or fraudulent information or the omission of any material fact, may subject me to criminal civil or administrative penalties for fraud, false statements, false claims or otherwise”


• • 200.305

Interest Earned on Federal Funds paid annually (rather than promptly) • Interest Bearing account increased to $500 for administrative purposes

• 200.339


Can Terminate Award

– Non compliance – For Cause – With Consent

Direct Cost

• • 200.413

Clarifies the circumstances where Administrative Support cost may be treated as direct cost

Compensation & Payroll


High standards of internal control over salaries and wages

Allowable -vs- Non-Allowable Cost


: 200.421 Advertising and Public Relations are allowable exceptions to the otherwise unallowable cost • 200.460 Proposal Cost are allowable



Develop a checklist of Allowable and Unallowable Cost for each grant file

Internal Controls

• • 200.303

Must safeguard and protect personally identifiable or sensitive information

Source Documents for Best Practices:

1. The Green Book 2. “Internal Control Framework” by COSO 3. Appendix XI, Compliance Supplement

Mandatory Disclosure

• 200.112: Awarding Agency


establish Conflict of Interest policy and Non Federal entity


disclose any potential Conflicts of Interest • 200.113:


disclose in a timely manner and in writing


violations of criminal law involving fraud, bribery or gratuity violations

Appendix II: Contract Provisions


All contracts must contain provision covering the guidance, statues and regulations provided in this appendix

(11 areas) * Legal remedies when contractors violate or breach * Termination for cause or convenience * EEO * Rights to Inventors Made under Contract * Byrd Anti-Lobbying Amendment

Contract Administration

• • 200.318


maintain oversight to ensure contractors perform in accordance with terms, conditions and specifications of the contract

Prior Approval

• • 200.407


for the following circumstances: Change in principal investigator, project leader, partner or scope of effort Unrecovered indirect cost Additions to program income or use of program income to meet cost sharing or match Changes in project scope/objective, key person specified in award (non-construction award) Transfer of participant support cost to other expense categories Transfer or subcontract of work under the award

Auditor Selection

Peer Review is now a factor in selecting an auditor

• •


Add requirement to upcoming RFPs Request periodic Peer Review results

Single Audit

• 200.512:


publish Single Audit Reports online at the Federal Audit Clearinghouse • •

Suggestion(s): Establish procedures/metrics Timely Single Audit submission Coordinated Audit Follow-Up

(e.g. using SF SAC categories to track findings)

Single Audit Report

• • 200.512

Auditor and auditees


ensure report do not include any Protected Personally Identifiable Information (PPII) •


sign statement that reports don’t include PPII and authorization to make reports publically available on a website.

Audit Resolution

• • 200.513

3 months to resolve findings • Federal Agency will appoint a Senior Accountable Official for oversight of Single Audit

Audit Findings

• • 200.516


identify audit findings as repeat (from prior audit) with reference to the audit finding number

Suggestion: Internally track audit findings

Close Out

• • 200.343


Final reports due 90 days from end of period of performance • Close Out period extended to one year

[email protected]

(813) 276-3388 If nothing ever changes, there’d be no butterflies ~ Author Unknown