Transcript Document

OMB Update, Including
Grant Reform
NSAA Annual Conference Wednesday, June 11, 2014
Saint Paul, Minnesota
Tammie S. Brown CPA, CFE
DHHS/OIG/OAS
OMB - Compliance requirements
reduction project
• Least Critical Elements
• Real Property Acquisition
and Relocation Assistance
• Davis-Bacon Act
• Equipment and Real
Property Management
• OMB Working Groups
• Group 1(Cost Principles)
•
•
Activities Allowed or Unallowed
Allowable Costs/Cost Principles (2 CFR part 225/OMB
Circular A-87; 2 CFR part 200/OMB Circular A-21;
2CFR part 230/OMB Circular A-122)
• Group 2 (Administrative Requirements)
•
•
•
•
•
•
•
Cash Management
Equipment and Real Property Management
Period of Availability of Federal Funds
Procurement and Suspension and Debarment
Program Income
Reporting
Subrecipient Monitoring
• Group 3 (Other)
•
•
•
•
•
Davis-Bacon Act
Eligibility
Matching, Level of Effort, Earmarking
Real Property Acquisition & Relocations Assistance
Special Tests and Provisions
Data Collection Form Problems
Part 200
• Limited search functions
• Unreliable information
• Disappearing audits
Page
3
Medicaid Compliance
Supplement
• MAGI eligibility pilots in Lieu of MEQC and PERM testing
• Many States will still be testing internal controls
• CMS will still be addressing findings from the pilots and any
other audits related to MAGI eligibility
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4
Code of Federal Regulations (CFR)
Title 2: Grants and Agreements
Subtitle A—OFFICE OF MANAGEMENT AND
BUDGET GUIDANCE FOR GRANTS AND
AGREEMENTS
CHAPTER II—OFFICE OF MANAGEMENT AND
BUDGET GUIDANCE
PART 200—UNIFORM ADMINISTRATIVE
REQUIREMENTS, COST PRINCIPLES, AND AUDIT
REQUIREMENTS FOR FEDERAL AWARDS
SUBPARTS A-F
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Creating Part 200 “Part 200”
Administrative Requirements
Cost Principles
Audit Requirements
Page
6
Six Subparts to Part 200
ABCDEF
• A—Acronyms and Definitions
• B—General Provisions
• C—Pre-Federal Award Requirements and Contents of Federal
Awards
• D—Post Federal Award Requirements
• E—Cost Principles
• F—Audit Requirements
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7
Part 200
Must vs. Should/AICPA vs. Part 200
must
AICPA
Part 200
unconditional
requirement
indicates
requirements
presumptively mandatory
requirement
indicates
best practices or
recommended
approaches
should
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8
Part 200
Q III-5: The word “should” is used
throughout section 200. Does it
really mean “must”?
No. The word “must” is used throughout section 200 to indicate
requirements. The word “should” is used to indicate best practices or
recommended approaches that the COFAR wanted non-Federal
entities to be aware of, but not necessarily required to comply with.
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9
Part 200
Should by any other Name
Best Practice
Part 200
Presumptively Mandatory
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10
§200.303 Internal controls.
The non-Federal entity must:
(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” issued by the Comptroller General of the
United States and the “Internal Control Integrated Framework”, issued by the Committee
of Sponsoring Organizations of the Treadway Commission (COSO).
(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 or the non-Federal entity considers sensitive consistent with applicable Federal,
state and local laws regarding privacy and obligations of confidentiality
Part 200
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11
Subpart A—Acronyms and
Definitions
• Internal controls vs. Internal control over
compliance requirements for Federal awards
• Subrecipient vs. Recipient (only direct)
• Subaward vs. Federal Award (direct or from
pass-through)
• PPII – Protected Personally Identifiable
Information
Part 200
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12
Subpart A—Acronyms and
Definitions
§200.82 Protected Personally Identifiable Information (Protected
PII).
Protected PII means an individual's first name or first initial and last
name in combination with any one or more of types of information,
including, but not limited to, social security number, passport
number, credit card numbers, clearances, bank numbers,
biometrics, date and place of birth, mother's maiden name,
criminal, medical and financial records, educational transcripts. This
does not include PII that is required by law to be disclosed. (See
also §200.79 Personally Identifiable Information (PII)).
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13
Part 200
Subpart B—General Provisions
•
•
•
•
•
•
•
•
•
•
•
•
•
•
§200.100
§200.101
§200.102
§200.103
§200.104
§200.105
§200.106
§200.107
§200.108
§200.109
§200.110
§200.111
§200.112
§200.113
Purpose.
Applicability.
Exceptions.
Authorities.
Supersession.
Effect on other issuances.
Agency implementation.
OMB responsibilities.
Inquiries.
Review date.
Effective/applicability date.
English language.
Conflict of interest.
Mandatory disclosures.
Part 200
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Subpart B—General Provisions
§200.100 Purpose
• Establishes uniform administrative
requirements, cost principles, and audit
requirements
• Federal awarding agencies must not impose
additional or inconsistent requirements
• Unless specifically required by Federal
statute, regulation, or Executive Order
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15
Part 200
Subpart B—General Provisions
§200.102 Exceptions
• OMB may allow exceptions
• Will be published on the OMB Web site
• Will be permitted only in unusual
circumstances
• No case-by-case exceptions Subpart F—
Audit Requirements
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16
Part 200
Subpart B—General Provisions
§200.110 Effective/applicability date
•
•
•
•
•
•
•
•
•
•
December 2013 – Final Guidance
12 mo.
December 2014 – Federal Agency Regulations
6 mo.
June 2015 – Start First Full Fiscal Year Under new Regs.
12 mo.
July 2016 – First Full Fiscal Year Ends
8 mo.
February 2014 – Issue first Single Audit under new requirements Page
17
No early implementation of Audit Requirements
Part 200
Subpart C—Pre-Federal Award
Requirements and Contents of
Federal Awards
§200.200 -§200.211
•
•
•
•
•
•
•
•
•
•
•
•
Purpose.
Use of grant agreements (including fixed amount awards), cooperative agreements, and
contracts.
Requirement to provide public notice of Federal financial assistance programs.
Notices of funding opportunities.
Federal awarding agency review of merit of proposals.
Federal awarding agency review of risk posed by applicants.
Standard application requirements.
Specific conditions.
Certifications and representations.
Pre-award costs.
Information contained in a Federal award.
Public access to Federal award information.
Part 200
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18
Subpart D—Post Federal Award
Requirements
§200.300 -§200.345
•
•
•
•
•
•
•
•
•
§200.303 Internal controls.
Standards for Financial and Program Management
Property Standards
Procurement Standards
Performance and Financial Monitoring and Reporting
200.331Requirements for pass-through entities
Subrecipient Monitoring and Management
Record Retention and Access
Closeout
Post-Closeout Adjustments and Continuing Responsibilities
Collection of Amounts Due
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19
Part 200
§200.330 Subrecipient and
contractor determinations.
(a) Subrecipients.
• 1) Determines eligibility;
• (2) Federal program objectives;
• (3) Responsibility for programmatic decision
making;
• (4) Complies with program requirements; and
• (5) carry out a program for a public purpose, as
opposed to providing goods or services for the
benefit of the pass-through entity
Part 200
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20
§200.330 Subrecipient and
contractor determinations.
b) Contractors.
• (1) Provides the goods and services within normal business
operations;
• (2) Provides similar goods or services to many different
purchasers;
• (3) Normally operates in a competitive environment;
• (4) Provides goods or services that are ancillary to the
operation of the Federal program; and
• (5) Is not subject to compliance requirements of the
Federal program as a result of the agreement, though
similar requirements may apply for other reasons.
Part 200
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21
§200.330 Subrecipient and
contractor determinations.
c) Use of judgment in making determination. In determining
whether an agreement between a pass-through entity and
another non-Federal entity casts the latter as a subrecipient
or a contractor, the substance of the relationship is more
important than the form of the agreement. All of the
characteristics listed above may not be present in all cases,
and the pass-through entity must use judgment in classifying
each agreement as a subaward or a procurement contract.
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22
Part 200
§200.331 Requirements for passthrough entities
• MUST:
– (4) An approved federally recognized indirect cost rate negotiated between the subrecipient
and the Federal government or, if no such rate exists, either a rate negotiated between the
pass-through entity and the subrecipient (in compliance with this part), or a de minimis
indirect cost rate as defined in §200.414 Indirect (F&A) costs, paragraph (b) of this part.
What if you have an
existing rate of 7%?
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23
Part 200
§200.331Requirements for passthrough entities
•
Must:
– (b) Evaluate each subrecipient's risk of noncompliance with Federal
statutes, regulations, and the terms and conditions of the subaward for
purposes of determining the appropriate subrecipient monitoring
described in paragraph (e) of this section, which may include
consideration of such factors as:
• (1) The subrecipient's prior experience with the same or similar subawards;
• (2) The results of previous audits including whether or not the subrecipient
receives a Single Audit in accordance with Subpart F—Audit Requirements of
this part, and the extent to which the same or similar subaward has been
audited as a major program;
• (3) Whether the subrecipient has new personnel or new or substantially
changed systems; and
• (4) The extent and results of Federal awarding agency monitoring (e.g., if thePage
subrecipient also receives Federal awards directly from a Federal awarding24
agency).
Part 200
§200.331Requirements for passthrough entities
•
•
•
•
•
Must:
(d) Monitor the activities of the subrecipient as necessary to ensure that the subaward
is used for authorized purposes, in compliance with Federal statutes, regulations, and
the terms and conditions of the subaward; and that subaward performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include:
(1) Reviewing financial and programmatic reports required by the pass-through entity.
(2) Following-up and ensuring that the subrecipient takes timely and appropriate
action on all deficiencies pertaining to the Federal award provided to the subrecipient
from the pass-through entity detected through audits, on-site reviews, and other
means.
(3) Issuing a management decision for audit findings pertaining to the Federal award
provided to the subrecipient from the pass-through entity as required by §200.521
Management decision.
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25
Part 200
§200.331Requirements for passthrough entities
•
(e) Depending upon the pass-through entity's assessment of risk posed by the
subrecipient (as described in paragraph (b) of this section), the following monitoring
tools may be useful for the pass-through entity to ensure proper accountability and
compliance with program requirements and achievement of performance goals:
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26
Part 200
§200.331Requirements for passthrough entities
•
•
•
•
•
•
(1) Providing subrecipients with training and technical assistance on program-related
matters; and
(2) Performing on-site reviews of the subrecipient's program operations;
(3) Arranging for agreed-upon-procedures engagements as described in §200.425
Audit services.
(f) Verify that every subrecipient is audited as required by Subpart F—Audit
Requirements of this part when it is expected that the subrecipient's Federal awards
expended during the respective fiscal year equaled or exceeded the threshold set forth
in §200.501 Audit requirements.
(g) Consider whether the results of the subrecipient's audits, on-site reviews, or other
monitoring indicate conditions that necessitate adjustments to the pass-through
entity's own records.
(h) Consider taking enforcement action against noncompliant subrecipients as
described in §200.338 Remedies for noncompliance of this part and in program
regulations.
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27
Part 200
§200.338 Remedies for
noncompliance
• (a) Temporarily withhold cash payments pending correction of the deficiency
by the non-Federal entity or more severe enforcement action by the Federal
awarding agency or pass-through entity.
• (b) Disallow (that is, deny both use of funds and any applicable matching
credit for) all or part of the cost of the activity or action not in compliance.
• (c) Wholly or partly suspend or terminate the Federal award.
• (d) Initiate suspension or debarment proceedings as authorized under 2 CFR
part 180 and Federal awarding agency regulations (or in the case of a passthrough entity, recommend such a proceeding be initiated by a Federal
awarding agency).
• (e) Withhold further Federal awards for the project or program.
• (f) Take other remedies that may be legally available.
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Part 200
Subpart E—Cost Principles
§200.400 -§200.475
•
•
•
•
General Provisions
Basic Considerations
Direct and Indirect (F&A) Costs
Special Considerations for States, Local Governments and
Indian Tribes
• Special Considerations for Institutions of Higher Education
• General Provisions for Selected Items of Cost
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29
Part 200
Subpart F—Audit Requirements
§200.500 -§200.521
• General
• Audits
• Auditees
• Auditors
• Management Decisions
Part 200
Page
30
CA
NY
OH
PA
TX
IL
MI
FL
MA
NJ
MN
MO
WI
WA
NC
IN
GA
VA
KY
LA
OK
TN
AL
AZ
IA
AR
OR
MD
CO
MS
SC
CT
DC
KS
WV
NE
ME
NM
MT
AK
PR
VT
SD
NH
UT
ID
RI
ND
NV
HI
WY
DE
VI
GU
MP
FM
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
1458
1347
1035 Audits
1830
1663
2380
2357
2335
2832
3818
NUMBER OF SINGLE AUDITS BY STATE
Total
Part 200
Page
31
NY
CA
TX
PA
FL
IL
OH
NC
MI
MA
NJ
TN
GA
MO
WA
VA
MD
LA
AZ
IN
WI
MN
CO
KY
OR
AL
SC
DC
OK
IA
CT
MS
AR
NM
PR
UT
KS
WV
ND
NV
RI
ID
ME
NE
NH
AK
VT
HI
SD
DE
WY
MT
GU
VI
MP
FM
$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
23.8
$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
Billion
$101,373,205,414
$98,777,195,641
$138,400,762,620
$134,670,138,495
TOTAL DOLLARS COVERED BY SINGLE AUDITS FOR EACH STATE
Total
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32
Part 200
Subpart F—Audit Requirements
§200.501 Audit Requirements
• $750,000
• $500,000
Page
33
Part 200
CA
NY
OH
PA
TX
IL
MI
FL
MA
MN
NJ
WA
NC
MO
WI
IN
GA
VA
LA
KY
AL
AZ
TN
OK
AR
OR
MD
IA
CO
SC
MS
CT
DC
KS
NM
WV
ME
NE
PR
MT
AK
SD
VT
UT
NH
ID
RI
ND
NV
HI
WY
DE
VI
GU
MP
FM
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%
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%
Audit Coverage
Over
Under
Part 200
Page
34
NY
CA
TX
PA
FL
IL
OH
NC
MA
MI
NJ
TN
GA
MO
WA
VA
MD
LA
AZ
IN
WI
MN
CO
KY
OR
AL
SC
DC
OK
IA
CT
MS
AR
NM
PR
UT
KS
WV
ND
NV
RI
ID
ME
NE
NH
AK
VT
HI
SD
DE
WY
MT
GU
VI
MP
FM
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%
.47% loss
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%
Dollars Covered
Over
Under
Part 200
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35
Subpart F—Audit Requirements
§200.502 Basis for determining Federal awards expended
• The determination of when a Federal award is
expended should be based on when the activity
related to the Federal award occurs.
• Generally, the activity pertains to events that
require the non-Federal entity to comply with
Federal statutes, regulations, and the terms and
conditions of Federal awards
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36
Part 200
Subpart F—Audit Requirements
§200.503 (a)-(e) Relation to other audit requirements
a) Federal agency must rely
b) Others can do non-duplicate audits – Must Review
FAC for recent audits
c) Does not limit authority of others
d) Federal agency to pay for additional audits.
e) Request major program, 180 days
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Part 200
Subpart F—Audit Requirements
§200.504 - §200.507
•
•
•
•
§200.504
§200.505
§200.506
§200.507
Frequency of audits.
Sanctions.
Audit costs. (See §200.425)
Program-specific audits.
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Part 200
Subpart F—Audit Requirements
§200.508 (a)-(d) Auditee responsibilities.
a) Arrange audit, and ensure properly
performed and submitted
b) Prepare F/S and SEFA
c) Take corrective action to findings, prepare
schedule of PY findings and CY corrective
action plan
d) Provide auditors access…to everything!
Part 200
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Subpart F—Audit Requirements
§200.509 (a)-(c) Auditor selection.
1. Audit procurement
A.
B.
No State auditor carve out???
Maybe 200.508(a) “procure or otherwise arrange”
a)
b)
200.17 a state “must” follow the same policies and procedures it uses for
procurements of non-Federal Funds.
200.319 procurement contracts “must” be conducted in a manner providing full
and open competition…
2. Restricts auditor from preparing indirect cost
proposals >$1M
3. Use of Federal auditors
Part 200
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Subpart F—Audit Requirements
§200.510 (a)-(b) Financial Statements.
a) Financial statements - GAAP
b) Schedule of expenditures of Federal awards
(SEFA)
(2) For Federal awards received as a subrecipient,
the name of the pass-through entity and identifying
number assigned by the pass-through entity must
be included.
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41
Part 200
Subpart F—Audit Requirements
§200. 510 (b)(4) Financial Statements.
(5) To the extent
practical, pass-through
entities should identify
in the schedule the total
amount provided to
subrecipients from each
Federal program.
(4) Include the
total amount
provided to
subrecipients from
each Federal
program.
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42
Part 200
Subpart F—Audit Requirements
§200.511 Audit findings follow-up.
a) Make list, number findings, include fiscal
year
b) Summary schedule of prior audit findings,
list a finding until it is listed as “resolved” for
one year
c) Corrective action plan, in a document
separate from the auditor's findings
Part 200
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43
Subpart F—Audit Requirements
§200.512. Report submission (b)(1)&(2)
A senior level representative of the auditee
must sign a statement…that says…the reporting
package does not include protected personally
identifiable information,
…and that the FAC is authorized to make the
reporting package and the form publicly
available on a Web site.
(2) Exception for Indian Tribes
Part 200
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44
Subpart
F—Audit
Requirements
§200.512. Report submission
(g) FAC responsibilities.
The FAC must make available the reporting
packages…to the public…and follow up with
known auditees that have not submitted the
required data collection forms and reporting
packages.
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45
Part 200
Subpart
F—Audit
Requirements
§200.512. Report submission
(b) Data Collection.
The FAC is the repository
of record for...Audits… All
Federal agencies, passthrough
entities
and
others interested in a
reporting package and
data collection form must
obtain it by accessing the
FAC.
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Part 200
Federal Agencies §200.513
Responsibilities
The cognizant agency for audit must:
(ii) Obtain or conduct quality control reviews on
selected audits made by non-Federal auditors,
and provide the results to other interested
organizations.
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Part 200
Federal Agencies §200.513
Responsibilities
…audit quality project must be performed once
every 6 years beginning in 2018 or at such other
interval as determined by OMB, and the results
must be public.
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Part 200
Federal Agencies §200.513
Responsibilities
(b)(3)(iv) Develop a baseline, metrics, and
targets to track, over time, the effectiveness of
the Federal agency's process to follow-up on
audit findings
and on the effectiveness of Single Audits in
improving non-Federal entity accountability and
their use by Federal awarding agencies in
Page
making award decisions.
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Part 200
New Federal Management
• Single Audit Accountable Official
• Senior policy official
• Appoints KMSAL
• Key Management Single Audit Liaison
• Day to Day Operations of Single Audit
• NOT OIG Single Audit Coordinator
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Part 200
Federal Agencies §200.513
Responsibilities
(6) Key management single audit liaison must:
(i) point of contact for the single audit…within
and outside the Federal government.
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Part 200
Auditors§200.514-(c) Internal
control.
(1) The compliance supplement provides guidance on
internal controls over Federal programs based upon
the guidance in Standards for Internal Control in the
Federal Government issued by the Comptroller
General of the United States and the Internal Control –
Integrated Framework, issued by the Committee of
Sponsoring Organizations of the Treadway Commission
(COSO).
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Part 200
Auditors§200.515 Audit Reporting.
The dollar threshold used to distinguish between Type
A and Type B programs, as described in § 200.518
Major program determination paragraph (b)(1), or
(b)(3) when a recalculation of the Type A threshold is
required for large loan or loan guarantees;
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Part 200
Auditors§200.516 Audit Findings.
Old, report questioned cost over $10,000
(a)(3)&(4) Report questioned cost over $25,000
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Part 200
Auditors§200.516 Audit Findings.
(b) Audit finding detail and clarity.
(4) A statement of cause that identifies the reason or
explanation for the condition or the factors
responsible for the difference between the situation
that exists (condition) and the required or desired
state (criteria), which may also serve as a basis for
recommendations for corrective action.
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Part 200
Auditors§200.516 Audit Findings.
(5) The possible asserted effect to provide sufficient
information to the auditee and Federal agency, or
pass-through entity in the case of a subrecipient, to
permit them to determine the cause and effect to
facilitate prompt and proper corrective action. A
statement of the effect or potential effect should
provide a clear, logical link to establish the impact or
potential impact of the difference between the
condition and the criteria.
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Part 200
Auditors§200.516 Audit Findings.
(7)…The auditor should report whether the sampling
was a statistically valid sample.
(8) Identification of whether the audit finding was a
repeat of a finding in the immediately prior audit and if
so any applicable prior year audit finding numbers.
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Part 200
Auditors§200.517 Audit
Documentation.
• Same, keep for 3 years
• Same, let the feds see them, does not say anything
about pass-throughs?
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Part 200
Auditors§200.518 Major program
determination
Low risk Type A
No audit findings
Questioned costs >$10k
Type B, 1 for 1 low-risk Type A
Type B floor, various %’s, VA
$4M
Low Risk Auditee 25%
High Risk Auditee 50%
Low risk Type A
Material weaknesses
Questioned costs >5%
Type B, 1/4 low-risk Type A
Type B Floor, 25% of Type A
threshold
Low Risk Auditee 20%
High Risk Auditee 40%
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Part 200
Auditors§200.519-§200.520
• §200.519 Criteria for Federal program risk.
• §200.520 Criteria for a low-risk auditee.
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Part 200
Auditors§200.521 Management
decision.
While not required, the Federal agency or
pass-through entity may also issue a
management decision on findings relating to
the financial statements which are required
to be reported in accordance with GAGAS.
The Federal awarding agency or passthrough entity responsible for issuing a
management decision must do so within six
months of acceptance of the audit report by
the FAC.
Part 200
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Appendixes
I—Full Text of Notice of Funding Opportunity
II—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards
III—Indirect (F&A) Costs Identification and Assignment, and Rate Determination for Institutions of
Higher Education (IHEs)
IV—Indirect (F&A) Costs Identification and Assignment, and Rate Determination for Nonprofit
Organizations
V—State/Local Government and Indian Tribe-Wide Central Service Cost Allocation Plans
VI—Public Assistance Cost Allocation Plans
VII—States and Local Government and Indian Tribe Indirect Cost Proposals
VIII—Nonprofit Organizations Exempted From Subpart E—Cost Principles of Part 200
IX—Hospital Cost Principles
X—Data Collection Form (Form SF-SAC)
XI—Compliance Supplement
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Part 200
Tammie S. Brown, CPA, CFE
• [email protected]
Part 200
• Questions?
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