Transcript GEORGIA DEPARTMENT OF AUDITS AND ACCOUNTS

GEORGIA DEPARTMENT OF
AUDITS AND ACCOUNTS
Uniform Guidance:
What you need to know
Department of Natural Resources
March 12, 2015
Uniform Guidance
Superseded OMB Circulars:
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A-21 – Cost Principles for Educational Institutions
A-50 – Single Audit Act Follow-up
A-87 – Cost Principles for State, Local, and Indian Tribal Governments
A-89 – Catalog of Federal Domestic Assistance
A-102 – Grants and Cooperative Agreements with State and Local
Governments
A-110 – Uniform Administrative Requirements for Grants and Other
Agreements with Institutions of Higher Education, Hospitals, and Other
Nonprofit Organizations
A-122 – Cost Principles for Non-Profit Organizations
A-133- Audits of States, Local Governments and Non-Profit Organizations
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Uniform Guidance
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Eight different OMB guidance streamlined into one. Eliminating overlapping
duplicative and conflicting guidance.
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A-21
A-50
A-87
A-89
A-102
A-110
A-122
A-133
2 CFR Part 200
UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES,
AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS
(Uniform Guidance)
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Uniform Guidance
 Intended Outcomes
• Reduce administrative burden for non-Federal
entities
• Reduce the risk of waste, fraud and abuse
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Effective Dates section 200.110
December 26, 2014

Uniform Guidance is effective for all Federal awards and
for additional funding to existing awards (funding
increments) made on or after this date.

Procurement requirements - The Federal Government
will provide non-Federal entities a grace period for one
full fiscal year after the effective date of the Uniform
Guidance with certain requirements. (FAQ .110-6)
 Beginning FY 2017 Full Compliance with Procurement
Requirements
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Effective Dates section 200.110
December 26, 2014 through June 30, 2015
 Non-federal entities must adopt new
administrative requirements and cost principles
for all new Federal awards and funding
increments to existing awards.
• Auditor compliance testing will be effected if an entity
has new awards or funding increments made on or
after the effective date of the guidance
• Read and understand the terms and conditions of your
Federal award (FAQ .110-6)
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Effective Dates section 200.110
Fiscal year-end June 30, 2016 and beyond
 New single audit requirements will apply
 Auditors may have to continue testing some
awards under the “old” regulations and some
under the Uniform Guidance
 Testing under the “old” regulations and “new”
guidance may continue for several years
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Effective Dates section 200.110
Fiscal year-end June 30, 2017
 Non-federal entities who chose to take
advantage of the one full fiscal year grace period
must comply with procurement requirements
under the uniform guidance.
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Effective Dates – Old or New?
Assumes June 30, 2015, Year-end
 Scenario 1
• Entity expended funds from a new federal award, which was
awarded in early December.
 Scenario 2
• Entity expended funds from three new federal awards –
These were awarded in July 2014, October 2014 and
November 2014.
• In February 2015, the cognizant agency provided
incremental funding to the November 2014 federal award
and noted the uniform guidance applied.
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Effective Dates – Old or New?
Assumes June 30, 2015, Year-end
 Scenario 1
• Funding for the federal award received in early
December is subject to the “old” regulations.
 Scenario 2
• Funding for the ‘original’ July 2014, October 2014 and
November 2014 federal awards subject to the “old”
regulations .
• Incremental funding to the November 2014 federal
award is subject to the uniform guidance.
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2 CFR Part 200 (Uniform Guidance)
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Subpart A - contains acronyms and definitions used throughout the Guidance
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Subpart B - general provisions including the purpose of the Guidance, its applicability, and
effective date
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Subpart C - administrative requirements directed primarily at federal agencies including preaward activities and requirements for the contents of federal awards
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Subpart D –property, procurement, internal control, and subrecipient monitoring
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Subpart E - Cost Principles previously found in Circulars A-21, A-87, and A-122
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Subpart F – Audit Requirements
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Appendices I through XI – cost principles, Appendix X - data collection form, Appendix XI compliance supplement
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What you need to know – Subpart A
 Key Acronyms and Definitions

Use of “SHOULD” and “MUST”.
• Should = best practice or recommended approach.
• Must = required
• OMB has identified all SHOULDs and MUSTs in the “interim final rule” published on
December 19, 2014
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Contractor will be used instead of “vendor”.
• These terms have the same meaning

Personally Identifiable Information (PII) and Protected Personally Identifiable
Information (PPII).
• Definitions can be found in sections 200.79 (PII) and 200.82 (PPII)
• Auditors and auditees must ensure that no protected personally identifiable
information is included in their respective parts of the reporting package
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What you need to know – Subpart A
 Improper Payments 200.53
 Payment should not have been made
 Payment for incorrect amount
 Improper payments
•
•
•
•
•
Ineligible party, goods or services
Goods or services not received
Duplicate
Does not account for credits or discounts
Lack of documentation
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What you need to know – Subpart B
 Conflict of Interest section 200.112
• Federal awarding agencies must establish conflict
of interest policies for federal awards. Nonfederal entities must disclose in writing to federal
awarding agency or pass-through any potential
conflict of interest.
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What you need to know – Subpart B
 Mandatory Disclosures section 200.113
•
•
Non-federal entity must disclose, in a timely manner,
in writing to federal awarding agency or passthrough all violations of federal criminal law
involving fraud, bribery, or gratuity violations
potentially affecting the federal award.
Failure to make required disclosures can result in any
of the remedies described in section 200.338. (e.g.
temporarily withhold cash payments, disallow,
wholly or partly suspend or terminate the Federal
award)
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What you need to know – Subpart D
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Internal Controls section 200.303

The uniform grant guidance defines internal control as a process that
provides reasonable assurance that the Non-Federal entity is managing the
Federal award in compliance with Federal statute, regulations and the terms
and conditions of the Federal award.
The non-Federal entity must establish and maintain effective internal
controls over the Federal award and also:
 Comply with Federal statutes, regulations, and the terms and conditions of the Federal
award
 Evaluate and monitor its compliance with statue, regulations and terms and conditions of
the Federal award
 Take prompt action when instances of noncompliance are identified including
noncompliance identified in audit findings
 Take reasonable measures to safeguard protected personally identifying information and
other sensitive information
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What you need to know – Subpart D
 Internal Controls section 200.303
 Source documents for Best Practices
• Standards for Internal Control In the Federal Government
(Green Book) – Recently updated, September 2014
• Committee on Sponsoring Organizations (COSO)
The COSO 1992 framework was superseded by the COSO 2013
framework on December 15, 2014
• Appendix XI to Part 200—Compliance Supplement
Will consider COSO in the 2015 update
Will consider both Green Book and COSO in the 2016 update
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What you need to know
 Internal Controls – State Requirements
 “Each State organization is responsible for
adopting an internal control framework that is
suitable for the type of services they provide.”
(SAO Accounting Procedures Manual – Section 5
Internal Controls)
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What you need to know
 Internal Controls – State Requirements
 “Each State organization has a responsibility to
assess their internal control system and use this
information to design, implement, and monitor
internal controls that are suitable for their
organization.” (SAO Accounting Procedures
Manual – Section 5 Internal Controls)
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What you need to know
 Internal Controls – State Requirements
 All State organizations should evaluate their
internal controls. Large State organizations with
complex operations should formally document
their controls…. (SAO Accounting Procedures
Manual – Section 5 Internal Controls Conclusion)
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What you need to know
 Internal Controls
 Determine an appropriate framework or review
existing framework based on your agency’s
needs. An internal control framework serves as a
way to:
 Effectively apply internal controls
 Identify and analyze risks
 Develop and manage responses to risks
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What you need to know
 Internal Control Components
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Internal control consists of five integrated components:
 Control environment: Tone at the top
 Risk assessment: Determining what could go wrong
 Control activities: Actual internal control policies and procedures that
are put in place
 Information and Communication: Set requirements, expectations and
responsibility for carrying out the internal control environment
 Monitoring: Process of ensuring that controls are operating effectively
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What you need to know
 Internal Controls Components
 An effective internal control environment
requires that all five components are:
 Placed in operation
 Effectively designed
 Operating as intended
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What you need to know
 Internal Controls - Why?
 An entity’s failure to implement effective internal
controls could result in noncompliance.
 Remedies for noncompliance (200.338) stipulates
Specific Conditions (200.207) or actions the Federal
agency or pass-through entity may take if a nonFederal entity fails to comply with Federal statutes,
regulations or the terms and conditions of the award
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What you need to know – Subpart D
 Procurement
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sections 200.317 through 200.326
Procurement standards are modeled after A-102
• State agencies will follow the same policies and procedures they use
for procurements from non-federal funds
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Five procurement methods
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Micro-purchases ( < $3,000)
Small purchases (> $3,000 and < $150,000)
Sealed bids (> $150,000)
Competitive proposals (> $150,000)
Noncompetitive purchases: special circumstances applicable to all purchase levels
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What you need to know – Subpart D
 Procurement
sections 200.317 through 200.326
 All procurement methods must comply with the
following standards:
Documented polices and procedures
Purchases are necessary
Full and open competition
Conflict of Interest policy
Proper documentation
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What you need to know – Subpart D
 Procurement - FAQ .110-6 Effective Dates and Grace Period
 The Federal Government will provide nonFederal entities (NFEs) a grace period for one full
fiscal year after the effective date of the Uniform
Guidance:
 NFEs must comply with terms and conditions of their Federal award
 NFEs must document whether in compliance with old or new standard
and must meet the documented standard
 The Single Audit Supplement will instruct auditors to review
procurement policies and procedures based on the documented
standard
 NFEs must comply fully with the uniform guidance beginning in fiscal
years 2017 and beyond
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What you need to know – Subpart D
 Procurement – Identified State Impact
 Geographical preferences
 The uniform guidance is clear that if utilizing federal
funds to procure goods/services the nonfederal entity
must conduct procurements in a manner that prohibits
the use of statutorily or administratively imposed state
or local geographical preferences (see supplementary
information in the 12/26/14 final guidance – 200.319)
 No other known impacts as of today
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What you need to know – Subpart D
Subrecipient Monitoring and Management
Requirements
 200.330 Subrecipient and Contractor
Determinations
 200.331 Requirements of Pass-Through
Entities
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What you need to know – Subpart D
 Subrecipient and Contractor Determinations
200.330
 (a) Subrecipients
 (b) Contractors
 (c) Use of Judgment
DNR must make case-by-case determinations whether
each agreement it makes for the disbursement of Federal
program funds casts the party receiving the funds in the
role of a subrecipient or a contractor. (In the new
guidance, contractor is used instead of vendor)
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What you need to know – Subpart D
(a) Subrecipients
 A subaward is for the purpose of carrying out a
portion of a Federal award and creates a Federal
assistance relationship with the subrecipient.
 Characteristics of a Subrecipient:
1.
2.
3.
4.
5.
Determines who is eligible to receive what Federal assistance
Has its performance measured in relation to whether objectives of a Federal
program were met
Has responsibility for programmatic decision making
Is responsible for adherence to applicable Federal program requirements
specified in the Federal award
In accordance with its agreement, uses the Federal funds to carry out a
program for a public purpose specified in authorizing statute, as opposed to
providing goods or services for the benefit of the pass-through entity
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What you need to know – Subpart D
(b) Contractors
 A contract is for the purpose of obtaining goods and
services for DNR’s own use and creates a
procurement relationship with the contractor.
 Characteristics of a Contractor:
1.
2.
3.
4.
5.
Provides the goods and services within normal business operations
Provides similar goods or services to many different purchasers
Normally operates in a competitive environment
Provides goods or services that are ancillary to the operation of the
Federal program
Is not subject to compliance requirements of the Federal program as
a result of the agreement, though similar requirements may apply
for other reasons
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What you need to know – Subpart D
(c) Use of Judgment
 In determining whether an agreement between a
pass-through entity (DNR) and another non-Federal
entity casts the latter as a subrecipient or 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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What you need to know – Subpart D
Requirements for Pass-Through Entities 200.331
 DNR MUST:
(a) Ensure that every subaward is clearly identified to the subrecipient as
a subaward and include all required information at the time of the
subaward
(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
(c) Consider imposing specific subaward conditions upon a subrecipient if
appropriate
(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 the subaward performance goals are achieved
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What you need to know – Subpart D
Requirements for Pass-Through Entities 200.331
 DNR MUST:
(e) Depending on DNR’s assessment of risk posed by the subrecipient,
determine which monitoring tools will be used to ensure proper
accountability and compliance with program requirements and
achievement of performance goals
(f) Verify that subrecipients who are expected to expend $750,000 or
more in Federal funds obtain the required audits
(g) Consider whether results of subrecipient monitoring procedures
necessitate adjustments to DNR’s records
(h) Consider taking enforcement action against noncompliant
subrecipients
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What you need to know – Subpart D
(a) Ensure that every subaward is clearly identified to the subrecipient as a
subaward and includes all required information at the time of the
subaward.
Required information includes:
(1) Federal Award Identification
(i)
(ii)
(iii)
(iv)
(v)
(vi)
(vii)
(viii)
(ix)
Subrecipient name (which must match the name associated with its unique
entity identifier (DUNS number)
Subrecipient’s unique entity identifier (DUNS number)
Federal Award Identification Number (FAIN)
Federal Award Date (see 200.39 for more information)
Subaward Period of Performance Start and End Date
Amount of Federal Funds Obligated by this action
Total Amount of Federal Funds Obligated to the subrecipient
Total Amount of the Federal Award
Federal award project description, as required to be responsive to the
Federal Funding Accountability and Transparency Act (FFATA)
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What you need to know – Subpart D
(a) Ensure that every subaward is clearly identified to the subrecipient as a
subaward and includes all required information at the time of the
subaward. (continued)
Required information includes:
(x) Name of Federal awarding agency, pass-through entity, and contact
information for awarding official
(xi) CFDA Number and Name; the pass-through entity must identify the dollar
amount made available under each Federal award and the CFDA number at
time of disbursement
(xii) Identification of whether the award is Research and Development (R&D)
(xiii) Indirect cost rate for the Federal award
(2) All requirements imposed by the pass-through entity on the subrecipient
so that the Federal award is used in accordance with Federal
statutes, regulations and the terms and conditions of the Federal award
(3) Any additional requirements that the pass-through entity imposes on the
subrecipient in order for the pass-through entity to meet its on
responsibility to the Federal awarding agency including identification
of any required financial and performance reports
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What you need to know – Subpart D
(a) Ensure that every subaward is clearly identified to the
subrecipient as a subaward and includes all required information
at the time of the subaward. (continued)
(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 or a de minimus indirect cost rate as defined in 200.414
(5) A requirement that the subrecipient permit the pass-through entity and
auditors to have access to the subrecipients records and financial
statements as necessary
(6) Appropriate terms and conditions concerning closeout of the subaward
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What you need to know – Subpart D
(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

The new Uniform Guidance give the following examples of factors that
may be considered in the evaluations.
(1) The subrecipient’s prior experience with the same or similar
subawards
(2) The results of previous audits of the subrecipient 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
(4) The extent and results of Federal awarding agency monitoring. For
example, if the subrecipient also receives Federal awards directly
from a Federal awarding agency
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What you need to know – Subpart D
(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. (continued)

Other possible considerations (not in the guidance).
(1) The size of the subaward (risk follows the expenditures)
(2) Subject to a single audit
(3) The complexity of the program
(4) Significant changes that could effect the Federal risk
(5) Newly formed organization
(6) Complaints against the subrecipient
(7) Timeliness of required reports within the past 12 months
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What you need to know – Subpart D
(c)
Consider imposing specific subaward conditions
upon a subrecipient if appropriate.
 See 200.207 Specific Conditions for details of what
these conditions might be
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What you need to know – Subpart D
(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 the subaward performance goals are achieved.

For ALL subrecipients, monitoring MUST include:
(1)Reviewing financial and performance reports required by
DNR
(2)Following-up and ensuring that the subrecipient takes
timely and appropriate action on all deficiencies 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 DNR as required by 200.521
Management decision
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What you need to know – Subpart D
(e) Depending on DNR’s assessment of risk posed by the
subrecipient, determine which monitoring tools will be used to
ensure proper accountability and compliance with program
requirements and achievement of performance goals.

These are monitoring options listed in the new guidance and
could be incorporated for the subrecipients that are deemed
to have higher risk through the risk assessment process:
(1)Providing subrecipients with training and technical
assistance on program-related matters
(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
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What you need to know – Subpart D
(f) Verify that subrecipients who are expected to expend $750,000 or
more in Federal funds obtain the required single audit.

The $500,000 threshold has been increased to $750,000 in the new guidance
(g) Consider whether results of subrecipient monitoring procedures
necessitate adjustments to DNR’s records.

Should any issues noted be reflected in DNR’s records?
(h) Consider taking enforcement action against noncompliant
subrecipients.

See 200.338 Remedies for noncompliance for further information
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What you can anticipate – Audit Requests
Good morning, I’m the auditor and I’m your friend.
(its okay to laugh, hiss, or boo at this slide)
 How to make the auditor happy….
 What will the auditor want?
 Documentation, documentation,
documentation…
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What you can anticipate – Audit Requests
The following items are likely to be asked for by
the auditor: (not all inclusive)

Listing of all subawards by Federal program (CFDA) made
during the current state fiscal year which includes the
amounts of the subawards.
•
Some agencies post all their subawards separately in a single
account or accounts in TeamWorks. If that is the case, then auditor
could pull population from TeamWorks. If DNR does not do this, the
auditor must rely on listings provided to us by DNR.
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What you can anticipate – Audit Requests
The following items are likely to be asked for by
the auditor: (not all inclusive)

Your program’s policies and procedures (plan) for
subrecipient monitoring.
•
This plan should include an understanding of the scope, frequency,
and timeliness of monitoring activities and the number, size, and
complexity of awards to subrecipients, including, as applicable, to
subawards to for-profit entities.
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What you can anticipate – Audit Requests
The following items are likely to be asked for by
the auditor: (not all inclusive)

Copies of selected subaward agreements and the
Contractor/Subrecipient determination worksheets.
•
We will check for all required information to be included in the
agreement/contract and verification of subrecipient determination.
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What you can anticipate – Audit Requests
The following items are likely to be asked for by
the auditor: (not all inclusive)

Current year risk assessments for the following subrecipients
and documentation of the during-the-award monitoring that
should correspond to the assessed risk as indicated in the
risk assessment document.
49
What you can anticipate – Audit Requests
The following items are likely to be asked for by
the auditor: (not all inclusive)

Documentation of corrective action for deficiencies noted in
during-the-award monitoring
50
What you can anticipate – Audit Requests
The following items are likely to be asked for by
the auditor: (not all inclusive)

We will request a list of subrecipients and review for
documentation that supports the following:
•
•
•
Required audits were completed for selected subrecipients
DNR issued management decisions on audit findings within six
months after receipt of the audit report
Subrecipients took appropriate and timely corrective action on all
audit findings.
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What you need to know – Subpart E
 Cost Principles – What is new and how is this
applicable to subrecipients?

Uniform Guidance clarifies that indirect costs are now
allowable.

Federal agencies are now required to accept and apply
the approved indirect cost rate as established by the
cognizant agency for the non-federal entity
(200.414(c)(1)).
• Two exceptions to not using the approved negotiated rate:
 When the rate is required by federal statute or regulation
 When awarding agency head has documented justification for applying
another rate
52
What you need to know – Subpart E
 Cost Principles – What is new?

OMB has authorized a new de minimis rate equivalent to 10
percent of the modified total direct costs (200.414(f)). This
rate does not apply if:
• The entity has received a negotiated indirect cost rate.
• The entity is a state public assistance agency in accordance with
Appendix VI to Part 200 (e.g. TANF, Medicaid)

The de minimis rate:
•
•
•
•
Can be used indefinitely or until an indirect cost rate is negotiated
Does not require review of actual costs
Must be applied consistently for all federal awards
Restricted from use if an entity’s direct federal funding is greater than
$35 million (appendix VII.D.1.b)
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What you need to know – Subpart E
 Cost Principles – What is new?
 Salaries of administrative and clerical staff should be
considered indirect costs unless they can be
considered direct costs (200.413).
 Salaries for administrative and clerical staff must
meet four conditions to be classified as direct costs:




Must be integral to a project or activity;
Individuals should be specifically identified with the activity;
Should be explicitly included in the budget; and
Costs should not be recovered as indirect costs.
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What you need to know – Subpart E
 Cost Principles – What is new?

Annual and fiscal reports or vouchers requesting payment
must include a certification by an official who is authorized to
legally bind the non-Federal entity. (200.415)
• Certification language has been strengthened to include specific
language acknowledging the statutory consequences of false
certifications
• Certification of cost allocation plan or indirect cost rate proposal is
required

Requirements for public assistance cost allocation plans can be
found at Appendix VI to Part 200 and Subpart E of 45 CFR Part
95.
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What you need to know – Subpart E
 Compensation (200.430)

Costs of compensation are allowable to the extent that
they satisfy the specific requirements of section 200.430
and that the total compensation for individual
employees:
 Is reasonable for the services rendered and conforms to the
established written policy of the non-Federal entity consistently
applied to both Federal and non-Federal activities;
 Follows an appointment made in accordance with a non-Federal
entity’s laws and/or rules or written policies and meets the
requirements of Federal statutes, were applicable; and
 Is determined and supported as provided in paragraph (1);
Standards for Documentation of Personnel Expenses, when
applicable. These standards are described below.
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What you need to know – Subpart E
 Compensation (200.430)

Standards for documentation of personnel expenses:
•
•
•
•
Must be based on records that accurately reflect the work performed
Be supported by a system of internal control
Be incorporated into the official records of the non-Federal entity
Reflect the total activity for which the employee is compensated not
exceeding 100% of compensated activities
• Encompass both federally assisted and all other activities
compensated by non-Federal entity
• Comply with the established accounting policies and practices of the
non-federal entity
• Support the distribution of the employee’s salary or wages among
specific activities or cost objectives if the employee works on more
than one Federal award
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What you need to know – Subpart E
 Compensation (200.430(i)(1)(x)(5)(i))
 Substitute processes or systems of allocating
salaries and wages to Federal awards may be
used in place of or in addition to the records
described above if approved by the cognizant
agency.
• Systems may include but are not limited to:




Random moment sampling
“rolling” time studies
Case counts; or
Quantifiable measures of work performed.
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What you need to know – Subpart E
 Compensation – Fringe Benefits (200.431)
 The cost of fringe benefits in the form of regular
compensation paid to employees during periods of
authorized absences from the job, such as for annual
leave … are allowable if all of the following criteria
are met:
• They are provided under established written leave policies;
• The costs are equitably allocated to all related activities,
including Federal awards; and,
• The accounting basis (cash or accrual) selected for costing
each type of leave is consistently followed by the nonFederal entity or specified grouping of employees.
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What you need to know – Subpart F
 Audit Requirements – What is new?

Nonfederal entities that expend $750,000 or more in
federal awards during the entity’s fiscal year must have a
single or program specific audit performed (200.501).

Nonfederal entities that expend less than $750,000 in
federal awards during the entity’s fiscal year are not
required to perform a single or program specific audit
(200.501).
 Some exceptions apply as noted in section 200.503
 Records must be available for review or audit
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What you need to know – Subpart F
 Audit Requirements – What is new?
 Audit Findings (200.516)
• Known and likely questioned costs have been increased from
$10,000 to those greater than $25,000
 Audit requirements under part 200 are applicable to
both recipients and subrecipients.
 Possible changes to the 2015 compliance
requirements.
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What you should do now
 Obtain an Understanding of the New
Requirements
• Office of Management and Budget - UNIFORM
ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES,
AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS.
http://www.whitehouse.gov/omb/grants_docs
• Council on Financial Assistance Reform (COFAR) Frequently Asked Questions (FAQs)
https://cfo.gov/cofar/
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What’s next
 “Interim Final Rule” was published on December 19, 2014
and all comments were due on February 17, 2015
 OMB is in the process of reviewing comments in
coordination with Federal awarding agencies
 Understand Effective Dates - December 26, 2014
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What you should do now
 Set Tone at the Top
 Develop a Plan to become Compliant
•
•
•
•
•
Determine Policy and Procedure Changes
Establish or Update Internal Controls
Establish Action Items and Item Owners
Establish a Training Program
Establish Deadlines
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