OMB Uniform Guidance 2014 Implementation at the University of Washington

Northwest Chapter of Internal Auditors August 5 th , 2014 Ted Mordhorst Asst. Dir. For Post Award Financial Compliance Research Accounting and Analysis University of Washington

OMB Uniform Guidance 2014

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Final Guidance document published in the Federal Register Dec 26, 2013.

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Codified in 2 CFR 200 Replaces 8 previous OMB Circulars:

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Circular A-110 Circular A-21

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Circular A-102 Circular A-87

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Circular A-89 Circular A-102

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Circular A-133 Circular A-50

OMB Uniform Guidance 2014

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Applicable to Direct Federal Grants, Cooperative Agreements and Cost-reimbursable contracts.

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Each federal awarding agency must implement Effective for new $ received on or after Dec. 26, 2014 Audit effective for the entities first full fiscal year after 12/26/14.

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Example: Entities fiscal year ends June 30

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th New audit requirements apply to fiscal year that ends June 30, 2016

University of Washington Approach

•  A Core Team has been assembled Sponsored by Mary Lidstrom, Vice Provost for Research and Susan Camber, Associate Vice President, Financial Management  The team has representatives from:  OR, OSP, GCA, MAA, School of Medicine, College of Arts and Sciences, Procurement Services, and Internal Audit, The AG office  Additional sub-teams have been formed to review some of the more complex areas.

University of Washington Presenter’s Office

Uniform Guidance Working Group

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The working groups compared the new regulation to the existing regulations in A-110, A-21 and A-133

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Identify changes

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Map changes to university policy and procedures

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Identifying possible changes to IT systems both central and in units

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Propose changes to policy, procedures necessary to maintain compliance

University of Washington Presenter’s Office

Uniform Guidance Working Group

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Develop internal Communication plan.

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Develop protocol for making changes to policies and procedures.

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Develop training for campus personnel.

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Modify existing training material for faculty and staff.

University of Washington Presenter’s Office

Uniform Guidance Working Group

 Timeline  APRIL 15 DISCOVERY (initial discovery of what changed complete)  MAY 15 DISCOVERY (impact to UW systems complete)  JUNE 01 DISCOVERY (map to UW policy & procedure complete)  JUNE 26 FEDERAL PLANS RELEASED (Federal agencies release their respective implementation plans)(Has not happened.)  SEPT 30 DRAFT OF CHANGES TO UW POLICY (comprehensively address & publish all changes to UW policy)  DEC 01 UW READY TO IMPLEMENT CHANGES (changes to UW policy & procedure approved & published)  DEC 26 FEDERAL IMPLEMENTATION BEGINS University of Washington Presenter’s Office

Uniform Guidance Working Group

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We established a web page for the team at:

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http://www.washington.edu/research/topics/uniform grant-guidance/

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Contains links to the Final Uniform Guidance document Links to other documents and presentations Continues to be updated as more information becomes available.

Uniform Guidance Working Group

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There are Open Issues…

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Agency deviations – how will these be policed?

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Conflict of Interest – agency plans are key

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Research Terms and Conditions – (FDP) a lot to do in little time

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Internal Controls – audit repercussions, if any?

Procurement – could be most significant new burden

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Subrecipient Monitoring – could be second most significant

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Closeouts – not a major change in the Uniform Guidance, but the pressure for timely closeouts has raised profile

Uniform Guidance Working Group

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Other Issues…

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The UW is working with the Council on Governmental Relations to obtain clarification from OMB on a number of areas:

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Conflict of Interest – Institutional or individual

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Program Income – Treatment of Royalties or other IP Income

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Equipment – “Conditional Title”

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Procurement – Small purchase threshold – required competition

Uniform Guidance Working Group

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Challenges:

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Conflicting Priorities for team members

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Differing interpretations

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OMB/COFAR slow response to questions

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Pending clarification issues

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Agency implementation plans not published

Uniform Guidance Working Group

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A lot of questions remain but some of the more visible changes will have little impact on our policy and procedure.

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Effort Certification – No change planned

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Direct Charging of Administrative & Clerical Salaries – Little or no change planned

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Electronic Records – Already moving to a paperless environment

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Subrecipient Monitoring – Just revamped our processes

Uniform Guidance Implementation University of Washington

 Questions?