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U.S. Department of Homeland Security Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Super Circular). Presented by: Andrea Brandon, Director Financial Assistance Policy and Oversight December 2, 2014. Super Circular Objectives.
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U.S. Department of Homeland Security Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards(Super Circular) Presented by: Andrea Brandon, Director Financial Assistance Policy and Oversight December 2, 2014 Procurement Sensitive – For Official Use Only
Super Circular Objectives Super Circular Objectives • Eliminate duplicative and conflicting guidance • Focus on performance over compliance for accountability • Encourage efficient use of information technology and shared services • Provide consistent and transparent treatment of costs
Super Circular Objectives Super Circular Objectives, cont’d • Encourage non-Federal entities to have family-friendly policies • Strengthen oversight • Target audit requirements on risk of waste, fraud, and abuse
Super Circular Logistics • Combines Circulars A-21, A-50, A-87, A-89, A-102, A-110, A-122. and A-133 • Can be found at 2 CFR 200 • Will take effect December 26, 2014 • Requires that awarding agencies adopt the circular and issue a regulation by the December, 2014 date
DHS Activities on the Super Circular • Developed in-depth analysis of operational changes in the new circular • Has been submitted to the Council of Heads of Financial Assistance Activities (CHFAA) for review and comment • Is available to DHS financial assistance operational staff on the DHS Connect SharePoint site.
DHS Activities on the Super Circular • Prepare a DHS FAQ to assist financial assistance Component operational staff • DHS-wide webcasts to keep the Components informed • Continue to update analysis of the Super Circular based on feedback from the Components
DHS Activities on the Super Circular • Develop DHS performance metrics for outcome related requirements specified in the new guidance • Determine new risk areas and control points as they relate to the new guidance. • A-123 Internal Control Guidance on various points of the grants management process
Some Key Changes found in the Super Circular • Streamlines salaries and wages reporting requirements for grantees • Internal controls for grant recipient reporting • Updates policies on direct vs. indirect cost • Creates a de minimis 10% indirect cost rate for grantees without a negotiated rate • Cost sharing only allowed by program statute or publically announced by the head of the agency • Cost sharing criteria cannot be considered in the peer review process • Clarification of allowable and unallowable costs for entertainment, employee morale, participant incentives, etc. • More rigorous pre-award fiscal analysis of applicants • Single Audit threshold raised to $750,000 • Single Audits publically available for review on the Federal Audit Clearinghouse (FAC)
Questions: • Is this only related to OMB circulars or does it also make changes to the CFR or other guidance, rules and regulations? • Highlight the differences between the Super Circular and the 44 CFR. • What kind of recipient does the Super Circular Apply to? • What is the date that it becomes applicable to grantees? • What is FEMA doing to prepare for the Implementation? • How will FEMA assist the states in this transition? • Will there be changes for sub recipients as well?
Super Circular Questions? Contact: Andrea Brandon 202-447-0675 Andrea Brandon@hq.dhs.gov