OMB Uniform Guidance Training

1. OMB Uniform Guidance Training “Super-Circular” 2 CFR PART 200—UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS

2. Uniform Guidance Presentation April 28, 2016 Uniform Guidance is a combined, simplified, version of 8 circulars.

3. Presentation by Sunny Colombe, Chief Administrative Officer, Great Plains Tribal Chairmen’s Health Board Date: 04/28/2016 Uniform guidance

4. Grant Regulations 1 2 3 4 5 Section The 5 W’s: Who, What, Where, When, Why Section Speak Clearly: Terminology Section Raising the Bar: Thresholds and Limits Section It Takes a Village: New Family-friendly Policies Section Truth and Consequences: Audit Transparency and Remedies

5. 5 Ws 1 Who is COFAR? What is the Super-Circular? Where are the old circulars? When was the effective date Why where the regulations changed? Section The 5 W’s : Who, What, Where, When, Why

6. Grant Regulations-Who . http://cfo.gov/cofar//

7. Grant Regulations-What “Super-Circular” 2 CFR PART 200—UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS

8. Grant Regulations-Where PART 200 Sub Part A: Definitions ----------------------------------------------Sub Part B: General Provisions Sub Part C: Pre-Award Requirements Sub Part D: Post Award Requirements -----------------------------------------------Sub Part E: Cost Principles ----------------------------------------------Sub Part F: Audit Requirements Administrative Requirements 2 CFR Part 215 (A-110) A-102/Common Rule, A-89 2CFR Part 225, 220, 230 (A-87, A-21, A-122) A-133, A-50

9. Grant Regulations-When Effective Date: 12/26/14 • New Awards • Additional Funding Increments • Audits for Fiscal Year after December 26th, 2014 * Existing Awards governed by Terms and conditions-except for Audit change December 26th, 2014

10. Grant Regulations-Why Better Outcomes • Performance Measurements-described in Award • Standardize Business Processes • Well-Trained Workforce • Clearer Funding Opportunities Spending Accountability • Target Risk and Add Transparency • Standardize Data Collection and Add Analytics • Strong Oversight and Increased Audit Resolution Administrative Burden • Minimize Burden on Grantees and Federal Agencies

11. Speak Clearly 2 Must vs. Should Non-Federal Entity and Pass-Though Entity State vs. Tribal Government Contractor vs. Vendor Award Section Speak Clearly: The difference between “must” and “should”

12. Must vs. Should Must = Requirement Should = Best Practices or recommended approach Which provisions are “Have-to” vs. “Nice to do?”

13. Non-Federal Entity and Pass-Though Non-Federal Entity = A state, local government, Indian tribe, institution of higher education (IHE), or nonprofit organization that carries out a Federal award as a recipient or Subrecipient Pass-through Entity = Non-Federal entity that subawards to a subrecipient New all inclusive term

14. State vs. Tribal Government State = any state of the United States, the District of Columbia, the commonwealth of Puerto Rico, the Virgin Islands, Guam, American Samoa, the Commonwealth of the Northern Mariana Islands, and any agency or instrumentality thereof exclusive of local governments Indian Tribe =tribe, band, nation, or other organized group or community, including any Alaska Native village or regional or village corporation as defined in or established pursuant to the Alaska Native Claims Settlement Act which is recognized as eligible for the special programs and services provided by the United States to Indians because of their status as Indians Definition change only-doesn’t affect award relationship New Grant Regulations |

15. Contractor vs. Vendor Contractor = means an entity that receives a contract. (The term ‘‘contractor’’ includes entities that, in other contexts, may be referred to as ‘‘vendors’’) Contract = means a legal instrument by which a non-Federal entity purchases property or services needed to carry out the project or program under a Federal award. Subaward. Vs. Contract: The type of relationship is more important than what you call the document

16. Award Award can mean $$$ or document, depending on context Federal Award = (1) Federal financial assistance that a non-Federal entity receives directly from a Federal awarding agency or indirectly from a pass-through entity (2) Certain cost-reimbursement contracts under the Federal Acquisition Regulations Does not include other contracts that a Federal agency uses to buy goods or services from a contractor or a contract to operate Federal government owned, contractor operated facilities (GOCOs)

17. Raising the Bar 3 Indirect Cost Rates Purchases Internal Controls and Pre-Award Review New Certifications Single Audit Threshold Section Raising the Bar: Thresholds and Limits

18. Indirect Cost Rate New 10% de minimis Indirect Cost Rate • For non-federal entities that never had a negotiated cost rate in place • Can elect to use this rate indefinitely One-time Extension • One-time extension of existing negotiated cost rate proposal up to 4 years • Subject to review and approval from Cognizant Agency

19. Purchases Purchasing • Micro-purchase $3000 no competition-if reasonable • Fixed Amount Subawards-not to exceed Simplified Acquisition Threshold of $150,000 (prior written approval) • Strengthen Conflict of Interest requirements • Purchases of computers under capitalization requirements can be treated as supplies

20. Internal Controls and Pre-Award Review Internal Controls and Pre-Award Review • Establish and maintain effective internal controls • Evaluate and monitor compliance • Pre-Award framework includes risk assessment • Mandatory Conflict of Interest, and Violation of Law Disclosures • Agency must describe the merit review process in the Funding Opportunity Both Federal Agencies and Pass-through entities must do risk assessment

21. New Certifications Certification of Costs ‘‘By signing this report, I certify to the best of my knowledge and belief that the report is true, complete, and accurate, and the expenditures, disbursements and cash receipts are for the purposes 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” • Signed by Official who can legally bind organization • Penalties under False Claims Act

22. Single Audit Threshold Single Audit Threshold • Raised to $750,000 • Still covers 99% of Federal $$$ Awarded • Relieved burden for 5000 organizations

23. It Takes a Village 4 Promote Women in the Sciences Conferences Travel Costs Fringe Benefits Family-related Leave Section It Takes a Village: Family-friendly Policies

24. Promote Women in the Sciences Promote Women in Science and Technology • Support Family Friendly Policies • Balance Work and Family Responsibilities • Targeted Travel and Conference Costs

25. Conferences Conference Spending • Cost of determining locally-available child-care resources are Allowable • But not the cost of the actual child-care • Focus still on limiting excessive conference and meeting spending

26. Travel Travel Costs • Temporary dependent care costs that result directly from travel to conferences and meet specified standards are Allowable • Must be a direct result of travel for the Award • Temporary and consistent with Travel Policy • Doesn’t Include costs of travel

27. Fringe Benefits Fringe Benefits • Can include Family-friendly Policies • Consistently applied • Better allow employees to balance their personal responsibilities while maintaining successful careers contributing to Federal awards

28. Family-related Leave Family Related Leave Explicitly allows Family-related Leave Policies Consistently applied Provided under established written leave policies

29. Truth and Consequences 5 Making Internal Controls More Visible Personally Protected Identifiable Information Federal Audit Clearinghouse (FAC) Analytics to Reduce Repeat Offenders Implementation Timing Section Truth and Consequences: Audit Transparency and Remedies

30. Making Internal Controls More Visible Internal Controls • Moves from A-133 Audit Requirements to earlier in Grant Lifecycle • Now in Administrative Requirements • Must provide reasonable assurance • Focus area

31. Personally Protected Identifiable Information Personally Identifiable Information (PPII) • Take reasonable measures to safeguard protected personally identifiable information and sensitive information • More and more information will be captured in various databases • Must sign statement that reports don’t include PPII and authorize publishing reports on the internet

32. Federal Audit Clearinghouse (FAC) Federal Audit Clearinghouse • Centralize Audit Reports and findings • For both recipients and sub-recipients • Reduce duplication of reports-no separate copy to pass-through entity • Some exceptions for Indian Tribes

33. Analytics to Reduce Repeat Offenders Analytics • Identify and reduce repeat findings • Use Cooperative Audit Resolution practices • Increased Threshold for likely questioned costs from 10K to 25K • New tools for agencies to track resolution

34. Q & A and Wrap-up Uniform guidance

35. Questions?