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Implementing the Super-Circular

Implementing the Super-Circular. Barbara Loescher & Trisha Edwards Fiscal Integrity & Audit Section. Topics for T oday. Overview of FIAS Supercircular New administrative requirements New cost guidelines New audit requirements What this means for c ounties Other hot topics.

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Implementing the Super-Circular

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  1. Implementing the Super-Circular Barbara Loescher & Trisha Edwards Fiscal Integrity & Audit Section

  2. Topics for Today • Overview of FIAS • Supercircular • New administrative requirements • New cost guidelines • New audit requirements • What this means for counties • Other hot topics

  3. Fiscal Integrity & Audit Section • Purpose is to monitor compliance with rules, regulations, licensing requirements and contracts to ensure that DCF funding is used appropriately • Created in 2012 • Consists of section chief and 5 auditors • Basic responsibilities • Desk reviews • On-site fiscal reviews • Internal audits

  4. Overview - Super-Circular • Combines 8 Circulars • Published December 26, 2013 • Effective Dates • December 26, 2014 • Single Audits – December 31, 2015 • Link: See references page • Additional guidance later this year

  5. Impact & Objectives • Reduce administrative burden • Reduce fraud, waste and abuse • Improve program integrity • Strengthen accountability • Shift from legacy awards to merit awards • More oversight required for pass-through agencies

  6. Administrative Requirements Reforms • Performance goals & reporting, cost effectiveness and collaboration • Technology changes • Computers now supplies • Flexibility in document retention • Standardized requirements and definitions

  7. Administrative Requirements Reforms • Stronger oversight • Conflict of interest policies • Internal controls • How audit results are treated • Sub-recipient monitoring

  8. Cost Principles Reforms • All entities – same guidance • Except for-profit agencies • Indirect/direct costs • Written cost allocation plan • No universal rule except consistency • Time and effort reporting • Emphasis on internal controls rather than PARs

  9. Cost Principles Reforms • Changes to specific items of cost • Advertising • “Employee morale” costs eliminated • Entertainment • Conference spending • Fines, penalties, damages and other settlements • Collection of unallowable costs • Home offices • And others

  10. A-133 Audit Reforms • Single audit threshold increased • $500,000 to $750,000 • Type A programs increased • $300,000 to $750,000 • Risk criteria has changed • Questioned costs threshold increased • $10,000 to $25,000

  11. A-133 Audit Reforms • Repeat findings • Compliance areas • Still not sure • Will be published 4/15/2015 • Online publication of reports • Federal Audit Clearinghouse

  12. How Does This Affect Counties? • Changes to your contracts with DCF • Discuss with Executive committee • Changes to county contracts with providers • New language • New references • New allowable cost requirements • New audit requirements for 2015 audits

  13. More Ways It Affects Counties • May be less auditing for A-133 audits • Training by DCF for county financial managers through rest of 2014 • New State Single Audit Guidelines for 2015 audits

  14. DCF Oversight of Providers • FIAS Fiscal Reviews: • Compliance with laws and licensing requirements • Financial stability • Allowability of costs • Fiduciary responsibility • Contract compliance • Fraud and abuse • Overpayment recovery • Includes all agencies receiving DCF funding

  15. Fiscal Reviews Results • Insight from the trenches • Luxury vehicles • Ghost vehicle • Lavish trips • Fraudulent invoices • Related party transactions • Personal items • “Me first” mentality • Home office • Holiday parties • Box Bucks tickets • Gas allowances • ATM withdrawals • Undocumented items • Donations • Overdraft charges • Unreasonable • Unnecessary

  16. County Fiscal Reviews • Expanding into county fiscal reviews • Scheduling first wave in coming months • Review centered on: • Cost allocation • Allowable costs • Sub-recipient monitoring

  17. Allowable Cost Policy Manual Update • Major re-write • Currently being reviewed internally • To be discussed with Executive Committee • Current (tentative) ETA – before year end

  18. In Closing • Read the Super-Circular • Continue spending public funds prudently • Update your contracts • The ACPM is coming • And we’ll see you soon!

  19. For Further Information Barbara Loescher, CIA Chief, Fiscal Integrity & Audit Section Department of Children & Families (608)264-6992 Barbara.Loescher@wisconsin.gov Trisha Edwards, CPA Auditor – Senior Department of Children & Families (608) 267-2981 Trisha.Edwards@wisconsin.gov

  20. Questions?

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