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Accounting For Grants. FGFOA Beginner Boot Camp, Tuesday, November 19, 2013 Hyatt Regency, Sarasota FL Bert Martinez CPA, Senior Audit Manager Purvis Gray & Company, LLP Tallahassee / Gainesville / Ocala / Sarasota. Grant Accounting – Scope of Presentation. Regulatory Environment
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Accounting For Grants FGFOA Beginner Boot Camp, Tuesday, November 19, 2013 Hyatt Regency, Sarasota FL Bert Martinez CPA, Senior Audit Manager Purvis Gray & Company, LLP Tallahassee / Gainesville / Ocala / Sarasota
Grant Accounting – Scope of Presentation Regulatory Environment Grant Compliance Resources Internal Controls Administrative Requirements Cost Principles Single Audit
Regulatory Environment • The grantee should have an understanding of the external factors and regulators regarding grant oversight and/or single audits. • AICPA • GAO • PCAOB • OIGS • OMB
Grant Compliance Resources • Grant Agreement • Federal Clearinghouse • Florida Single Audit Act • Compliance Matrix • Statutes, Regulations and Program Requirements
Grant Cooperative Agreement Contract
Grant Agreement Obtain and read your grant agreement and amendments Summarize the important terms and conditions for compliance Keep it readily available for review
Federal Audit Clearinghouse • The Federal Audit Clearinghouse homepage • Single audit reference materials • Links to several resources to assist the auditors and auditees with Federal compliance requirements • Single audit basics and where to get help for Federal grant recipients provided by the Grants Management Committee of the United States Government Chief Financial Officers Council
Florida Single Audit Act The grants manager should be familiar with applicable state compliance requirements as designated by the Executive Office of the Governor in Section 215.97, Florida Single Audit Act.
Compliance Matrix • The Federal matrix of compliance requirements for federal programs is updated annually and can be found as part of the OMB A-133 Compliance Supplement link from the Federal Audit Clearinghouse homepage • As part of the Florida Single Audit Act, the state also updates the State Projects Compliance Supplement matrix of compliance requirements.
Compliance Requirements • Activities Allowed or Unallowed • Allowable Costs/Cost Principles • Cash Management • Davis-Bacon Act • Eligibility • Equipment and Real Property Management • Matching, Level of Effort, Earmarking • Period of Availability • Procurement and Suspension and Debarment • Program Income • Real Property Acquisition/Relocation Assistance • Reporting • Subrecipient Monitoring • Special Tests and Provisions
Statutes, Regulations & Program Requirements • CFDA and CSFA • Grant Agreement • Public Policy Requirements • Special Conditions or Restrictions • Program Guidance
Internal Controls • The Grant Manager should establish written policies and procedures regarding internal controls over each of the Compliance Requirement areas that may include: • approvals and authorization • segregation of duties • record retention • management review • documentation
Administrative Requirements - Financial administration - Equipment/supplies/real property - Reporting requirements
Administrative Requirements • Equipment • Must be used to program acquired for • If no longer needed, may be used for any other project paid for with federal dollars • Must be tracked until fair market value is below the threshold for capital equipment • If above FMV, may be retained or sold but proceeds go to federal agency • What threshold to use
Reporting Compliance The Grant Manager: • should have an understanding of the reporting requirements for the applicable program • should have policies and procedures in place to ensure that reporting – financial, performance and special, as applicable, is accurate and timely • Electronic versions of standard forms are located on OMB’s homepage – (http://www.whitehouse.gove/omb/grants/grant-forms.html
Administrative Requirements • Records Retention Period • Federal government: 3 years • State government or your agency
OMB Circulars • Cost Principles • Audits
Financial Compliance • Cost Principles • Allocable • Necessary and reasonable • Treated consistently (direct or indirect) • In accordance with GAAP • Net of all applicable credits
Financial Compliance (continued) • Cost Principles (OMB Circular A-87) • Not used for cost sharing or matching requirement for another federal award • Adequately documented • Authorized or not prohibited under under state or local laws and regulations • In conformance with limits or exclusions on types of amounts of costs • Consistent with recipient’s policies and procedures
Financial Compliance (continued) • Cost Principles (OMB Circular A-87) • Selected items of cost • Salaries charged to grants
Single Audit Act • Single Audit Act (SAA) [Auditor and auditee’s responsibilities] • Compliance Supplement
An Effective GrantCompliance Program • Written grant procedures • Checklists • Grant monitoring and auditing • Formal and informal grant training program • Quarterly newsletter • Web page on County’s Intranet