COMPLIANCE WITH OMB CIRUCLAR A-133 AUDIT READINESS

1. (404) 874-0555 WPG-INC.COM COMPLIANCE WITH OMB CIRUCLAR A-133 AUDIT READINESS WELCOME The Wesley Peachtree Group CERTIFIED PUBLIC ACCOUNTANTS

2. OMB CIRCULAR A-133 AUDIT READINESS PRESENTED BY... Milton V. Jones The Wesley Peachtree Group, CPAs

3. Introduction The Wesley Peachtree Group, CPAs Largest minority-owned firm in southeast Specializes in higher education Particular focus on HBCUs

4. Introduction Topic—Improving A-133 Audit Preparedness Takeaways—A Better Understanding of A-133 Requirements and the Audit Process

5. Agenda OMB Circular A-133 Compliance Requirements Items Generally Requested During the Audit Common Deficiencies

6. Understanding OMB Circular A-133 Compliance Requirements A - Activities Allowed or Unallowed B - Allowable Costs/Cost Principles C - Cash Management D - Davis-Bacon Act E - Eligibility F - Equipment and Real Property Management G - Matching, Level of Effort, Earmarking

7. Understanding OMB Circular A-133 Compliance Requirements H - Period of Availability of Federal Funds I - Procurement and Suspension and Debarment J - Program Income K - Real Property Acquisition Relocation Assistance L - Reporting M - Sub-recipient Monitoring N - Special Tests and Provisions

8. A - Activities Allowed or Unallowed Unique to each Federal program Grant specific

9. B - Allowable Costs/Cost Principles • Three cost principles circulars • OMB Circular A‑87—“Cost Principles for State, Local, and Indian Tribal Governments” • OMB Circular A-21—“Cost Principles for Educational Institutions” • OMB Circular A-122—“Cost Principles for Non-Profit Organizations”

10. C - Cash Management Reimbursement basis Rule of thumb

11. D - Davis-Bacon Act Construction and renovation contracts Dollar threshold

12. E - Eligibility Eligibility requirements Sample selection Compliance testing

13. F - Equipment and Real Property Management Tag Track Threshold

14. G – Matching, Level of Effort, Earmarking Proof of compliance

15. H - Period of Availability of Federal Funds Funding period Extended period (cost extension)

16. I - Procurement and Suspension and Debarment • Procurement • Procurement procedures • Suspension and Debarment • Covered transaction • Threshold • Government website link http://epls.arnet.gov

17. J – Program Income Identification Income use

18. L - Reporting Financial Reporting Performance Reporting Special Reporting

19. M – Subrecipient Monitoring Identification Monitoring Compliance

20. N – Special Test and Provision Grant specific

21. OMB Circular A-133 Compliance Requirements Summary www.whitehouse.gov/omb/circulars_default Questions

22. Items Generally Requested During the Audit Overview

23. Items Generally Requested During the Audit Schedule of Expenditures of Federal Awards

24. Items Generally Requested During the Audit Grant Award Notification with Budgets and Narratives (Internal Controls, Compliance Requirements: All)

25. Items Generally Requested During the Audit Budget versus Actual Comparison pulled directly from the accounting system. (Internal Controls, Compliance Requirement: A, B)

26. Items Generally Requested During the Audit Documentation supporting allocation of common costs. (Internal Controls, Compliance Requirement: A, B)

27. Items Generally Requested During the Audit Schedule of Salaries and Fringes charged to Internal Controls, Compliance Requirement: A, B

28. Items Generally Requested During the Audit Sample selection of disbursements determined by auditor to test controls and/or compliance (Internal Controls, Compliance Requirements: A, B, F, H, I)

29. Items Generally Requested During the Audit Time and effort reports (Internal Controls, Compliance Requirements: A, B, H)

30. Items Generally Requested During the Audit General ledger support for all cash drawdowns made during the year. (Internal Controls, Compliance Requirements: C)

31. Items Generally Requested During the Audit Proof of compliance with matching requirements, level of effort and earmarking. (Internal Controls, Compliance Requirements: G)

32. Items Generally Requested During the Audit Evidence of periodic monitoring of compliance with the Davis-Bacon Act. The dollar threshold for project qualifying under the Davis-Bacon Act is $2,000. (Internal Controls, Compliance Requirements: D)

33. Items Generally Requested During the Audit Listing of participants and/or recipients. (Internal Control, Compliance Requirements: E)

34. Items Generally Requested During the Audit Evidence of compliance with eligibility requirements, if any. Eligibility requirements are generally defined in the narrative of the grant. (Internal Controls, Compliance Requirements: E)

35. Items Generally Requested During the Audit All program reports submitted for performance, financial and special purposes. (Internal Controls, Compliance Requirements: L)

36. Items Generally Requested During the Audit Bank statements for all cash accounts holding Federal funds. (Internal Controls, Compliance Requirements: J)

37. Items Generally Requested During the Audit Sub-agreements with all entities working on Federal grants awarded to the College. (Internal Controls, Compliance Requirements: M)

38. Items Generally Requested During the Audit Summary Questions

39. Common Deficiencies Overview

40. Common Deficiencies Proper approvals from the Business Office Personnel are not consistently applied.

41. Common Deficiencies Time effort reporting is not maintained, properly approved or accurately allocated to salary expense.

42. Common Deficiencies Supporting documentation such as invoices, purchase orders or requisitions are not available for expenses.

43. Common Deficiencies Drawdowns are received in excess of three days of needs.

44. Common Deficiencies Davis-Bacon Act compliance requirement is often overlooked because of the low threshold of $2,000.

45. Common Deficiencies Competitive bids are not performed or documented.

46. Common Deficiencies Evidence is not available showing verification of vendor qualifications against government databases for suspensions and debarments. http://epls.arnet.gov

47. Common Deficiencies Annual performance reports are filed untimely.

48. Common Deficiencies Summary Questions

49. Conclusion Topic—Improving A-133 Audit Preparedness • A-133 Compliance Requirements • Items Generally Requested During the Audit • Common Deficiencies Takeaways—A Better Understanding of A-133 Requirements and the Audit Process Contact us with any additional questions

50. THE WESLEY PEACHTREE GROUP, CPAs (404) 874-0555 WPG-INC.COM THANK YOU Donald K. Murphy Keith X. Terrell don@wpg-inc.com keith@wpg-inc.com Milton V. Jones mjones@wpg-inc.com