Changes to Requirements for Administering Federal Funds

1. Changes to Requirements for Administering Federal Funds Presented by Edward A. Hofma, CPA, CGMA Principal in the CPA firm of Averett Warmus Durkee, PA 1417 East Concord Street Orlando, Florida 32803 (407) 849 -1569 ehofma@awd-cpa.com

2. Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards • https://www.federalregister.gov/articles/2013/12/26/2013-30465/uniform-administrative-requirements-cost-principles-and-audit-requirements-for-federal-awards#h-36

3. Administrative Requirements

4. Post-Award Requirements • Financial and program management • Cash management • Compliance with matching requirements • Program income • Property standards • Procurement standards • Termination and enforcement standards

5. Cost Principles • Articulates basic considerations of cost • Differentiates direct and indirect costs • Provides guidance on indirect cost allocations • Provides guidance on indirect cost rates • Provides guidance on over 50 items of cost

6. Audit Requirements

7. Seven Prior OMB Circulars are superseded: • Circular A-21: Cost Principles for Educational Institutions • Circular A-87: Cost Principles for State, Local and Indian Tribal Governments • Circular A-89: Catalog of Federal Domestic Assistance • Circular A-102: Grants and Cooperative Agreements with State and Local Governments • Circular A-110: Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations • Circular A-122: Cost Principles for Non-Profit Organizations • Circular A-133: Audits of States, Local Governments and Non-Profit Organizations

8. Major Objectives of Policy Reform • Eliminating duplicative and conflicting guidance • Focusing on performance instead of compliance for accountability. • Encouraging efficient use of information technology and shared services • Providing for consistent and transparent treatment of costs • Limiting allowable costs to make best use of federal resources • Setting standard business processes using data definitions • Encourages family-friendly policies • Strengthening oversight

9. Changes to Administrative Requirements – General Provisions • Changes the threshold for classifying personal property as supplies to $5,000 • Mandatory conflict of interest policies to be included in contracts as determined by each agency

10. Changes to Administrative Requirements – Pre-Award Requirements • Final guidance issued to allow “Fixed Amount” awards rely more on performance than on compliance. • Requires that funding opportunities be available for application for 60 days

11. Changes to Administrative Requirements – Post-Award Requirements (Internal Control) • Internal control guidance that previously was only discussed in the audit requirements has been moved to the administrative requirements to encourage recipients to better structure internal control earlier in the process • Incorporates the guidance of the GAO Standards for Internal Control for the Federal Government • Incorporates the guidance of the Committee of Sponsoring Organizations (COSO) of the Treadway Commission • Both of these documents emphasize entity level controls over activity level controls • Areas of entity level controls are control environment, risk assessment, information and communication, control activities, and monitoring

12. Changes to Administrative Requirements – Post-Award Requirements (Other) • Requires non-federal entities to take reasonable measures to safeguard protected personally identifiable information • Procurement policies will follow former OMB Circular A-122 rather than A-110. • Requires a three year record retention policy • Expresses a preference for electronic records over paper records • Allows termination of a contract for cause • In close out, agencies have 90 days to file their final reports • The government has a statute of limitations of three years for recoveries of funds under the contract that they determine were not properly used.

13. Changes to Cost Principals (General) • Direct costs – makes changes regarding when administrative costs can be charged as a direct cost instead of an indirect cost. • Specifically authorizes use of indirect costs rates, and gives agencies standards for developing and using indirect cost rates. • Authorizes a de minimis indirect cost rate of 10% of direct costs • Institutions of Higher Educations that expend more than $50,000,000 must use the Federal Acquisition Regulations (FAR) Cost Accounting Standards • Addresses changes to about 40 categories of cost

14. Changes to Cost Principals (Specific Items of Cost) • Advertising is now allowed if it is used for program outreach • Personal compensation – allows the federal agencies flexibility in documentation required to support payroll, but implemented in its place requirements for internal controls over payroll. • Conferences – allows costs of identifying sources of dependent care are allowable, but not the costs of providing the care. • Idle Facilities and Capacity – Such costs can be allowable for a reasonable period of time not to exceed one year. • Materials and supplies – Personal property less than $5,000 can be classified as materials and supplies. • Travel costs can now include dependent care costs within specific parameters.

15. Audit Requirements –Auditee Responsibilities

16. Identify federal funds made to sub-recipients • Advise sub-recipients of the compliance requirements for their grant Audit Requirements – Cognizant Agency Responsibilities • Monitor the activities of the sub-recipients

17. Changes to Audit Requirements (General) • The federal funds threshold for requiring a Single Audit is raised from $500,000 to $750,000 • Requires program specific audit guides be included in the compliance supplement • A list is provided of valid reasons for why an audit finding does not warrant further action • The threshold for questioned costs raised from $10,000 to $25,000 • The threshold for Type A programs is raised from $300,000 to $750,000

18. Changes to Audit Requirements (Compliance Requirements) There were discussions of many approaches in the exposure drafts It has been left hanging pending further announcement

19. Changes to Audit Requirements (Determinations of Major Programs) • Identify Type A programs • Identify low risk Type A programs • Identify high risk Type B programs, but not required to identify high risk Type B programs that exceed 25% of the low risk Type A programs. • Must audit all high risk Type A and B programs, and such additional programs as are necessary to cover the percentage of coverage requirement. • Percentage of coverage requirement is lowered from 50% to 40% for high risk auditees, and from 25% to 20% for low risk auditees.

20. Changes to Audit Requirements (Criteria for Risk Assessments) • Weaknesses in internal control • A program administered under multiple control structures • Significant pass-through to sub-recipients • Prior audit findings • Programs not recently audited (within the last two years) • Complexity of the program • New programs • Programs at the end of their life cycle

21. Questions?