Uniform Guidance and Additional Noteworthy Changes
The Office of Management Budget, under federal agencies’ guidance, has released its “Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards” known as the Uniform Guidance (UG). The former Office of Management Budget circulars were combined to form the Uniform Guidance. The date it became effective was December 26, 2014. New grants, that were awarded by the federal government, and additional funding of existing awards after this date, fall under the new guidance and administrative process must follow the UG.
For non-profit and non-federal organizations, such as local governments who receive federal grants, changes within the organization must take place to become compliant with the guidance. Recommended areas an organization should revisit include: conflict of interest policy (and sub-recipients), procurement policy, cash management policy, and internal controls. Organizations should establish monitoring controls for these areas and ensure the individuals monitoring them are supervised. It would be beneficial for organizations to have written policies and elections to ensure compliance with the UG. Organizations should inventory their grants and indicate whether awards were pre-December 26, 2014. Additional implementation guidelines are located at: http://clarknuber.com/articles/omb-uniform-guidance-implementation-top-10-changes/.
Single audit thresholds have also changed for fiscal years beginning after December 26, 2014. To be a federal single audit, a recipient must have federal expenditures of at least $750,000. For State single audit, the threshold remains at $500,000. The UG requires Auditors to perform risk assessment on federal major programs differently than in the past. Going forward, the Schedule of Expenditures of Federal and State Awards will be presented slightly different than in the past. To ensure that you are in compliance with UG requirements, contact your external Auditor and discuss with them any questions you may have.
For more information pertaining to compliance with UG requirements, visit: http://www.ecfr.gov/cgi-bin/retrieveECFR?gp=&SID=6fa3d383114ae5678709f6516c351b55&mc=true&n=pt2.1.200&rPART&ty=HTML#se2.1.200_1318.
Article by: Ko Tang Cha-Moses, Audit Manager