1 / 13

OMB Uniform Guidance 2014 Implementation at the University of Washington

OMB Uniform Guidance 2014 Implementation at the University of Washington. Northwest Chapter of Internal Auditors August 5 th , 2014 Ted Mordhorst Asst. Dir. For Post Award Financial Compliance Research Accounting and Analysis University of Washington. OMB Uniform Guidance 2014.

axel-townsend
Télécharger la présentation

OMB Uniform Guidance 2014 Implementation at the University of Washington

An Image/Link below is provided (as is) to download presentation Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript

  1. OMB Uniform Guidance 2014Implementation at the University of Washington Northwest Chapter of Internal Auditors August 5th , 2014 Ted Mordhorst Asst. Dir. For Post Award Financial Compliance Research Accounting and Analysis University of Washington

  2. OMB Uniform Guidance 2014 • Final Guidance document published in the Federal Register Dec 26, 2013. • Codified in 2 CFR 200 • Replaces 8 previous OMB Circulars: • Circular A-110 Circular A-21 • Circular A-102 Circular A-87 • Circular A-89 Circular A-102 • Circular A-133 Circular A-50

  3. OMB Uniform Guidance 2014 • Applicable to Direct Federal Grants, Cooperative Agreements and Cost-reimbursable contracts. • Each federal awarding agency must implement • Effective for new $ received on or after Dec. 26, 2014 • Audit effective for the entities first full fiscal year after 12/26/14. • Example: Entities fiscal year ends June 30th • New audit requirements apply to fiscal year that ends June 30, 2016

  4. University of Washington Approach • A Core Team has been assembled • Sponsored by Mary Lidstrom, Vice Provost for Research and Susan Camber, Associate Vice President, Financial Management • The team has representatives from: • OR, OSP, GCA, MAA, School of Medicine, College of Arts and Sciences, Procurement Services, and Internal Audit, The AG office • Additional sub-teams have been formed to review some of the more complex areas. University ofWashington Presenter’s Office

  5. Uniform Guidance Working Group • The working groups compared the new regulation to the existing regulations in A-110, A-21 and A-133 • Identify changes • Map changes to university policy and procedures • Identifying possible changes to IT systems both central and in units • Propose changes to policy, procedures necessary to maintain compliance University ofWashington Presenter’s Office

  6. Uniform Guidance Working Group • Develop internal Communication plan. • Develop protocol for making changes to policies and procedures. • Develop training for campus personnel. • Modify existing training material for faculty and staff. University ofWashington Presenter’s Office

  7. Uniform Guidance Working Group • Timeline • APRIL 15 DISCOVERY (initial discovery of what changed complete) • MAY 15 DISCOVERY (impact to UW systems complete) • JUNE 01 DISCOVERY (map to UW policy & procedure complete) • JUNE 26 FEDERAL PLANS RELEASED (Federal agencies release their respective implementation plans)(Has not happened.) • SEPT 30 DRAFT OF CHANGES TO UW POLICY (comprehensively address & publish all changes to UW policy) • DEC 01 UW READY TO IMPLEMENT CHANGES (changes to UW policy & procedure approved & published) • DEC 26 FEDERAL IMPLEMENTATION BEGINS University ofWashington Presenter’s Office

  8. Uniform Guidance Working Group • We established a web page for the team at: • http://www.washington.edu/research/topics/uniform-grant-guidance/ • Contains links to the Final Uniform Guidance document • Links to other documents and presentations • Continues to be updated as more information becomes available.

  9. Uniform Guidance Working Group • There are Open Issues… • Agency deviations – how will these be policed? • Conflict of Interest – agency plans are key • Research Terms and Conditions – (FDP) a lot to do in little time • Internal Controls – audit repercussions, if any? • Procurement – could be most significant new burden • Subrecipient Monitoring – could be second most significant • Closeouts – not a major change in the Uniform Guidance, but the pressure for timely closeouts has raised profile

  10. Uniform Guidance Working Group • Other Issues… • The UW is working with the Council on Governmental Relations to obtain clarification from OMB on a number of areas: • Conflict of Interest – Institutional or individual • Program Income – Treatment of Royalties or other IP Income • Equipment – “Conditional Title” • Procurement – Small purchase threshold – required competition

  11. Uniform Guidance Working Group • Challenges: • Conflicting Priorities for team members • Differing interpretations • OMB/COFAR slow response to questions • Pending clarification issues • Agency implementation plans not published

  12. Uniform Guidance Working Group • A lot of questions remain but some of the more visible changes will have little impact on our policy and procedure. • Effort Certification – No change planned • Direct Charging of Administrative & Clerical Salaries – Little or no change planned • Electronic Records – Already moving to a paperless environment • Subrecipient Monitoring – Just revamped our processes

  13. Uniform Guidance ImplementationUniversity of Washington Questions?

More Related