1 / 50

Presented by: Wayne Ball NCSI Fiscal Support Team (FST)

Federal Funding-Fisca l Fun- Wyoming 2017 WAVE Conference Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Reporting. Presented by: Wayne Ball NCSI Fiscal Support Team (FST). Purpose/Objectives.

jesusp
Télécharger la présentation

Presented by: Wayne Ball NCSI Fiscal Support Team (FST)

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. Federal Funding-Fiscal Fun-Wyoming 2017 WAVE ConferenceUniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Reporting Presented by: Wayne Ball NCSI Fiscal Support Team (FST)

  2. Purpose/Objectives • This brief presentation is to inform the audience about the New Uniform Guidance Requirements and how/where to access them. • Make participants aware that all grantees of Federal awards and projects are required to follow the Uniform Guidance.

  3. RealityOut of Touch 07.178.65 Monitoring LoD

  4. Uniform Guidance (2 CFR § 200) • The Uniform Guidance (2 CFR § 200) streamlines and consolidates government requirements for receiving and using federal awards so as to reduce administrative burden and improve outcomes. It was published in the Federal Register (79 Fed. Reg. 75871) on December 19, 2014, and became effective for new and continuation awards issued on or after December 26, 2014. Please note the new regulations do not affect grant funds awarded prior to December 26, 2014, unless funds made available under those grants are carried forward into a new Federal fiscal year or a continuation grant.

  5. Guidance in the Federal Register http://www2.ed.gov/policy/fund/guid/uniform-guidance/index.html • Federal Register notice 80 FR 43301, Published on July 22, 2015 • Federal Register notice 80 FR 54407, Published on September 10, 2015

  6. Overview: Review of Uniform Guidance ) (2 CFR § 200) • Audit Requirements • Cost Principles • Indirect Costs • Internal Controls • Procurement • Risk and Subaward Management

  7. WEA Directors Meeting 07.178.65 Monitoring LoD

  8. The Uniform GuidanceAudit Requirements – 2 CFR Part 200 Subpart F U.S. Department of Education

  9. Uniform Guidance: Key Changes Four Broad Types of Changes in Audit Requirements and their impact at ED and its grantees

  10. Uniform Guidance: Overview Prior to the issuance of the Uniform Guidance, the audit requirements relating to Single Audits were set forth in OMB Circular A-50, Audit Follow-up, OMB Circular A-133, and the Compliance Supplement to that Circular. The audit requirements resulting from the Uniform Guidance are found at 2 CFR 200, Subpart F, and Appendix XI.

  11. Uniform Guidance: 4 Key Changes and Their Impact 1. Strengthen oversight by focusing audits where there is greatest risk of waste, fraud, and abuse of taxpayer dollars. • Increases audit threshold from $500,000 to $750,000 (2 CFR 200.501). • Gives more weight, in testing, to programs with high-risk audit findings in prior years (2 CFR 200.518). • Raises questioned cost threshold from $10,000 to $25,000 (2 CFR 200.516). • Lowers audit burden further by reducing percentage of expenditures tested.

  12. Uniform Guidance: 4 Key Changes and Their Impact 2. Provide for greater transparency of audit results by making Single Audit reports available to the public online, removing impediments to their distribution, and increasing information in audit reports. • Complete reports will be available at the FAC website, with some exceptions, related to Indian Tribes • Subgrantees are no longer required to submit their reporting package to the pass-through agency. FAC will be the source of subgrantees’ reports (2 CFR 200.512) • FAC submission process will be changed to require that audits be in text-based PDF and unlocked to improve accessibility. • More information available on audit findings and Federal expenditures.

  13. Uniform Guidance: 4 Key Changes and Their Impact 3. Audit follow-up will focus more on higher questioned costs, with greater attention to timely issuance of management decisions, and ensuring quality of audits resolved, and avoiding the recurrence of audit findings. 2CFR 200.513 • Higher threshold for reporting questioned costs means fewer, but more significant, findings resolved • Six-months clock for issuing Management Decisions starts when FAC accepts Subpart F audits; prior to Uniform Guidance it started when the agency resolving the audit received it • Federal agencies are to take part every six years in an audit quality evaluation projects. • By using Cooperative Audit Resolution practices Federal agencies are expected to significantly reduce the recurrence of audit findings among grantees.

  14. Uniform Guidance: 4 Key Changes and Their Impact 4. Strengthen Federal agencies’ use of the Single Audit process to support more efficient and effective grants management. 2 CFR 200.513 • Agencies are to develop a baseline, metrics, and targets to track effectiveness of agencies’ processes to follow up on audit findings and how they use Single Audits in awarding grants and improving accountability by grantees. • Federal agencies must establish two new positions: (1) a Single Audit Accountable Official to link the Single Audit process to improved program outcomes, including accountability by grantees, and (2) a Key Management Single Audit Liaison, over operational issues, ranging from training to cooperative audit resolution.

  15. Cost Principles – 2 CFR Part 200 Subpart E U.S. Department of Education

  16. Uniform Guidance Title 2 of the Code of Federal Regulations, Part 200 (2 CFR Part 200) Accepted by the Department of Education in 2 CFR Part 3474

  17. Authorities to consider when using 2 CFR Part 200 “This guidance does not change or modify any existing statute or guidance otherwise based on any existing statute.”

  18. When does 2 CFR Part 200 start? Uniform Guidance (2 CFR Part 200) applies to: • New and Continuation grants awarded on or after December 26, 2014 Former regulations (EDGAR Part 74 or 80 and OMB circulars) apply to: • Grants awarded prior to December 26, 2014

  19. Where are the cost principles requirements?

  20. Cost Principles: Overview • Allowable • Reasonable and Necessary • Allocable • Direct v. Indirect • Special Considerations by Entity Type • Selected Items of Cost • Expanded Authorities

  21. A Life Without Accountability 07.178.65 Monitoring LoD

  22. Indirect Cost Concerns Under the Uniform Guidance U.S. Department of Education

  23. What Are Indirect Costs? • Costs that have been incurred for common or joint purposes. • Costs that benefit entire organization, and cannot be specifically identified to one cost objective. An indirect rate ensures that each Federal agency providing funding picks up its fair share of indirect costs.

  24. Key Changes in Indirect Costs • 200.210(a)(15) Federal awarding agency must include the Indirect cost rate on the Federal Award (Grant Award Notification (GAN)). • 200.414(f) - Grantees that have never negotiated an indirect cost rate may use de minimis rate of 10% of MTDC • 200.414(g) – One-time extension of a current negotiated rate for a period of up to 4 years. • 200.331(a)(4) Sub-recipients can use Federal rate agreement, negotiate a rate, or de minimis rate.

  25. Procurement Policies under the Uniform Guidance U.S. Department of Education

  26. Locating Procurement Standards §200.317 - 326

  27. §200.317 Procurement by states • A State must use the same procedures it uses to procure property and services under a Federal award as it uses for all other procurements using non-federal funds. • States will comply with §200.322 Procurement of recovered materials. • All other grantees and subgrantees must follow sections 200.318 through 200.326.

  28. Risk Management System

  29. What is Risk? Risk is the possibility that an event will occur and adversely affect the achievement of objectives. (GAO – The Green Book)

  30. What is Risk Management? Risk management can be described as the continuous process of assessing risks, reducing the potential that an adverse event will occur, and putting steps in place to deal with any event that does occur. (GAO)

  31. Risk Assessment Risk Management Risk-Based Monitoring Risk Mitigation

  32. The Future Appropriate Distribution of Funds Fiscal monitoring as part of general supervision 1. Ensure timely obligation and liquidation of funds. YES! 2. Ensure appropriate distribution of funds. YES! 3. Ensure appropriate use of funds. NEED FISCAL MONITORING! Timely Obligation & Liquidation Appropriate Use of Funds

  33. What to look for… • Spending inconsistencies that appear to be program related • A133 audit or single audit findings • LEA basic information: LEA determination status, enrollment numbers and AYP results

  34. Subrecipient Monitoring under the Uniform Guidance • Subaward notice includes required information • Evaluate subrecipient’s risk of noncompliance • Impose specific conditions if appropriate • Monitor the activities of the subrecipient as necessary 2 CFR § § 200.328(a) and 331

  35. Subrecipient Monitoring under the Uniform Guidance Continued • Based on assessment of risk, consider monitoring activities (TA, on-site monitoring, etc) • Verify that every subrecipient is monitored as required • Consider if audits and monitoring requires adjustment in entities own records • Consider taking enforcement action 2 CFR §§200.328(a) and 331

  36. Oversight! Fiscal Monitoring

  37. Documents to Assist with Designing and Implementing a Risk Management System

  38. Documents Needed • For full list see Grads 360 • Examples include: • Current monitoring procedures and protocols • Proposed monitoring procedures and protocols • Monitoring cycle, if applicable • Risk rubric/assessment/factors • Summary of IDEA-related fiscal monitoring and audit findings for prior two years

  39. Resources Relevant resources have been posted on https://osep.grads360.org/#program/fiscal-monitoring, including: • OSEP’s Risk Management System PowerPoint • Monitoring Protocols • Fiscal Monitoring Overview • Related Resources

  40. Resources (cont.) • GAO – The Green Book) http://www.gao.gov/greenbook/overview • UGG- http://www.grants.gov/web/grants/learn-grants/grant-policies/omb-uniform-guidance-2014.html • EDGAR- http://www2.ed.gov/policy/fund/reg/edgarReg/edgar.html • IDEA- http://www2.ed.gov/policy/speced/guid/idea/idea2004.html

  41. Discussion Questions on Current Monitoring Procedures • How do you select LEAs for monitoring? • Do you currently conduct a risk assessment? • Do you conduct programmatic monitoring and fiscal monitoring together, separately, or some combination? • Do you monitor jointly with other offices responsible for Federal programs (e.g., Title I)? • How doe the results of monitoring inform the TA provided to LEAs?

  42. 07.178.65 Monitoring LoD

  43. Everything is a process. 07.178.65 Monitoring LoD

  44. Contact Information Wayne Ball 970-227-8234 wball@air.org Southeast North Central Anne Louise Thompson 203-687-6063 althomp@wested.org Northeast Mid-South Jana Rosborough 913-219-9136 jrosbor@wested.org Mountain Plains Western

  45. THANK YOU!http://ncsi.wested.org | @TheNCSI

More Related