(UGG Webinar) On Dec. 26, OMB released interim requirements for the Uniform Grant Guidance. Is your organization positioned for compliance? Learn: • What changes were made to the UGG, and why. • Who will be affected. • When changes will go into effect. • How public sector award recipients can position themselves for compliance. • What grantees need to know to be compliant in the months and years ahead. Presented by Sandy Swab, public sector consultant. About Sandy Swab Sandy Swab is an independent public sector consultant at SRSwab Consulting. Previously, she was a senior policy analyst with the federal Office of Management and Data and policy manager for the Recovery Accountability and Transparency Board. She managed the Grants Reporting Information Project (GRIP), a recipient reporting project, which was the basis of the 2014 DATA Act pilot project. She regularly speaks on the topics of grants and financial management, data analysis and data standardization, system development and implementation, government-wide reporting requirements and policy analysis.

1. Preparing Your Organization
for Compliance
Highlights of the Federal Uniform
Guidance for Grants
Presented by:
Sandra Swab
Feb. 19, 2015
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3. About the Presenter
 Sandra Swab is currently an independent consultant focusing on
grants, data standards and performance measurement.
 Over 30 years government experience focusing on focusing grants,
financial and program management.
 Grants experience includes in setting up a federal funding program
and developing reporting requirements for it, overseeing and writing
grants agency policies, as well as developing electronic systems to
support the management of agency grants.
 Sandra also wrote and developed grant government-wide policies
while working at the Office of Management and Budget as a Senior
Policy Analyst.
 She is a member of the National Grants Management Association
(NGMA) and the Association of Government Accountants (AGA).
She is also sits on the Grants Advisory Board for Thompson Publishing.
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4. Agenda
 Background—A Historical Perspective
 Objectives of the Uniform Guidance
 Guidance Focus
 Structure of the Guidance
 Overview of the Uniform Guidance
 Questions
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5. A Little History of How We Got
Here
 P.L. 106-107 (1999)—Grant Streamlining
 FFATA (2006)—Reporting on federal
spending on a public website
 GPRA Modernization (2010)—Publish
agency performance goal
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6. A Little History of How We Got
Here
 ARRA (2009)—Central recipient
reporting of ARRA awards with
managed oversight
 DATA Act (2014)—Gov’t-wide data
standards for financial data
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7. History Continued
 Executive Orders focused on
regulation burden, improper payments
and innovation
Federal Assistance Guidance:
2 CFR Chapter 1, Chapter II, Part 200, et al.—Uniform
Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards, Final Rule (12/26/2013)
Interim Final Rule of Federal Agency Regulatory Implementation
of OMB’s Administrative Requirements; FR, Vol.79, No. 244;
(12/19/2014)
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8. UNIFORM GUIDANCE
OBJECTIVES & FOCUS
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9. Guidance Objectives
 Ease administrative burden
 Strengthen oversight
 Enhance accountability
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10. Focus of Uniform Guidance
 Standardization
 Format & Data
 Reporting
 Performance
 Award
 Organizational
OMB
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11. Focus of Uniform Guidance
 Standardization—Format & Data
 Federal agencies to use standard format
for funding opportunities (identify
performance measures—200.202)
 Federal agencies are required to supply
specific data on grant awards (200.210) &
includes award performance goals &
indirect cost rate
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12. Focus of Uniform Guidance
 Standardization—Format & Data
 Non-Federal Entities must be able to
identify in its accounts federal awards
received by:
 Federal program, award ID, CFDA number &
title, year, federal awarding agency and
name of pass-through entity
 States & non-federal entities need to be able
to trace funds to assure funds are used
according to federal statutes and regulations
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13. Focus of Uniform Guidance
 Standardization—Reporting
 Use OMB-approved standard information
collection instruments, e.g. SF-425
Report standardization allows:
 Non-federal entities to standardize their
data to meet reporting requirements
 Non-federal entities to use standardized
data in management processes
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14. Focus of Uniform Guidance
 Performance—Awards
 Federal agencies are required to identify
performance measures for each award
 Non-federal entities are required to report
on performance by:
 Relating financial data to performance
accomplishments
 Reporting cost information, when applicable
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15. Focus of Uniform Guidance
 Performance—Organizational
 Non-federal entities will be required to
demonstrate good management
practices by:
 Documenting performance history on funded
projects (federal & non-federal)
 Establishing or maintaining effective internal
controls to ensure compliance
 Establishing or maintaining organizational
policies and procedures that supports the
uniform guidance
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16. UNIFORM GUIDANCE
STRUCTURE
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17. Structure of the Guidance
 Consolidation
 Consolidated 8 OMB Circulars
 Provides consistency of terms
 Eliminated overlapping & confusing
compliance requirements
There are six subparts and 11 Appendices
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18. Structure of the Guidance
 Part 200
 Six Subparts
 Subpart A—Acronyms & Definitions
 Subpart B—General Provisions
 Subpart C—Pre-Federal Award Requirements
and Contents of Federal Awards
 Subpart D—Post Federal Award Requirements
 Subpart E—Cost Principles
 Subpart F—Audit Requirements
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19. UNIFORM GUIDANCE
OVERVIEW

20. Overview of Uniform Guidance
 Terms to Review
 Contract/Contractor
 Subaward/Subrecipient
 Cognizant agency for audit/oversight
agency for audit
 Cognizant agency for indirect costs
 Supplies and equipment
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21. Overview of Uniform Guidance
 Policy Changes
 Focus on performance
 Performance measures per award
 Introduces different types of grants (fixed price)
 Focus on performance measurement to
improve program outcomes
 Requires non-federal entities to meet identified
performance requirements & report
 Pass-through entities can pass down needed
performance requirements
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22. Overview of Uniform Guidance
 Policy Changes
 Requires federal agencies to accept
federal negotiated indirect cost rate or
use “de minimis” rate of 10% (same for
subrecipients)
 Compensation requirement for standards
with flexibility for implementation (200.430)
 Internal Controls; including PII
 IHEs Cost accounting standards &
disclosure statement (200.419)
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23. Overview of Uniform Guidance
 Policy Changes
 Family friendly policies--dependent care
costs-- conferences (200.432); and travel
dependent care costs (200.474)
 Listing of items requiring prior approval
(200.407)
 Supports use of technology to manage,
store and transmit funding data
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24. Overview of Uniform Guidance
 Management and Oversight
 Risk evaluation of potential applicants
prior to award (Federal agencies & pass-
through entities)(200.205 &200.331)
 Criteria must be in funding announcement
 Evaluation can result in special award
conditions
 Merit review of applications
 Process described in funding opportunity
 See Appendix 1
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25. Overview of Uniform Guidance
 Management and Oversight
 Disclosures of conflict of interest and
criminal violations; and certifications
 Pass-through entity responsibilities—
extensive for oversight and managing
(200.331)
 Cash payment transfers must minimize the
time funds are received to disbursement
of funds—requires cash management
oversight
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26. Overview of Uniform Guidance
 Management and Oversight
 Award Management requires managing
 Program Income
 Cost-Sharing
 Budget revisions
 Performance and financial management
Items above including requesting a cash payment
requires sound management practices and
monitoring with periodic internal reporting.
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27. Overview of Uniform Guidance
 Management and Oversight
 Cost principals—55 Items of Cost
 Non-federal entity’s accounting practices
must be consistent with the cost principles
 Identifies allowability of costs
 Cost must reasonable and necessary
 Conform to any limitations set forth in the cost
principles
 Adequately documented
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28. Overview of Uniform Guidance
 Management and Oversight
 Policy and procedure flexibility
 Procurement—requires using non-federal
entity’s procedures (grace period)
 Travel—use entity’s procedures or follow
federal GSA travel guidelines
 Time and effort--entity’s procedures must
meet standards
 Internal controls—ability to comply with
federal statutes & regulations; remedy non-
compliance; and PII
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29. Overview of Uniform Guidance
 Management and Oversight
 Audit Requirement
 Single audit--$750,000 expended in entity’s
fiscal year
 Exempt from single audit if less than $750K, but
may have an audit in relation to other
requirements—if required (200.503) and not be
duplicative
 Auditees must produce a financial statement
with schedule of expenditures of federal
awards (200.508 and 200.510)
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30. WHAT DOES THE UNIFORM
GUIDANCE OFFER
Conclusion
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31. Conclusion
 Uniform Guidance offers
 Flexibility—using their policy and
procedures
 Identification of standard data for
management and reporting
 Encourages use of electronic systems to
manage, store and transmit data in a
machine readable format
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32. In Conclusion
 Uniform Guidance establishes
 Risk criteria evaluation that requires non-
federal entities to be able to show it can
manage risk—financial integrity,
performance capability, etc.
 Stronger oversight of subrecipients and
places accountability on pass-through
entities and non-federal
 Need to link financial reporting to
performance to improve federal program
outcomes
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33. In Conclusion
 Uniform Guidance requires recipients
 To have internal business practices &
reporting in place to support federal
activities--reliance on sound business
practices
 To have capability to monitor award
activities, disbursements and budget to
easily produce required reports—reduce
waste, fraud and abuse
 To use standard data for reporting
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34. Questions
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