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GOVERNMENTAL UPDATES:
UNIFORM GUIDANCE (UG) AND GASB
Presented by
Brittney Williams, CPA, CGFM
Heinfeld, Meech & Co., P.C.
Agenda
2
• Uniform Guidance (UG) Refresher
• GASB Updates
• New GASB Pronouncements
• Major Projects
• Practice Issues
• P...
Part 200 – UniformAdministrative Requirement, Cost Principles,
andAudit Requirements for FederalAwards
Subpart A - Acronym...
Objectives
Goals of COFAR based on guidance from Executive Office
• Streamline guidance for Federal awards to ease adminis...
Post-Award Requirements
Internal Controls (Section 200.303)
• Moved from audit requirements to post-award requirements
• O...
Post-Award Requirements
Procurement (Section 200.318)
• “Integrity Rules”
• Must maintain written standards of conduct cov...
Post-Award Requirements
Procurement (Section 200.318)
• Must avoid acquisition of unnecessary or duplicative items
• Encou...
Cost Principles
Indirect Cost Rates (Section 200.414)
• Non-Federal entities that have never had a negotiated
indirect cos...
Cost Principles
Other Revisions
• Measures to safeguard personal and sensitive information
• Encouragement of family-frien...
Cost Principles
Required Certification
“By signing this report, I certify to the best of my knowledge
and belief that the ...
Audit Requirements
Basic Structure Remains the Same
Single Audit Threshold Changes
Changes in the Type A/B Program Thresho...
Additional Considerations
Uniform Guidance provides for a government-wide audit
quality project once every 6 years beginni...
GASB UPDATES
GASB Statements
Major Projects
Practice Issues
Pre-Agenda Research
13
Effective Dates – June 30
• 2016
• Statement 72 – fair value measurement and application
• Statement 76 – GAAP hierarchy
•...
Statement 72: Fair Value Measurement
and Application
Statement Summary
• Defines Fair Value
• Describes measurement techni...
Investment Measurement (Fair Value
Application)
16
• Fair value is the price
that would be received
to sell an asset or pa...
Fair Value Hierarchy
The fair value hierarchy categorizes the inputs to valuation
techniques used to measure fair value in...
Valuation Approaches
Apply valuation approach(s) that best represent fair value in the
circumstances using one of the thre...
Investment Measurement (Fair Value
Application)
Assets that meet the definition of an Investment should be
reported at Fai...
Investment Measurement (Fair Value
Application)
• Investments Not Reported at Fair Value
• MM investments and participatin...
Required Disclosures
21
• The fair value measurement at year end
• The level of the fair value hierarchy (level 1, 2, 3)
•...
Standard Note Disclosure for Fair Value
Narrative Format
NOTE 2 –Fair Value Measurements
The City categorizes its fair val...
Standard Note Disclosure for Fair Value
23
Tabular Format
NOTE 2 –Fair Value Measurements
The Plan categorizes its fair va...
GAAP Hierarchy: Statement 76
• Effective for periods beginning after June 15, 2015
• Revised Comprehensive Implementation ...
GAAP Hierarchy: Statement 76
• 2 Categories of Authoritative Guidance
• Category A
• GASB Statements
• Formerly issued Int...
GAAP Hierarchy: Statement 76
Authoritative GAAP
Category A must meet
ALL of the following:
• Formally approved
by the Boar...
GAAP Hierarchy: Statement 76
NonAuthoritative
27
If no authoritative GAAP
exits:
• Consider authoritative
GAAP for similar...
Accounting and Financial Reporting for
Postemployment Benefits Other Than
Pensions- GASB 75
• What: GASB Issued Statement ...
Accounting and Financial Reporting for
Postemployment Benefits Other Than
Pensions- GASB 75
• Key Points
• Employers will ...
Accounting and Financial Reporting for
Postemployment Benefits Other Than
Pensions- GASB 75
New disclosure requirement for...
Tax Abatement Disclosures: Statement 77
• Transaction must meet this definition:
A reduction in tax revenues that results ...
Tax Abatement Disclosures: Statement 77
Key Points:
• A principal distinction between tax abatements and other tax
expendi...
Tax Abatement Disclosures: Statement 77
• General Disclosure Principles
• A government should disclose information separat...
Tax Abatement Disclosures: Statement 77
34
Descriptive
Information
Government’s Own
Abatements
Other Government’s
Abatemen...
Tax Abatement Disclosures: Statement 77
35
Other Disclosures Government’s Own
Abatements
Other Government’s
Abatements
Dol...
Standard Setting Process
• Pre-Agenda Research
• Added to Agenda
• Initial Deliberations
• Preliminary Views (PV)
• Follow...
MAJOR PROJECTS
37
Asset Retirement Obligations
• What: GASB is considering establishing accounting and
financial reporting standards for leg...
Fiduciary Activities
• What: GASB reviewing the standards that clarify when a
government has a fiduciary responsibility an...
Financial Reporting Model-
Reexamination of Statements 34, 35, 37,
41 and 46 and Interpretation 6
• What: In September of ...
Leases – Reexamination of NCGA
Statement 5 and GASB statement 13
• What: GASB is redeliberating its proposed revisions to
...
PRACTICE ISSUES
42
Blending Requirements for Certain
Component Units
• What: GASB proposed revising the standards regarding
how certain compo...
Certain Debt Extinguishments Using
Existing Resources
• What: The GASB is considering improvement to the
existing guidance...
Other Practice Issues
• Implementation Guidance- Update
• Currently in ED Rediliberations
• Implementation Guide for State...
Pre-Agenda Research
• Debt Disclosures, including Direct Borrowing
• Reexamination of Statements 34, 38 and 62
• Going Con...
Questions
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Governmental Updates - Uniform Guidance and GASB

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Heinfeld Meech & Co. - State and Local Government Conference (Tempe, 1/28/2016)

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Governmental Updates - Uniform Guidance and GASB

  1. 1. GOVERNMENTAL UPDATES: UNIFORM GUIDANCE (UG) AND GASB Presented by Brittney Williams, CPA, CGFM Heinfeld, Meech & Co., P.C.
  2. 2. Agenda 2 • Uniform Guidance (UG) Refresher • GASB Updates • New GASB Pronouncements • Major Projects • Practice Issues • Pre-Agenda Research
  3. 3. Part 200 – UniformAdministrative Requirement, Cost Principles, andAudit Requirements for FederalAwards Subpart A - Acronyms and 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 3
  4. 4. Objectives Goals of COFAR based on guidance from Executive Office • Streamline guidance for Federal awards to ease administrative burden • Strengthen oversight over Federal funds to reduce risks of waste, fraud and abuse • Eliminate duplicative and conflicting guidance • Focus on performance over compliance for accountability • Use of grant agreements, cooperative agreements and contracts including provisions for fixed amount awards • Encourage efficient use of information technology and shared resources • Provide for transparent and consistent treatment of costs • Limit allowable costs to make the best use of Federal dollars • Setting standard business processes using data definitions • Encourage non-Federal entities to have family friendly policies • Strengthen oversight • Target audit requirements on risk of fraud, waste and abuse 4
  5. 5. Post-Award Requirements Internal Controls (Section 200.303) • Moved from audit requirements to post-award requirements • Organization must establish and maintain effective internal control over Federal awards to provide reasonable assurance that awards are being managed in compliance with laws and regulations • Internal controls should be in compliance with COSO and the Standards for Internal Control in the Federal Government (the “Green Book”) • Must take prompt action when noncompliance is identified • Must take reasonable measures to safeguard personally identifiable information and other information deemed sensitive 5
  6. 6. Post-Award Requirements Procurement (Section 200.318) • “Integrity Rules” • Must maintain written standards of conduct covering conflicts of interest with respect to employees engaged in the selection, award, and administration of contracts, including disciplinary actions for violations • No real or apparent conflicts of interest permitted • Must maintain written standards of conduct covering organizational conflict of interest for affiliates of subsidiary organizations • Mandatory disclosure requirements for violations • Non-Federal entities may set standards for non-substantial interests or gifts of nominal value 6
  7. 7. Post-Award Requirements Procurement (Section 200.318) • Must avoid acquisition of unnecessary or duplicative items • Encourages the use of excess or surplus property • Encourages the use of inter-entity agreements • Must maintain records sufficient to detail the history of the procurement • Must maintain oversight to ensure contractors perform the terms and conditions of contract • “Federal agency will not substitute its judgment for that of the non-Federal entity unless the matter is primarily a Federal concern” 7
  8. 8. Cost Principles Indirect Cost Rates (Section 200.414) • Non-Federal entities that have never had a negotiated indirect cost rate may use a de minimis rate of 10% • Must use the 10% de minimis rate on all awards until negotiated • Costs must be consistently charged and may not be double charged in order to utilize the de minimis rate • The SEFA must include a note as to whether or not the entity elected to use the 10% de minimis indirect cost rate 8
  9. 9. Cost Principles Other Revisions • Measures to safeguard personal and sensitive information • Encouragement of family-friendly policies • Conference hosts must ensure conference costs managed in manner to minimize costs to Federal award • Definition of supplies clarified to include computer equipment with an acquisition cost of less than $5,000 • Computer equipment may be charged as a direct cost if essential to performance of a Federal award, even if it is not solely dedicated to an award cost objective • Annual reports and payment requests must include a certification by an authorized official 9
  10. 10. Cost Principles Required Certification “By signing this report, I certify to the best of my knowledge and belief that the report is true, complete, and accurate, and the expenditures, disbursements and cash receipts are for the purposes and objectives set forth in the terms and conditions of the Federal award. I am aware that any false, fictitious, or fraudulent information, or the omission of any material fact, may subject me to criminal, civil or administrative penalties for fraud, false statements, false claims or otherwise. (U.S. Code Title 18, Section 1001 and Title 31, Sections 3729–3730 and 3801–3812).” 10
  11. 11. Audit Requirements Basic Structure Remains the Same Single Audit Threshold Changes Changes in the Type A/B Program Threshold Changes to the risk assessment of the Type A/B Programs Percentage of Coverage Rule adjustment Changes to the risk assessment of the entity Changes for reporting audit findings DCF Changes 11
  12. 12. Additional Considerations Uniform Guidance provides for a government-wide audit quality project once every 6 years beginning in 2018 Included language to allow for future combining of the audit reporting and the data collection form OMB to evaluate implementation of guidance against previously developed metrics Reduction of compliance requirements may be revisited in the future Possible new COFAR guidance 12
  13. 13. GASB UPDATES GASB Statements Major Projects Practice Issues Pre-Agenda Research 13
  14. 14. Effective Dates – June 30 • 2016 • Statement 72 – fair value measurement and application • Statement 76 – GAAP hierarchy • 2017 • Statement 73 – pensions not within the scope of Statement 68 and amendments to Statements 67 and 68 • Statement 74 – financial reporting by OPEB plans • Statement 77 – tax abatement disclosures • 2018 • Statement 75 – OPEB accounting for employers and nonemployer contributing entities 14
  15. 15. Statement 72: Fair Value Measurement and Application Statement Summary • Defines Fair Value • Describes measurement techniques, approaches • Describes what should be reported at fair value • Describes what should be disclosed for fair value measurements 15
  16. 16. Investment Measurement (Fair Value Application) 16 • Fair value is the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date. Fair Value
  17. 17. Fair Value Hierarchy The fair value hierarchy categorizes the inputs to valuation techniques used to measure fair value into three levels. • Level 1 inputs are quoted prices (unadjusted) for identical assets or liabilities in active markets that a government can access at the measurement date. • Level 2 inputs are inputs-other than quoted prices included within Level 1-that are observable for an asset or liability, either directly or indirectly. • Level 3 inputs are unobservable inputs for an asset or liability. 17
  18. 18. Valuation Approaches Apply valuation approach(s) that best represent fair value in the circumstances using one of the three approaches: Market approach: Uses prices and other relevant data derived from market transactions for identical or similar assets, liabilities, or a group of assets and liabilities. Cost approach: Reflects the amount that would be required currently to replace the present service capacity of an asset. Income approach: Converts future amounts to a single discounted amount. The fair value measurement would also reflect any current market expectations for future amounts. 18
  19. 19. Investment Measurement (Fair Value Application) Assets that meet the definition of an Investment should be reported at Fair Value • Alternative investments • Equity securities, stock warrants, and stock rights that don’t have readily determinable fair values • Commingled investment pools that are not government sponsored • Intangible assets • Land and land rights • Real estate If they meet the definition • Lending assets of an investment • Natural resource assets 19
  20. 20. Investment Measurement (Fair Value Application) • Investments Not Reported at Fair Value • MM investments and participating interest-earning investment contracts that have a remaining maturity at time of purchase of one year or less, reported by governments other than external investment pools • Investments in 2a7-like pools (LGIP) • Investments in life insurance • Investments in common stock that meet the criteria for applying the equity method • Non-participating interest earning investment contracts • Unallocated insurance contracts • Synthetic guaranteed investment contracts that are fully benefit responsive 20
  21. 21. Required Disclosures 21 • The fair value measurement at year end • The level of the fair value hierarchy (level 1, 2, 3) • A description of the valuation technique used in the fair value measurement • If there has been a change in the valuation technique that has a significant impact on the result Recurring fair value measurements • The reason for the measurement Nonrecurring fair value measurements
  22. 22. Standard Note Disclosure for Fair Value Narrative Format NOTE 2 –Fair Value Measurements The City categorizes its fair value measurements within the fair value hierarchy established by generally accepted accounting principles. The hierarchy is based on the valuation inputs used to measure the fair value of the asset. Level 1 inputs are quoted prices in active markets for identical assets; Level 2 inputs are significant other observable inputs; Level 3 inputs are significant unobservable inputs. The City has the following recurring fair value measurements as of June 30, 20X1: • U.S. Treasury securities of $45 million are valued using quoted market prices (Level 1 inputs) • Corporate bonds of $12 million are valued using a matrix pricing model (Level 2 inputs). The City also has a nonrecurring fair value measurement as of June 30, 20X1, for a closed performing arts hall that will no longer be used by the government and therefore is considered to be impaired. The hall has been written down from $5.6 million to $3.4 million based on an appraisal of the property (Level 3 inputs). 22
  23. 23. Standard Note Disclosure for Fair Value 23 Tabular Format NOTE 2 –Fair Value Measurements The Plan categorizes its fair value measurements within the fair value hierarchy established by generally accepted accounting principles. The Plan has the following recurring fair value measurements as of December 31, 20X1:
  24. 24. GAAP Hierarchy: Statement 76 • Effective for periods beginning after June 15, 2015 • Revised Comprehensive Implementation Guide • Highlights • The hierarchy of generally accepted accounting principles (GAAP hierarchy) comprises the types of guidance that state and local governments follow when preparing financial statements • The GAAP hierarchy lists the order of priority for pronouncements to which a government should look for guidance • Statement 76 reduces the GAAP hierarchy to 2 categories of authoritative GAAP • Previously 4 categories under GASB Statement 55 24
  25. 25. GAAP Hierarchy: Statement 76 • 2 Categories of Authoritative Guidance • Category A • GASB Statements • Formerly issued Interpretations • Category B • GASB Technical Bulletins • GASB Implementation Guides (Q&As) • AICPA literature cleared by the GASB • Nonauthoritative 25
  26. 26. GAAP Hierarchy: Statement 76 Authoritative GAAP Category A must meet ALL of the following: • Formally approved by the Board • For the purpose of creating, amending, superseding, or interpreting standards • Exposed for a period of public comment Category B must meet ALL of the following: • Restricted to providing limited clarification • Cleared by the Board • Specifically made applicable to s&l governmental entities • Exposed for a period of public comment 26
  27. 27. GAAP Hierarchy: Statement 76 NonAuthoritative 27 If no authoritative GAAP exits: • Consider authoritative GAAP for similar transactions • If no analogy possible, may consider nonauthoritative literature that does not conflict or contradict authoritative GAAP Consider all of the following: • Consistency with the GASB Concepts Statements • Relevance to particular circumstances • Specificity of the guidance • General recognition of the issuer or author as an authority Sources: • GASB Concepts, FASB, FASAB, PSASB, IASB • AICPA literature • Widely used practices in S&L government • Literature of other professional associations/regulatory agencies
  28. 28. Accounting and Financial Reporting for Postemployment Benefits Other Than Pensions- GASB 75 • What: GASB Issued Statement 74 (plans) and 75 (employers), making OPEB accounting and financial reporting consistent with the pension standards in GASB Statements 67 and 68 • Why: Pension and OPEB standards were updated subsequent to a review of the effectiveness of the standards- objective was to establish a consistent set of standards for all postemployment benefits, providing more transparent reporting of the liability and more useful information about the liability and costs of benefits. • When: Effective for periods beginning after June 15, 2016 (plans) and June 15, 2017 (employers) 28
  29. 29. Accounting and Financial Reporting for Postemployment Benefits Other Than Pensions- GASB 75 • Key Points • Employers will have to report a net OPEB liability (total OPEB liability less fiduciary net position) on the accrual-based statement of net position. • Employer expense recognition will be separated from funding. • All employers will be required to sue the same actuarial cost allocation method for measurement, regardless of the actuarial method used for funding purposes. • Employers that participate in cost-sharing plans will be required to report their proportionate share of the net OPEB liability and expense of all participating employers. 29
  30. 30. Accounting and Financial Reporting for Postemployment Benefits Other Than Pensions- GASB 75 New disclosure requirement for Health-care trend rates. 1% decrease (8.5% decreasing to 4.5% Health-Care Cost Trend Rates (9.5% decreasing to 5.5%) 1% increase (10.5% decreasing to 6.5%) Net OPEB Liability (asset) 30 1% decrease Discount Rate 1% increase Net OPEB Liability (asset)
  31. 31. Tax Abatement Disclosures: Statement 77 • Transaction must meet this definition: A reduction in tax revenues that results from an agreement between one or more governments and an individual or entity in which (a) one or more governments promise to forgo tax revenues to which they are otherwise entitled and (b) the individual or entity promises to take a specific action after the agreement has been entered into that contributes to economic development or otherwise benefits the governments or the citizens of those governments. 31
  32. 32. Tax Abatement Disclosures: Statement 77 Key Points: • A principal distinction between tax abatements and other tax expenditures is the existence of an agreement with an individual or entity • The agreement generally is in writing but not necessarily • The agreement may or may not be legally enforceable • The agreement must precede the reduction of taxes and the recipient’s fulfillment of the promise to act • The tax reduction may occur before, during or after fulfilment of the promise- as long as it occurs after the agreement has been entered into 32
  33. 33. Tax Abatement Disclosures: Statement 77 • General Disclosure Principles • A government should disclose information separately for: • Its own tax abatements • Tax abatements that are entered into by other governments that reduce the reporting government’s tax revenues • Disclosure information may be presented for individual agreements or may be aggregated: • Its own abatements –organized by major tax abatement program • Other government abatement- Organized by the government entering into the abatements and the specific taxes being abated • Disclosure should commence in the period in which a tax abatement agreement is entered into and continue until the tax abatement agreement expires: 33
  34. 34. Tax Abatement Disclosures: Statement 77 34 Descriptive Information Government’s Own Abatements Other Government’s Abatements Name of program X Purpose of program X Name of government X Tax being abated X X Authority to abate taxes X Eligibility criteria X Abatement mechanism X Recapture provisions X Types of recipient commitments X
  35. 35. Tax Abatement Disclosures: Statement 77 35 Other Disclosures Government’s Own Abatements Other Government’s Abatements Dollar amount of taxes abated X X Amounts received or receivable from other governments associated with abated taxes X X Other commitments by the government X Quantitative threshold for individual disclosure X X Information omitted due to legal prohibitions X X
  36. 36. Standard Setting Process • Pre-Agenda Research • Added to Agenda • Initial Deliberations • Preliminary Views (PV) • Followed by a comment period • Exposure Draft (ED) • Followed by a comment period • Exposure Draft Redeliberations • Final Pronouncement 36
  37. 37. MAJOR PROJECTS 37
  38. 38. Asset Retirement Obligations • What: GASB is considering establishing accounting and financial reporting standards for legal obligation to retire certain capital assets such as nuclear power plants. • Why: Existing standards (Statement 18) address only municipal landfills but governments have retirement obligations for other types of capital assets. • When: Exposure Draft has been issued and the comment period ends 3/31/16 38
  39. 39. Fiduciary Activities • What: GASB reviewing the standards that clarify when a government has a fiduciary responsibility and is required to present fiduciary fund financial statements. • Why: Existing standards require reporting of fiduciary responsibilities but to not define what they are; use of private purpose trust funds and agency funds is inconsistent; business-type activities are uncertain about how to report fiduciary activities. • When: Exposure Draft has been issued, comment period ends 3/31/16 39
  40. 40. Financial Reporting Model- Reexamination of Statements 34, 35, 37, 41 and 46 and Interpretation 6 • What: In September of 2015, the Board added a project to the agenda to examine the effectiveness of the financial reporting model. • Why: The GASB is committed to ensuring standards remain effective; most of the requirements of Statement 34 became effective between 2002 and 2004 • When: Currently in initial deliberations. A due process document is expected by the end of 2016. The project is projected to extend into 2020/2021. • Potential Areas of Improvement • MD&A • GW • Major Funds • Governmental Fund f/s • Proprietary/BTA f/s • Extraordinary and special items • Fiduciary f/s • Budgetary comparisons 40
  41. 41. Leases – Reexamination of NCGA Statement 5 and GASB statement 13 • What: GASB is redeliberating its proposed revisions to existing standards on lease accounting and financial reporting based on the 2014 preliminary views. • Why: The existing standards have been in effect for decades without review to determine appropriateness. FASB and IASB have been conducting a joint project to update their lease standards. Opportunity to increase comparability and usefulness of information and reduce complexity for preparers. • When: ED expected 1st Q of 2016 41
  42. 42. PRACTICE ISSUES 42
  43. 43. Blending Requirements for Certain Component Units • What: GASB proposed revising the standards regarding how certain component units should be presented in the financial statements of the primary government. • Why: There is diversity in practice, with some component units. • Final Pronouncement due Q1 2016 43
  44. 44. Certain Debt Extinguishments Using Existing Resources • What: The GASB is considering improvement to the existing guidance related to all types of debt extinguishments. • Why: The project is intended to resolve certain issues in the existing guidance and provide improvements. • ED is expected in August 2016, currently in initial deliberations 44
  45. 45. Other Practice Issues • Implementation Guidance- Update • Currently in ED Rediliberations • Implementation Guide for Statements 74 and 75 on OPEB • Initial deliberations • Irrevocable Split – Interest Agreements • ED issued in June 2015, currently in rediliberations • Pension Issues • ED issued in December 2015, currently in rediliberations • User Guides- Updates • Added to agenda 45
  46. 46. Pre-Agenda Research • Debt Disclosures, including Direct Borrowing • Reexamination of Statements 34, 38 and 62 • Going Concern Disclosures • Reexamination of Statement 56 • Revenue Recognition for Exchange and Exchange-Like Transactions • Reexamination of Specific Statement 62 Provisions 46
  47. 47. Questions

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