This document summarizes a presentation about the Uniform Guidance, also known as the "Super Circular", which consolidates and streamlines eight federal regulations into a single policy guide. The Super Circular aims to eliminate duplicative guidance, focus on performance over compliance, provide consistent treatment of costs, and strengthen oversight. It is effective December 26, 2014 and applies to new awards and additional funding to existing awards after that date. Key changes include new pre-award processes, the addition of fixed-price awards, revisions to procurement rules, changes to indirect cost rules, increased internal controls, updates to time and effort rules, and more stringent integrity rules around conflicts of interest and mandatory disclosure.
Uniform Grant Guidance: Preparing Your Organization for ComplianceStreamLinkSoftware
(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.
This informative presentation sheds light on the new Uniform Administrative Requirements, Cost Principles and Audit. It covers new and updated regulations;
1.
Introduction
2.
Subpart A -Acronyms and Definitions (200.0 series)
3.
Subpart B -General Provisions (200.100 series)
4.
Subpart C -Pre-Federal Award Requirements and Contents of Federal Awards (200.200 series)
5.
Subpart D -Post Federal Award Requirements (200.300 series)
6.
Subpart E -Cost Principles (200.400 series)
7.
Subpart F -Audit Requirements (200.500 series)
8.
Appendix I-XI
The OMB has put out new direction on how those organizations receiving federal grants handle reporting. Smith & Gesteland presented a seminar explaining the basics of what has been referred to as The Super Circular.
Uniform Grant Guidance: Preparing Your Organization for ComplianceStreamLinkSoftware
(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.
This informative presentation sheds light on the new Uniform Administrative Requirements, Cost Principles and Audit. It covers new and updated regulations;
1.
Introduction
2.
Subpart A -Acronyms and Definitions (200.0 series)
3.
Subpart B -General Provisions (200.100 series)
4.
Subpart C -Pre-Federal Award Requirements and Contents of Federal Awards (200.200 series)
5.
Subpart D -Post Federal Award Requirements (200.300 series)
6.
Subpart E -Cost Principles (200.400 series)
7.
Subpart F -Audit Requirements (200.500 series)
8.
Appendix I-XI
The OMB has put out new direction on how those organizations receiving federal grants handle reporting. Smith & Gesteland presented a seminar explaining the basics of what has been referred to as The Super Circular.
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As part of the push for federal grant reform, the U.S. Office of Management and Budget (OMB) recently finalized changes to Circular A-133, Audits of States, Local Governments, and Non-Profit Organizations. The OMB released the changes in December 2013 in its guidelines, “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards” (Uniform Grant Guidance).
The final phase of the Office of Management and Budget’s Uniform Grant Guidance is nearly here, which means nonfederal agencies should be gearing up for the changes coming to their Single Audits.
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Join Mary Jo Dolson, Amy Gibson and Mark Thomas of Skoda Minotti’s State and Local Tax team for an informative discussion on state and local tax issues facing the real estate and construction industry.
As part of the push for federal grant reform, the U.S. Office of Management and Budget (OMB) recently finalized changes to Circular A-133, Audits of States, Local Governments, and Non-Profit Organizations. The OMB released the changes in December 2013 in its guidelines, “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards” (Uniform Grant Guidance).
The final phase of the Office of Management and Budget’s Uniform Grant Guidance is nearly here, which means nonfederal agencies should be gearing up for the changes coming to their Single Audits.
2018 Community Health Center Accounting Standards UpdateJones & Roth
In this session, we will discuss several sweeping accounting standards updates that will specifically affect Community Health Centers. Specifically, there are three new upcoming standards updates that will require changes in financial reporting and presentation; recording of leases, revenue recognition from contracts, and changes in financial statement presentation for non-profit organizations.
Baker Tilly Presents: Government Contract Reporting Requirements: What did yo...BakerTillyConsulting
Presented at NCMA's World Congress 2016
Presenters: Baker Tilly's Nathan Geesaman, CPA, CFE, Manager and Accenture Federal Services' Katherine Adams, Senior Contract Manager.
For U.S. federal government contractors, there are myriad contractual reporting requirements that must be submitted to the government beyond the annual ICS submitted to DCAA. Contract managers must understand and communicate what is required in order to comply with the terms of the contract. This session will discuss some of these government reporting requirements, such as small business subcontracting, government property, service contracts, eCMRA, GSA Schedules, GWACs, and CPARS. www.bakertilly.com/governmentcontractors
B2G Seminar Slides for Get in the Game. Sponsored by Whittaker-Cooper Financial Group. Presented by Jack Quinn Solutions, LLC and Space Coast Entrepreneurs
This presentation provides an update on both recently issued and forthcoming pronouncements of the Financial Accounting Standards Board (FASB). Through this presentation, you should be able to identify what changes are effective for your 2015 financial statements, including changes you may choose to early adopt.
Dynamic Changes Occurring: OMB's Uniform Grant GuidanceStreamLinkSoftware
At this year’s National Association of State Auditors, Comptrollers and Treasurers (NASACT) Annual Conference in Chicago, Illinois, StreamLink Software CEO, Adam Roth, and partner at accounting firm Plante Moran, Michelle Watterworth, presented on UGG’s impact on grant administration and audits.
All entities will have to reevaluate their revenue recognition processes when the Financial Accounting Standard Board (FASB)’s Accounting Standard Update (ASU) 2014-09, Revenue from Contracts with Customers (Topic 606) is adopted, beginning with those early adopting in 2017.
SEC Adopts Enhanced Compensation and Corporate Governance Proxy Disclosure Rules for 2010 Proxy Season
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Robert Belcher and Ken Conner co-presented this PowerPoint at the 2012 RocketCity GovCon Conference hosted by Solvability in Huntsville, Ala. on Sept. 20, 2012.
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Additionally, we will discuss if your organization can thrive without the latest technology, whether your IT team is doing what they should be, how your IT infrastructure measures up to best practices, and what technology you may be missing out on.
3. AGENDA
•
What Is It and When Is It Effective?
•
New Pre-award Processes
•
Fixed-Price Awards
•
Revisions to the Procurement Rules
•
Changes to the Indirect Cost Rules
•
Increase of Internal Controls
•
Updates to the Time and Effort Rules
•
Focusing and Improving Transparency of Single Audits
•
More Stringent Integrity Rules
–
Conflicts of Interest
–
Mandatory Disclosure
3
4. THE SUPER CIRCULAR – WHAT IS IT?
•
The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards ─ more commonly Known as the “Super Circular” (codified at 2 CFR Part 200)
•The Super Circular consolidates and streamlines eight Federal regulations (including OMD Circulars A-110, A-122, and A-133) into a single, comprehensive policy guide
•Among other things, the Super Circular aims to:
–Eliminate duplicative and conflicting guidance
–Focus on performance over compliance for accountability
–Provide for consistent and transparent treatment of costs
–Strengthen oversight
–Reduce waste, fraud, and abuse
•What this equates to is a more formal, contract-like set of rules
4
5. WHEN IS THE SUPER CIRCULAR EFFECTIVE?
FEDERAL AGENCIES MUST IMPLEMENT THE REQUIREMENTS TO BE EFFECTIVE BY DECEMBER 26, 2014
AUDIT REQUIREMENTS WILL APPLY TO AUDITS OF FISCAL YEARS BEGINNING ON OR AFTER DECEMBER 26, 2014
ADMINISTRATIVE REQUIREMENTS AND COST PRINCIPLES WILL APPLY TO NEW AWARDS AND TO ADDITIONAL FUNDING (FUNDING INCREMENTS) TO EXISTING AWARDS MADE AFTER DEC 26.
EXISTING FEDERAL AWARDS WILL CONTINUE TO BE GOVERNED BY THE TERMS AND CONDITIONS OF THE FEDERAL AWARD, EXCEPT FOR AUDIT AS SUBPART F IS BASED ON 12/26/2014 FISCAL YEAR DATE.
5
6. NEW PRE-AWARD PROCESSES
•
Increased uniformity aimed at standardization in awarding process
•
99 Standard Definitions
–
Example: “Contractor” is used rather than “Vendor”
–
Standard definitions provide potential for standardization, but may also create uncertainty if the terms are interpreted differently in different settings
•
Standard application requirements
–
Federal awarding agencies must not impose additional or inconsistent requirements, unless
•
Based on Federal statue, regulation, or Executive Order
•
OMB approves information in the Federal award in accordance with id. § 200.210
•15 Standard data sets once awarded, see id. § 200.210
6
7. FIXED-PRICE AWARDS
•
Super Circular citations – 200.45, 200.201 and 200.332
•
Considered a “grant” where funder provides specific level of support without regard to actual costs
•
Option in addition to grant, cooperative agreement, and contract – either by government or pass-through entity
•
Accountability based on performance and results
•
Award amount negotiated using cost principles or “ other pricing information”
•
No government review of actual costs
7
8. FIXED-PRICE AWARDS (CONTINUED)
•
Cannot be used if there is mandatory cost sharing/match
•
Can only be used if adequate cost or unit pricing data to assure that non-Federal entity will realize no profit
•
At end of project, non-Federal entity must provide written assurance that project was completed or level of effort expended
–
Periodic reports may also be required
8
9. FIXED – PRICE SUBAWARDS
•
Require prior written approval from Federal awarding agency
•
Cannot be more than Simplified Acquisition Threshold (currently $150,000)
•
Must otherwise meet requirements in 200.201
9
10. PROCUREMENT
•
Super Circular citation: 200.318 through 200.326
•
Greatly expanded from A-110 (and generally more onerous)
•
Major changes
–
New provision covering conflict of interests with parent, affiliate, or subsidiary organizations
–
Procurement records must be maintained sufficiently to detail the history of procurement (used to be only procurements over small purchase threshold)
–
New provision on time and material contracts
–
Competition!
•
The words “to the maximum extent practical” are GONE
10
11. PROCUREMENT (CONTINUED)
•
Five methods prescribed in great detail
–
Procurement by micro-purchase
–
Procurement by small purchase
–
Procurement by sealed bids (formal advertising)
–
Procurement by competitive proposal
–
Procurement by noncompetitive proposal
•
Contracting with small and minority businesses, women’s business enterprises, and labor surplus area firms
–
“Positive efforts… whenever possible” changed to “ must take all necessary affirmative steps to assure”
11
14. CHANGES TO THE INDIRECT COST RULES
•
Federal agencies must accept negotiated indirect cost rates, id. § 200.414
-
Allows deviation from negotiated rates in limited circumstances:
•
Pursuant to statute or regulation
•
When approved by the Federal awarding agency head based on a written justification
•
Must be pursuant to a publicly established policy and criteria for using other than negotiated rates
•
Must provide notice in the grant announcement
•
Requires notice to OMB
•
Requires pass-through entities( e.g., states and local governments) to honor a nonprofit’s negotiated indirect cost rates or negotiate a rate
-
Significant change because in the past, many state and local governments simply did not pay indirect costs
14
15. CHANGES TO THE INDIRECT COST RULES (CONTINUED)
•
Nonprofits
–
Empowered to elect an automatic indirect cost rate of 10%, which can be used indefinitely
–
Alternatively, can negotiate a higher rate
–
Allows nonprofits to choose a course that makes the most business sense for the organization
•
Indirect or direct?
–
In certain circumstances, program administration costs(e.g., secretarial staff dedicated to a specific program) can be counted as direct costs
–
In the past, in some instances, grantees were required to pass these charges on via their indirect cost rates
15
16. INCREASE OF INTERNAL CONTROLS
•
Internal Controls, id. § 200.303
–
OMB highlighted the internal control requirements of the Super Circular as “extremely important””
–
Requirements moved from A-133, and include a broad direction to comply with Federal and state law, the “Standards for Internal Control in the Federal Government” issued by the Comptroller General ( the “ Green Book”), and the “Internal Control Integration Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commissions
–
Non-federal entities must exercise judgment in crafting internal control mechanisms for their specific programs that were compliant
•
Suggested Guidance
–
Develop a plan for monitoring spending: Did you spend the money the way you said you would?
–
Develop a plan of action for when irregularities occur
16
17. UPDATES TO THE TIME AND EFFORT RULES
•
A-122 previously required grantee to maintain written records of employees’ activities used to document an employee’s time as an allowable cost
•
Specific support for salaries and wages included:
–
After-the-fact determination of actual activity for each employee, not the budgeted amount;
–
Total activity for which employees were compensated;
–
Signed by individual employees or responsible supervisor with firsthand knowledge; and
–
Prepared at least monthly to coincide with one or more pay periods.
•
Now, grantee must meet broad objectives for allowability; specific time and effort documentation is not required. See id. § 200.430(i).
–
Must conform to non-Federal entity’s written policies, be reasonable, and meet Standards for Documentation of Personnel Expenses. See § 200.430(i).
•
Emphasis on system for internal control
–
Potential for negative audit findings and qui tam suits
17
18. UPDATES TO THE TIMES AND EFFORT RULES (CONTINUED)
•
TNC’s system
–
Every employee from CEO to preserve assistant
–
Actual time worked every day
–
No estimates except in very limited circumstances
•
Vacation time
•
Planned medical leave
•
Needs of payroll (timing of submission of reports)
•
Changes for nonprofits from A-122
–
Budget estimates (estimates determined before services performed) may be used for changes to awards, BUT… (see next slide)
18
19. UPDATES TO THE TIMES AND EFFORT RULES (CONTINUED)
–
System for estimating must produce “ reasonable approximations” of activity actually performed:
–
Significant changes in work activity (as defined in written policies) are identified and entered into records timely (one- or two- month fluctuations between workload categories are okay as long as distribution is reasonable over longer term); and
–
Must be a process to review the charges made based on budget and adjustments after the fact so that “ the final amount charged to the Federal award is accurate, allowable, and properly allocated.”
19
20. SELECTED ITEMS OF COST
200.422 - ADVISORY COUNCILS
These costs are still allowable if authorized by statute or with prior approval from the Federal awarding agency.
200.428 COLLECTIONS OF IMPROPER PAYMENTS (NEW)
The costs incurred by a non-Federal entity to recover improper payments are allowable as either direct or indirect costs, as appropriate.
20
21. SELECTED ITEMS OF COST
200.431 – COMPENSATION – FRINGE BENEFITS
•
GAAP for accrual based accounting
•
Mass severance
•
Excessive severance pay
•
Family friendly leave
200.432 – CONFERENCES
•
Requires conference hosts/sponsors to exercise discretion and judgment in ensuring that conference costs are appropriate, necessary and managed in a manner that minimizes costs to the Federal award.
•
Allows costs of finding local dependent care
21
22. SELECTED ITEMS OF COST
200.438 – ENTERTAINMENT COSTS
•
Unallowable unless
1.
Those costs have a programmatic purpose and are authorized in the approved budget for the federal award, or
2.
Those costs have prior written approval from the federal awarding agency
200.440 – EXCHANGE RATES (NEW)
Allows for cost increases from fluctuations in exchange rates with certain conditions being met and of course, the availability of funds.
200.449 – INTEREST
•
Paragraph (b)(2) establishes the date of January 1, 2016, as the date that non-federal entities whose fiscal year starts on or thereafter may be reimbursed for financing costs associated with patents and computer software . 22
23. SELECTED ITEMS OF COST
200.464 – RELOCATION COSTS OF EMPLOYEES
•
Limits the previously unlimited amount of time for which a Federal award may be charged for the costs of an employee’s vacant home to up to six months.
200.474 – TRAVEL COSTS
•
Provides that temporary dependent care costs that result directly from travel to conferences and meet specified standards are allowable.
23
24. FOCUSING AND IMPROVING TRANSPARENCY OF SINGLE AUDITS
•
Raises the threshold for compliance audits from $500,000 per fiscal year to $750,000 per fiscal year, id. § 200.501
–
Right-sizing of threshold to focus government’s attention where it is most needed to prevent waste, fraud and abuse
–
Another positive change for nonprofits, particularly smaller nonprofits and those that receive only small amounts of funding from the Federal government
–
Should reduce costs for these nonprofits
–
OMB estimates that approximately 5,000 organizations will be relieved from the audit requirement as a result of the higher threshold
•
Single audit reports will be available to the public online, id. § 200.512
24
25. CONFLICT OF INTEREST
•
Reporting Conflicts of Interest(“COI”), id. § 200.112
–
Section 200.112 continues the practice of allowing agencies to establish their own COI policies that are “appropriately tailored to the specific nature of their programs”
•
Non-Federal agencies must disclose any COI to an awarding agency
–
Agencies must access COIs as part of their risk assessment
•
Requires reporting of Organizational Conflict of Interest(“OCI”)
–
Non-federal entities must have “strong policies preventing organizational conflicts of interest which will be used to protect the integrity of procurements under Federal awards and subawards.”
–
FAR Part 9.5 outlines the FAR OCI rules that may provide guidance
25
26. MANDATORY DISCLOSURE
•
Mandatory Disclosure, id. § 200.113
–
Requires organizations to disclose “ in a timely manner” and in writing “all violations of Federal criminal law involving fraud, bribery, or gratuity violations potentially affecting the Federal awards”
–
An organization’s failure to make the required disclosures can result in a number of actions, including suspension and/or debarment
26