The Office of Management and Budget’s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), was officially implemented by the Council on Financial Assistance Reform (COFAR), in December of 2014. Uniform Guidance is a framework for grants management, and supersedes guidance from earlier OMB circulars. Among other things, Uniform Guidance removes previous guidance that is conflicting, establishes standard language and lays the groundwork for Federal agencies to standardize the processing of data.
A lot of time, work and planning goes into getting your Federal Award. Now that you have the funds, additional time spent ensuring that you are in compliance with Uniform Guidance is an important step in ensuring that your project is successful, and that your audit, if required, goes well. Here are some general guidelines that award recipients should follow that will go a long way toward a favorable audit result.
Award Recipients should:
Review Subpart D – Post Federal Award Requirements, Standards for Financial and Program Management, Internal Controls (200.303) of Uniform Guidance (found here: http://www.grants.gov/web/grants/learn-grants/grant-policies/omb-uniform-guidance-2014.html) with emphasis on the following:
- Non-federal entities “must”
- Comply with federal statutes, regulations and terms of awards received, and establish and maintain effective internal control over federal awards that provides reasonable assurance of the compliance
- Evaluate and monitor the compliance
- Take prompt action when instances of non-compliance are identified, and
- Take reasonable measures to safeguard personally identifiable information and other sensitive information
- Internal control structure should be in compliance with Standards for Internal Control in the Federal Government (Green Book), issued by the Comptroller General of the United States and the Internal Control Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). However, it is not a requirement that the non-federal entity strictly follow the Green Book or the COSO Framework.
Award Recipients should not:
The two most notable mistakes that non-Federal entities make have to do with advance payments and budget revisions. Because grants can be paid in advance, procedures and controls that meet defined standards for fund control and accountability as established by the Code of Federal Regulations must be in place to minimize the time elapsing between the transfer of funds and disbursement of those funds by the grantee.
- Advance Payments
- Advance payments to a non-federal entity must be limited to the minimum amounts needed and be timed in accordance with the actual immediate cash requirements in carrying out the purpose of the approved program or project.
- The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements.
- The non-federal entity must make timely payments to contractors in accordance with contract provisions.
Approved budgets for Federal Awards summarize the financial aspects of the project or program as approved during the Federal Award process. Once again, procedures and controls governing revisions to the budget, and proper reporting of any revisions are key.
- Budget Revisions
- Award recipients are required to report deviations from budget, project scope or objective and request prior approvals from Federal awarding agencies for budget or plan revisions.
- Non-construction award recipients must request prior approval from Federal awarding agencies for one or more of the following program or budget-related reasons:
- Change in the scope or objective of the project or program
- Change in a key person specified in the application of the Federal award
- Disengagement from the project for more than three months or a 25% reduction in time devoted to the project by the approved project director or principal investigator.
- Changes in the approved cost sharing or matching provided by the grant recipient.
At Clausen & Associates, we know that your focus is the project that you received the Federal Award for---and not always compliance issues---so our team of experts is here to help. Clausen & Associates CPAs specializes in Program Specific and Compliance Audits, and would be honored to serve your audit and/or tax needs. Give us a call today at 303.678.5392, to discuss how we can help.
-Barb Clausen, Clausen & Associates CPA
A note from ReliAscent: Clausen & Associates CPA is a valued and trusted partner to ReliAscent. We highly recommend their audit and tax services to our clients, and all contractors/grantees. Should your business require a program specific or uniform guidance audit (or tax services), we urge you to contact Barb and the Clausen team---they are efficient, affordable, and extremely knowledgeable & capable. Should you have any questions about government contract and/or accounting compliance, audits, contract management or outsourced CFO services for contractors and grantees, please do not hesitate to contact ReliAscent.