On December 26, 2013, the Office of Management and Budget (OMB) Issued Uniform Grant Guidance. The Uniform Guidance combined eight previously separate sets of OMB guidance into one. OMB has eliminated about 80 pages of overlapping duplicative and conflicting provisions of guidance that were developed separately over many years.
Non-federal entities will need to implement the new administrative requirements and Cost Principles for all new federal awards made after December 26, 2014.
The new audit requirements become effective for fiscal years beginning on or after December 26, 2014.
You can get more information about the policies that have changed at:
The Uniform Guidance reduces administrative burden and risk of waste, fraud and abuse by:
- Eliminating duplicative and conflicting guidance
- Focusing on performance over compliance for accountability
- Encouraging efficient use of information technology and shared services
- Providing for consistent and transparent treatment of costs
- Limiting allowable costs to make the best use of Federal resources
- Setting standard business processes using data definitions
- Strengthening oversight
- Targeting audit requirements on risk of waste, fraud, and abuse
Some of the areas impacted by the change include:
- Use of “should” and “must”
- Should – best practice
- Must – required
- Subrecipient vs. Contractor
- look at the substance of the relationship
- Audit threshold increased from $500,000 to $750,000
- Reduces minimum audit coverage from 50% to %40 for non-low risk auditees
- Increases the threshold for known and likely questioned cost from $10,000 to $25,000
- Major program determination
- Reporting to Federal Audit Clearinghouse (FAC)
- Changes in reporting for the SEFA
We recommend you start planning now by:
- Ensure understanding of effective dates and new requirements
- Development plan to be compliant
- Include senior management
- Access available resources
- Train staff
posted by Drew Ulmer, CPA
