OMB Super-Circular Proposal FPP Agenda Item February 8, 2013

OMB Proposal Released On January 31, 2013, the Office of Management and Budget (OMB) released its: “Proposed OMB Uniform Guidance: Cost Principles, Audit, and Administrative Requirements for Federal Awards” This notice of proposed guidelines is a detailed, 244-page document that consolidates a number of key cost circulars covering the federal cost principles (A-87), the federal administrative rules (A-102), and non-federal audits (A-133) 2

OMB Proposal Released (cont.) OMB also provided an 89-page summary and description of the changes from the notice released last February. The documents are posted on www.regulations.gov under docket number OMB-2013-0001 Interested parties may submit comments for 90 days (until April 30th) to the above website. 3

Super-Circular This proposal would streamline the language from eight existing OMB circulars into one document. Subchapter A – General Provisions Subchapter B – Pre-award Requirements Subchapter C – Federal Award Notice Subchapter D – Inclusion of Terms and Conditions Subchapter E – Post Federal Award Requirements Subchapter F – Cost Principals Subchapter G – Audit Requirements Subchapter H - Appendices 4

Single Audit Threshold Among the issues of intense interest to the grants community are changes to the single audit requirements. One of the most significant proposals would raise the threshold for single audits from $500,000 to $750,000. The original OMB proposal was for a $1 million threshold. 5

Other Single Audit Changes Major Program Determination: This proposal includes changes to all four steps of the risk-based approach to focus on the areas of highest risk and reduce the number of major programs tested. Streamlining of the Compliance Supplement: May cut back on number of types of compliance requirements, but those may move under “Special Tests and Provisions” 6

Time and Effort Documentation Now titled, “Documentation of Personnel Expenses” Uses language from a number of applicable circulars and combine them into a single set of requirements. The type of documentation completed is still dependent on the number of cost objectives worked on by the employee. We will need to review how the recent U.S. Department of Education guidance matches up with this guidance. 7

Informational Webinar The Council on Financial Assistance Reform (COFAR) will be hosting an informational webinar on the proposed guidance with members of the grant community today (2-8-13). However, a recorded version will be available for later viewing. www.cfo.gov/cofar 8