Uniform Guidance Audit: Overview, Timeline and Contacts RAS Friday - May 17th, 2019 Nuala McGowan, Sr. Director of Research Finance and Compliance, FAS Christyne Anderson, Manager, Training and Compliance, OSP

Agenda - Uniform Guidance (UG) Audit: What is it and why do we have one? What is tested in the UG Audit? Timeline of the Harvard University UG Audit Contacts

What is a UG Audit? Office of Management and Budget (OMB) Uniform Guidance (UG) requires an annual external audit of non-profit organizations expending more than $750,000 in federal funds Requirements are to test internal controls and compliance over financial reporting as well as test compliance and internal controls over major programs (two different levels) A sample of federal awards and their direct cost transactions are selected for testing to determine if expenditures and procedures are appropriate (i.e., in accordance with sponsor terms and conditions, and the CFR – Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements.    

Why is the UG Audit Important? All federal and non-federal sponsors look at the UG Audit report as a ‘report card’ of how the University spends their money Findings are reported to the federal government, become public record, and are distributed to all federal agencies through a clearinghouse Each department performing sponsored research is accountable for ensuring that the reported expenditures are appropriate with the terms and conditions of the award and federal cost principles (CFR - 200)

What is tested in the Uniform Guidance Audit? Financial & non-financial reporting Subrecipient monitoring Service centers F&A rate application Activities allowed / unallowed (direct costs, effort, etc) Internal controls Equipment Cost transfers Cost sharing Program income Procurement and Suspension and Debarment Note: Direct attribution (linkage between cost and purpose of the project) must be established and demonstrated through supporting documentation.

Additional testing takes place between PwC and OSP (LOC, FFRs, etc.) What’s involved? Direct Cost selection- Orientation in June Deep dive into one grant within your department 3-15 individual transactions selected for review Completion of the Compliance Control Questionnaire (CCQ)- a comprehensive document evaluating departmental procedures and internal controls Supporting documentation and CCQ due in mid-July Other selections (Cost Transfers, Cost Sharing, Procurement, etc.) Typically selected in April Supporting documentation due in May Additional testing takes place between PwC and OSP (LOC, FFRs, etc.)

Contacts Alan Berkeley Manager, Research Compliance & Training, RAS – FAS Berkeley@fas.Harvard.edu Christyne Anderson Manager, Training and Compliance, OSP Christyne_Anderson@Harvard.edu

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