OMB Uniform Guidance 2014 Implementation at the University of Washington Northwest Chapter of Internal Auditors August 5 th, 2014 Ted Mordhorst Asst. Dir. For Post Award Financial Compliance Research Accounting and Analysis University of Washington

 Final Guidance document published in the Federal Register Dec 26,  Codified in 2 CFR 200  Replaces 8 previous OMB Circulars:  Circular A-110Circular A-21  Circular A-102Circular A-87  Circular A-89Circular A-102  Circular A-133Circular A-50 OMB Uniform Guidance 2014

 Applicable to Direct Federal Grants, Cooperative Agreements and Cost-reimbursable contracts.  Each federal awarding agency must implement  Effective for new $ received on or after Dec. 26, 2014  Audit effective for the entities first full fiscal year after 12/26/14.  Example: Entities fiscal year ends June 30 th  New audit requirements apply to fiscal year that ends June 30, 2016 OMB Uniform Guidance 2014

 A Core Team has been assembled Sponsored by Mary Lidstrom, Vice Provost for Research and Susan Camber, Associate Vice President, Financial Management  The team has representatives from:  OR, OSP, GCA, MAA, School of Medicine, College of Arts and Sciences, Procurement Services, and Internal Audit, The AG office  Additional sub-teams have been formed to review some of the more complex areas. University of Washington Approach University of WashingtonPresenter’s Office

 The working groups compared the new regulation to the existing regulations in A-110, A-21 and A-133  Identify changes  Map changes to university policy and procedures  Identifying possible changes to IT systems both central and in units  Propose changes to policy, procedures necessary to maintain compliance Uniform Guidance Working Group University of WashingtonPresenter’s Office

 Develop internal Communication plan.  Develop protocol for making changes to policies and procedures.  Develop training for campus personnel.  Modify existing training material for faculty and staff. Uniform Guidance Working Group University of WashingtonPresenter’s Office

 Timeline  APRIL 15 DISCOVERY (initial discovery of what changed complete)  MAY 15 DISCOVERY (impact to UW systems complete)  JUNE 01 DISCOVERY (map to UW policy & procedure complete)  JUNE 26 FEDERAL PLANS RELEASED (Federal agencies release their respective implementation plans)(Has not happened.)  SEPT 30 DRAFT OF CHANGES TO UW POLICY (comprehensively address & publish all changes to UW policy)  DEC 01 UW READY TO IMPLEMENT CHANGES (changes to UW policy & procedure approved & published)  DEC 26 FEDERAL IMPLEMENTATION BEGINS Uniform Guidance Working Group University of WashingtonPresenter’s Office

 We established a web page for the team at:  grant-guidance/ grant-guidance/  Contains links to the Final Uniform Guidance document  Links to other documents and presentations  Continues to be updated as more information becomes available. Uniform Guidance Working Group

 There are Open Issues…  Agency deviations – how will these be policed?  Conflict of Interest – agency plans are key  Research Terms and Conditions – (FDP) a lot to do in little time  Internal Controls – audit repercussions, if any?  Procurement – could be most significant new burden  Subrecipient Monitoring – could be second most significant  Closeouts – not a major change in the Uniform Guidance, but the pressure for timely closeouts has raised profile Uniform Guidance Working Group

 Other Issues…  The UW is working with the Council on Governmental Relations to obtain clarification from OMB on a number of areas:  Conflict of Interest – Institutional or individual  Program Income – Treatment of Royalties or other IP Income  Equipment – “Conditional Title”  Procurement – Small purchase threshold – required competition Uniform Guidance Working Group

 Challenges:  Conflicting Priorities for team members  Differing interpretations  OMB/COFAR slow response to questions  Pending clarification issues  Agency implementation plans not published Uniform Guidance Working Group

 A lot of questions remain but some of the more visible changes will have little impact on our policy and procedure.  Effort Certification – No change planned  Direct Charging of Administrative & Clerical Salaries – Little or no change planned  Electronic Records – Already moving to a paperless environment  Subrecipient Monitoring – Just revamped our processes Uniform Guidance Working Group

 Questions? Uniform Guidance Implementation University of Washington