OMB Uniform Grant Guidance Overview Native Nation Events Tribal Accounting Conference November 16, 2015

2 The material appearing in this presentation is for informational purposes only and should not be construed as advice of any kind, including, without limitation, legal, accounting, or investment advice. This information is not intended to create, and receipt does not constitute, a legal relationship, including, but not limited to, an accountant-client relationship. Although this information may have been prepared by professionals, it should not be used as a substitute for professional services. If legal, accounting, investment, or other professional advice is required, the services of a professional should be sought.

3 OMB UNIFORM GRANT GUIDANCE DISCLAIMER - This presentation provides an overview of some of the key changes to grant requirements applicable to Tribes – it does not provide information on all changes that may be applicable for every grant

4 OMB UNIFORM GRANT GUIDANCE AGENDA Federal Register, December 26, 2013

5 MORGAN ARONSON, CPA, CGFM NATIONAL SINGLE AUDIT COORDINATOR DEPARTMENT OF INTERIOR OIG 1.History of UGG 2.General Compliance Areas - Procurement & Subrecipient Monitoring 3.Audit Report Submission and the Tribal OPT Out

6 DENIS ADAMS, CPA SENIOR TECHNICAL REVIEWER JOSEPH EVE, CPAS 1. Super Circular Audit Requirements

7 SEAN MCCABE, CPA MANAGING SHAREHOLDER ANUSKEWICZ & MCCABE 1. Indirect Cost Basics

8 OMB UNIFORM GRANT GUIDANCE GENERAL OVERVIEW Federal Register, December 26, 2013

9 Grant Administration and Pre-Award OMB Circular A-89 OMB Circular A-102 OMB Circular A-110 Cost Circulars OMB Circular A-21 OMB Circular A-87 OMB Circular A-122 Auditing OMB Circular A-50 Single Audit Act follow-up OMB Circular A-133 THE NEW GUIDANCE REPLACES / COMBINES:

10 NEW UNIFORM GRANT GUIDANCE – TITLE 2 OF THE CFR, SUBTITLE A, CHAPTER II, PART 200 Subpart A 200.0XXAcronyms and Definitions Subpart B 200.1XXGeneral Provisions Subpart C 200.2XX Pre-Federal Award Requirements and Contents of Federal Awards Subpart D 200.3XXPost-Federal Award Requirements Subpart E 200.4XXCost Principles Subpart F 200.5XXAudit Requirements Appendix I - XI VII State and local Government and Indian Tribe – Indirect Cost Proposals

11 Also includes 11 Appendices (I – XI) o Appendix VII – State and Local Governments and Indian Tribes – Indirect Cost Proposals o Appendix X – Data Collection Form o Appendix XI – Compliance Supplement OMB UNIFORM GRANT GUIDANCE

12 OMB issued Uniform Grant Guidance on December 26, 2013 o Electronic Code of Federal Regulations (e-CFR) version Electronic Code of Federal Regulations (e-CFR) o PDF version of the Federal Register Notice in its entiretyFederal Register Notice o Final Interim Rule, with some changes to previously issued guidance was issued December 19, 2014 o Amendment for Technical Corrections was Issued September 10, 2015 OMB UNIFORM GRANT GUIDANCE

13 Council on Financial Assistance Reform (“COFAR”) working with OMB on rollout and related guidance o Training webcasts were presented 1/27/2014 and 10/2/2014 and recordings of the webcasts are available on the COFAR website o Frequently asked Questions for New Uniform Guidance at 2 CFR 200 issued 2/12/2014 and 8/29/2014 and updated November 2014 and September 2015 Frequently asked Questions for New Uniform Guidance at 2 CFR 200 OMB UNIFORM GRANT GUIDANCE

14 OMB UNIFORM GRANT GUIDANCE Goals: Streamline rules, reduce administrative burden to grant recipients and strengthen Federal oversight Focus: Reducing waste, fraud, and abuse