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UNIFORM GUIDANCE: RESULTS AND BEST PRACTICES

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Presentation on theme: "UNIFORM GUIDANCE: RESULTS AND BEST PRACTICES"— Presentation transcript:

1 UNIFORM GUIDANCE: RESULTS AND BEST PRACTICES
Drag Picture and Send to Back Brian Mosier, CPA, CGFM AGA Great Lakes Region - RVP October 26, 2016

2 Drag Picture and Send to Back
What is an RVP?

3 GOVERNANCE www.agacgfm.org/leadership
Daily operations led by a Chief Executive Officer located at the national office in Alexandria, Va. Strategic guidance by a National President who chairs the National Executive Committee and Board of Directors Ann M. Ebberts, MS, PMP AGA Chief Executive Officer Douglas A. Glenn, CPA 2016–2017 AGA National President

4 Ways to Get Involved in AGA
Serve on local chapter committee Serve as a local chapter officer Serve as a regional officer Join a National Board or Committee Local - Regional/National -

5 Drag Picture and Send to Back
Uniform Guidance

6 Goals of the Uniform Guidance
Make compliance requirements and other federal award components uniform across all recipient types Improve performance outcomes Reduce unnecessary administrative burden

7 How have we done? Uniform Guidance was effective December 26, 2014
Audit requirement effective for years ending after December 26, 2015 Council on Financial Assistance Reform (COFAR) established to: Provide recommendations to Office of Management and Budget Share best practices with departments and agencies Engage relevant stakeholders

8 Audit Metrics Established by COFAR
Number of Single Audit Reports Number of Major Programs Selected for Audits (**) Number of Modified Opinions for Major Programs Selected for Audits (**) Number of Audit Findings of Material Weaknesses in Internal Controls for Major Programs Selected for Audits (**) Number of Repeat Findings for Higher Risk Major Programs (**) Number of Audit Objectives in Compliance Supplement (**) – Information not readily available at the time of this presentation

9 Audit Metrics Established by COFAR

10 Audit Metrics Established by COFAR

11 Administrative Metrics Established by COFAR
Number of OMB Approved Information Collections for Grants and Cooperative Agreements Number of New Awards Issued Number of New Fixed Amount Awards Issued Number of Agency Exceptions by CFDA to Federally Negotiated Indirect Cost Rates Number of Indirect Cost Rate Agreements Issued by Cognizant Agencies Number of Extensions of Indirect Cost Rate Agreements Issued

12 Administrative Metrics Established by COFAR

13 Administrative Metrics Established by COFAR

14 Administrative Metrics Established by COFAR

15 Best Practices in Implementing Uniform Guidance
Merit Review and Risk Assessment Subaward Determination Subrecipient Monitoring Fixed Amount Awards Personnel Services Indirect Cost Rates Single Audit and CAROI

16 Pool of Grant Applicants
Merit Review and Risk Assessment High Risk Frequent monitoring and guidance Specific Conditions Moderate Risk Some monitoring and guidance Possible specific conditions Low Risk Limited/Focused monitoring Communicate best practices Pool of Grant Applicants

17 Merit Review and Risk Assessment
2 CFR – Federal Awarding Agency Review of Merit Proposals Federal Awarding Agencies must identify recipients that determine those most likely to achieve outcomes Grant Recipients should implement processes to track and report positive outcomes

18 Merit Review and Risk Assessment
2 CFR – Federal Awarding Agency Review of Risk Posed by Applicants Federal Awarding Agencies must have a framework in place for evaluating risks posed by applicants to evaluate: Financial stability Quality of management systems History of performance Reports and findings from audits Applicant’s ability to effectively implement requirements Grant Recipients need to be prepared to discuss all of the above

19 Merit Review and Risk Assessment
2 CFR – Specific Conditions Based on risks, Federal Awarding Agency (and pass-through) may impose specific conditions Requiring reimbursement payments vs. advance payments Frequent performance monitoring Enhanced reporting (performance and financial) Requiring technical or management assistance Establishing additional prior approvals

20 Merit Review and Risk Assessment
Success Stories Ideas

21 Subaward Determination

22 Subaward Determination
2 CFR – Subrecipient and contractor determinations Federal Awarding Agencies should make checklists available to recipients Grant recipients should make a determination for each agreement that involves federal award dollars

23 Subaward Determination
Success Stories Ideas

24 Subrecipient Monitoring
2 CFR – Requirements for pass-through entities Pass-through entities must: Issue subawards with required data elements Evaluate subrecipient’s risk of noncompliance Consider imposing specific subaward conditions Monitor the activities of the subrecipient Tailor monitoring activities to the risks identified Verify each subrecipient has Single Audit, if applicable Consider audit results

25 Negotiate Award Amount Establish Payment Milestones
Fixed Amount Awards Negotiate Award Amount Establish Payment Milestones Pay for Performance

26 Fixed Amount Awards 2 CFR – Use of grant agreements (including fixed amount awards), cooperative agreements, and contracts Federal Awarding Agencies should treat these as a grant agreement Allowable cost/activity compliance would be “N/A” All other compliance requirements could still be applicable Federal Awarding Agencies should use fixed amount awards as a way to ensure performance is achieved

27 Fixed Amount Awards Success Stories Ideas

28 Personnel Services 2 CFR 200.430 – Compensation – personal services
Significant changes with Uniform Guidance Changes relate to methods with tracking costs, not the types of costs allowed Changed from prescriptive compliance requirements to a framework

29 OMB Circular A-87 (old guidance)
Personnel Services OMB Circular A-87 (old guidance) Employees working on one program or cost objective can complete periodic certifications Everyone else must complete personnel activity reports Personnel activity reports must be signed by employee and conform to other standards

30 Uniform Guidance – Standards for Documentation
Personnel Services Uniform Guidance – Standards for Documentation Be supported by a system of internal control Reasonably reflect total activity of employee Comply with the established accounting policies and procedures

31 Personnel Services Considerations of implementing a new process of tracking and allocating personnel costs Only change from personnel activity reports if it adds efficiency Ensure the new process meets the Standards of Documentation of Personnel Expenses When evaluating new processes implemented by recipients, be aware of significant changes in allocations

32 Personnel Services Success Stories Ideas

33 Indirect Cost Rates 2 CFR 200.414 – Indirect (F&A) costs
Specific requirements for Institutions of Higher Education, Not-for-profit Organizations, and State and Local Governments included in Appendixes Cost allocation plans are still allowed, negotiated indirect cost rates are not required

34 Indirect Cost Rates Federal agency with the largest dollar value of Federal awards is the cognizant agency for indirect costs Process for approval has no significant changes Any non-Federal entity that has never received a negotiated indirect cost rate may elect to charge a de minimis rate of 10% of modified total direct costs. Any non-Federal entity that has a negotiated indirect cost rate may apply for a one-time extension of the rates for a period of up to four years. Negotiations only need to occur once every five years

35 Indirect Cost Rates Success Stories Ideas

36 Single Audit and CAROI AGA CAROI Playbook 2 CFR 200.25 2 CFR 200.26

37 Single Audit and CAROI Cooperative Audit Resolution and Oversight Initiative (CAROI) Section – Cooperative Audit Resolution Section – Corrective Action Section Responsibilities

38 Single Audit and CAROI Federal Awarding Agencies must perform the following: Follow-up on audit findings to ensure the recipient takes appropriate and timely corrective action Use cooperative audit resolution mechanisms to improve federal program outcomes Provide OMB with the name of a key management single audit liaison who must promote the federal awarding agency’s use of cooperative audit resolution mechanisms

39 Single Audit and CAROI

40 Single Audit and CAROI More information on CAROI and the CAROI Playbook can be found at: Implementation of continuous audit resolution is required, but should not be treated as only a compliance requirement. Being a champion of this process will help agencies improve the audit resolution process and improve program performance.

41 THANK YOU! Brian Mosier

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