1. 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

2. 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

3. 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.  

4. 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)

5. 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.

6. 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.)

7. Contacts
Alan Berkeley Manager, Research Compliance & Training, RAS – FAS Christyne Anderson Manager, Training and Compliance, OSP

8. Questions / Comments