Uniform Guidance: Top 10 considerations for your next single audit

The US Office of Management and Budget (OMB) issued comprehensive grant reform rules called Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) in December 2013. These rules were effective for new federal awards and changes to funding increments issued after December 26, 2014.

Now that we are a year into the new Uniform Guidance rules and your next audit is on the horizon, you’ll want to be mindful of key changes that will impact your single audit. The following are the top ten changes you should expect to notice in your next single audit.

1. Required written documentation

The Uniform Guidance now requires written policies in order to comply with certain requirements. Compliance areas for which each entity must maintain written policies include cash management, procurement, subrecipient monitoring, conflicts of interest, and time and effort reporting. Now is the time to prepare or refresh your written policies surrounding various aspects of grants management, as your auditors will be requesting these policies.

2. Disclosure of payments to subrecipients

Under prior OMB circular guidance, payments to subrecipients could be reported as a disclosure in the footnotes to the Schedule of Expenditures of Federal Awards (SEFA), if practical to identify. Under the Uniform Guidance, the payments to subrecipients must be disclosed on the face of the SEFA for each federal program. Entities should ensure that they are able to identify totals paid to subrecipients by Catalog of Federal Domestic Assistance (CFDA) number using their accounting system or another methodology. Your auditors will verify the totals to supporting documentation.

3. Summary Schedule of Prior Audit Findings and Corrective Action Plan change

The pre-Uniform Guidance rules required that only the findings related to federal awards be reported on the entity’s Summary Schedule of Prior Audit Findings (SSPAF). Under the Uniform Guidance, financial statement findings under Generally Accepted Government Auditing Standards (GAGAS) must also be reported on the SSPAF. This change creates consistency between the Corrective Action Plan and SSPAF in that both documents now require inclusion of both GAGAS and compliance findings. Entities that were not previously including the GAGAS findings reported in Section II of the Schedule of Findings and Questioned Costs will want to revise those documents as needed before providing them to the auditors.

4. CFDA numbers and cluster subtotals

The SEFA must contain a CFDA number for each grant awarded to your entity. Sometimes there are multiple lines on the SEFA with the same CFDA number. These lines must now be subtotaled on the SEFA. Clusters of programs must also be identified and subtotaled on the SEFA. As a result, some entities will need to change the design of their SEFA.

5. Subrecipient monitoring changes

Entities that pass federal money through to subrecipients have more prescriptive requirements to follow. Each pass-through entity is now required to evaluate each subrecipient’s risk of noncompliance. This risk assessment should be documented and will assist the pass-through entity in determining the appropriate monitoring activities to perform for each subrecipient. Auditors will request written risk assessment documentation to guide them in their audit procedures.

6. Subrecipient contracts

Under the Uniform Guidance, entities that pass federal money to recipients are required to include certain elements in their subaward contracts. Those elements include the subrecipient name and DUNS number, Federal Award Identification Number (FAIN), federal award date, subaward period of performance start and end date, amount of federal funds obligated, project description, name of the federal awarding agency / pass-through entity and contact information, CFDA number and name, identification if research and development, and a provision for indirect costs. Entities should ensure that these elements are included in their standard contract language for subrecipients.

7. Equipment tracking

The Uniform Guidance reiterated the importance of tracking capital assets purchased with federal funds. Items that should be documented in an entity’s property records for each capital asset acquisition using federal funds include a description of the property, serial number or other identifying number, source of the funding, who holds the title, acquisition date, cost, percentage of federal participation in the equipment cost, location, use and condition of the item, and disposition data.

8. Federal Funding and Accountability and Transparency Act (FFATA) reporting

Under the Uniform Guidance, there is no longer an audit requirement to test the FFATA filing requirements, so auditors may not be inquiring about this reporting unless there was a prior year finding. However, entities should be aware that the filing requirements still exist for direct federal awards received.

9. Identification of expenditures received under the Uniform Guidance and pre-Uniform Guidance

Entities may be spending grants awarded pre- and post-Uniform Guidance in the same year under audit. Entities should be prepared to identify expenditures of Uniform Guidance and pre-Uniform Guidance awards when requested by the auditor, as testing requirements may differ. The split between pre- and post-Uniform Guidance does not need be shown on the SEFA but should be readily available upon a request for a population of expenditures.

10. Methods of procurement

The five methods of procurement prescribed under the Uniform Guidance most closely follow the previous OMB Circular A-102, Grants and Cooperative Agreements with State and Local Governments. The five methods of procurement under the Uniform Guidance are micro-purchases, small purchases, sealed bids, competitive proposals, and noncompetitive proposals. Compliance with the provisions of procurement rules under the Uniform Guidance was extended for two full fiscal years after the effective date of the Uniform Guidance. Even those entities that previously followed OMB Circular A-102 should take this time to review their existing procurement policies to ensure compliance with these requirements.

As you prepare for your next single audit, Baker Tilly recommends that all recipients of federal awards be familiar with these and other requirements under the Uniform Guidance to ensure compliance with federal grant awards.

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