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Audit Requirements of the Uniform Guidance

Here's the punultimate installment of the several eCivis-hosted OMB training clips on the Uniform Guidance (2 CFR 200; previously known as the "super circular"), which is now in full effect for federal grantees. Part 9 of 10 from this OMB video series focuses on the audit portion of the final guidance, which strengthens oversight and scrutinizes where there is the greatest risk of waste, fraud, and abuse of taxpayer dollars. It improves transparency and accountability by making Single Audit reports available to the public online, and encourages federal agencies to take a more cooperative approach to audit resolution in order to more conclusively resolve underlying weaknesses in internal controls.

OMB Uniform Guidance Training: Cost Principles

eCivis Uniform Guidance Training March 2015

If you've been following along at home, you know this post is the latest installment of several of the eCivis-hosted OMB Uniform Guidance training videos, with previous posts covering the general overview of 2 CFR 200, which is now in full effect for federal grantees. In this article, OMB Senior Policy Analyst Victoria Collin details the feds' effort to remove barriers to entities who have never had a federally negotiated indirect cost rate (3:10); compensation for personal services (8:58); general advice on improving internal controls; "blended and braided" funds (11:40); family leave and conferences (18:50); IT infrastructure (20:03); and more. Check out the clip below and access all the training by clicking the large button at the bottom of this post.

Pass-Through Entity Requirements of the Uniform Guidance

If you've been following along at home, you know this post is the latest installment of several of the eCivis-hosted OMB Uniform Guidance training clips, with previous posts covering the general overview of 2 CFR 200, which is now in full effect for federal grantees. In this clip, OMB Senior Policy Analyst Victoria Collin addresses the requirements of pass-through entities. Here are some key timestamps in this segment of the training:

  • 0:33 - Providing an indirect cost rate to subrecipients (new) either through a negotiated rate or a de minimus rate of 10 percent of modified total direct costs
  • 1:58 - Performing risk assessment for subrecipient monitoring using the principle of risk
  • 3:06 - Verifying compliance to audit requirements
  • 3:46 - Requirements under the Transparency Act to report all subawards
  • 4:02 - Clarity on close-out obligations for final reports

Procurement Standards of the Uniform Guidance

The next video I want to share from our OMB Uniform Guidance training series covers the five methods of procurement standards and their general standards. Modeled on A-102 language, the procurement standards under the Uniform Guidance do not look much different for state and local governments. But for universities and nonprofits, there are some changes to note. The following nine-minute video covers these methods: micropurchases (1:50), small purchases (2:44), sealed bids (3:39), competitive proposals (3:58), and sole source (4:19). To help you visualize these standards, the OMB has presented a nifty "bear claw" to frame things. Office of Management and Budget Senior Policy Analyst Victoria Collin, who led this training, also covers the general standards that apply.

What Will I Recognize in the Uniform Guidance?

That's the question that leads this next video from our 10-part OMB Uniform Guidance training series. Last week we brought you a clip from OMB senior policy analyst Victoria Collin discussing how the first year of the Uniform Guidance (2 CFR 200) is a bit like the first year of marriage, where ideals and practical considerations meet. Now here's an overview of the changes in the OMB's Uniform Guidance and how they affect government, higher education, and nonprofit entities. This 22-minute video covers acronyms, applicability, pre-award requirements and agreements (11:05), the theme of "performance over compliance," post-award performance management (14:12), place-based initiatives (18:38), and much more. Without further ado, here's part 5 of 10. You can access the complete set of videos at the bottom of this page.

The First Year of the Uniform Guidance: Like the First Year of Marriage

So, here we are with the Uniform Guidance (2 CFR 200) after more than three years of "dating." Hear me out with the metaphor. We had ideas of what this "super circular" should look like, we shared opinions from multiple sides, and we discussed what the guidance should include or exclude. (Should we do more or less auditing? Is the indirect cost rate too burdensome? And so on.)

OMB Uniform Guidance Training Videos Are Here

With the new fiscal year starting in July for most state and local governments, many rolling grant programs and re-solicited grant opportunities will fall under the new administrative, cost principle, and reporting guidelines of the Uniform Guidance. Operationalizing the new guidance will require a solid understanding of the changes and their intent. It's critical that collaboration and information sharing improve and that local governments find more ways to share their training resources and best practices.

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