Preparing Your Organization

for ComplianceHighlights of the Federal Uniform

Guidance for Grants

Presented by:

Sandra Swab

Feb. 19, 2015

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About the Presenter

Sandra Swab is currently an independent consultant focusing on

grants, data standards and performance measurement.

Over 30 years government experience focusing on focusing grants,

financial and program management.

Grants experience includes in setting up a federal funding program

and developing reporting requirements for it, overseeing and writing

grants agency policies, as well as developing electronic systems to

support the management of agency grants.

Sandra also wrote and developed grant government-wide policies

while working at the Office of Management and Budget as a Senior

Policy Analyst.

She is a member of the National Grants Management Association

(NGMA) and the Association of Government Accountants (AGA).

She is also sits on the Grants Advisory Board for Thompson Publishing.

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Agenda

Background—A Historical Perspective

Objectives of the Uniform Guidance

Guidance Focus

Structure of the Guidance

Overview of the Uniform Guidance

Questions

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A Little History of How We Got

Here

P.L. 106-107 (1999)—Grant Streamlining

FFATA (2006)—Reporting on federal

spending on a public website

GPRA Modernization (2010)—Publish

agency performance goal

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A Little History of How We Got

Here

ARRA (2009)—Central recipient

reporting of ARRA awards with

managed oversight

DATA Act (2014)—Gov’t-wide data

standards for financial data

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History Continued

Executive Orders focused on

regulation burden, improper payments

and innovation

Federal Assistance Guidance:2 CFR Chapter 1, Chapter II, Part 200, et al.—Uniform

Administrative Requirements, Cost Principles, and Audit

Requirements for Federal Awards, Final Rule (12/26/2013)

Interim Final Rule of Federal Agency Regulatory Implementation

of OMB’s Administrative Requirements; FR, Vol.79, No. 244; (12/19/2014)

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UNIFORM GUIDANCE

OBJECTIVES & FOCUS

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Guidance Objectives

Ease administrative burden

Strengthen oversight

Enhance accountability

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Focus of Uniform Guidance

Standardization

Format & Data

Reporting

Performance

Award

Organizational

OMB

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Focus of Uniform Guidance

Standardization—Format & Data

Federal agencies to use standard format

for funding opportunities (identify

performance measures—200.202)

Federal agencies are required to supply

specific data on grant awards (200.210) &

includes award performance goals &

indirect cost rate

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Focus of Uniform Guidance

Standardization—Format & Data

Non-Federal Entities must be able to

identify in its accounts federal awards

received by:

Federal program, award ID, CFDA number &

title, year, federal awarding agency and

name of pass-through entity

States & non-federal entities need to be able

to trace funds to assure funds are used

according to federal statutes and regulations

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Focus of Uniform Guidance

Standardization—Reporting

Use OMB-approved standard information

collection instruments, e.g. SF-425

Report standardization allows:

Non-federal entities to standardize their

data to meet reporting requirements

Non-federal entities to use standardized

data in management processes

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Focus of Uniform Guidance

Performance—Awards

Federal agencies are required to identify

performance measures for each award

Non-federal entities are required to report

on performance by:

Relating financial data to performance

accomplishments

Reporting cost information, when applicable

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Focus of Uniform Guidance

Performance—Organizational Non-federal entities will be required to

demonstrate good management practices by: Documenting performance history on funded

projects (federal & non-federal)

Establishing or maintaining effective internal controls to ensure compliance

Establishing or maintaining organizational policies and procedures that supports the uniform guidance

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UNIFORM GUIDANCE

STRUCTURE

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Structure of the Guidance

Consolidation

Consolidated 8 OMB Circulars

Provides consistency of terms

Eliminated overlapping & confusing

compliance requirements

There are six subparts and 11 Appendices

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Structure of the Guidance

Part 200

Six Subparts

Subpart A—Acronyms & Definitions

Subpart B—General Provisions

Subpart C—Pre-Federal Award Requirements

and Contents of Federal Awards

Subpart D—Post Federal Award Requirements

Subpart E—Cost Principles

Subpart F—Audit Requirements

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UNIFORM GUIDANCE

OVERVIEW

Overview of Uniform Guidance

Terms to Review

Contract/Contractor

Subaward/Subrecipient

Cognizant agency for audit/oversight

agency for audit

Cognizant agency for indirect costs

Supplies and equipment

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Overview of Uniform Guidance

Policy Changes

Focus on performance

Performance measures per award

Introduces different types of grants (fixed price)

Focus on performance measurement to

improve program outcomes

Requires non-federal entities to meet identified

performance requirements & report

Pass-through entities can pass down needed

performance requirements

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Overview of Uniform Guidance

Policy Changes Requires federal agencies to accept

federal negotiated indirect cost rate or use “de minimis” rate of 10% (same for subrecipients)

Compensation requirement for standards with flexibility for implementation (200.430)

Internal Controls; including PII

IHEs Cost accounting standards & disclosure statement (200.419)

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Overview of Uniform Guidance

Policy Changes

Family friendly policies--dependent care

costs-- conferences (200.432); and travel

dependent care costs (200.474)

Listing of items requiring prior approval

(200.407)

Supports use of technology to manage,

store and transmit funding data

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Overview of Uniform Guidance

Management and Oversight

Risk evaluation of potential applicants

prior to award (Federal agencies & pass-

through entities)(200.205 &200.331)

Criteria must be in funding announcement

Evaluation can result in special award

conditions

Merit review of applications

Process described in funding opportunity

See Appendix 1

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Overview of Uniform Guidance

Management and Oversight

Disclosures of conflict of interest and

criminal violations; and certifications

Pass-through entity responsibilities—

extensive for oversight and managing

(200.331)

Cash payment transfers must minimize the

time funds are received to disbursement

of funds—requires cash management

oversight

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Overview of Uniform Guidance

Management and Oversight

Award Management requires managing

Program Income

Cost-Sharing

Budget revisions

Performance and financial management

Items above including requesting a cash payment

requires sound management practices and

monitoring with periodic internal reporting.

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Overview of Uniform Guidance

Management and Oversight

Cost principals—55 Items of Cost

Non-federal entity’s accounting practices

must be consistent with the cost principles

Identifies allowability of costs

Cost must reasonable and necessary

Conform to any limitations set forth in the cost

principles

Adequately documented

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Overview of Uniform Guidance

Management and Oversight

Policy and procedure flexibility

Procurement—requires using non-federal

entity’s procedures (grace period)

Travel—use entity’s procedures or follow

federal GSA travel guidelines

Time and effort--entity’s procedures must

meet standards

Internal controls—ability to comply with

federal statutes & regulations; remedy non-

compliance; and PII

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Overview of Uniform Guidance

Management and Oversight

Audit Requirement

Single audit--$750,000 expended in entity’s

fiscal year

Exempt from single audit if less than $750K, but

may have an audit in relation to other

requirements—if required (200.503) and not be

duplicative

Auditees must produce a financial statement

with schedule of expenditures of federal

awards (200.508 and 200.510)

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WHAT DOES THE UNIFORM

GUIDANCE OFFER

Conclusion

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Conclusion

Uniform Guidance offers

Flexibility—using their policy and

procedures

Identification of standard data for

management and reporting

Encourages use of electronic systems to

manage, store and transmit data in a

machine readable format

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In Conclusion

Uniform Guidance establishes Risk criteria evaluation that requires non-

federal entities to be able to show it can manage risk—financial integrity, performance capability, etc.

Stronger oversight of subrecipients and places accountability on pass-through entities and non-federal

Need to link financial reporting to performance to improve federal program outcomes

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In Conclusion

Uniform Guidance requires recipients

To have internal business practices &

reporting in place to support federal

activities--reliance on sound business

practices

To have capability to monitor award

activities, disbursements and budget to

easily produce required reports—reduce

waste, fraud and abuse

To use standard data for reporting

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Questions

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