Eery year the major dictionaries pour over the new words which have joined common usage in the last year and publish a list of words they added Grant Management Dictionary.

Some of the words, like “five-second rule” or “digital footprint” were not new to me while others like “mahoosive” (meaning exceptionally big) were a complete surprise.

For example, the Oxford English Dictionary added the following word “al-desko” which is a new term that refers to eating lunch at your desk.

(This new term stands in stark contrast to “al-fresco” which means “fresh air”)

While I had not heard this term before, certainly the act of eating lunch at my desk is not a new concept.

Similarly, the new grant regulations include a number of new terms which may be surprise to you, but in many cases the concepts will be familiar.

Here are nine of our favorite new grant management terms and definitions:

#1: Computing Devices

§ 200.20 Computing devices.

Computing devices means machines used to acquire, store, analyze, process, and publish data and other information electronically, including accessories (or ‘‘peripherals’’) for printing, transmitting and receiving, or storing electronic information. See also §§ 200.94 Supplies and 200.58 Information technology systems.

This was added to the new grant regulations because (due to the decrease in computer costs and the proliferation of new “devices” such as tablets) there has been a long-running argument over whether computers were supplies or equipment.

The good news is that if the computing device cost is lower than your capitalization limit it would be a supply with far fewer tracking requirement on your Federal award.

#2: Compliance Supplement

§ 200.21 Compliance supplement.

Compliance supplement means Appendix XI to Part 200—Compliance Supplement (previously known as the Circular A–133 Compliance Supplement).

Let’s face it; we are all in the habit of referring to the Single Act Audit as the “A-133” audit.

The new grant regulations make the A-133 reference obsolete.

Somehow “Compliance supplement audit” does NOT have the same musical ring to it, but compliance supplement is the new term we will be using.

#3: Cooperative Audit Resolution

§ 200.25 Cooperative audit resolution

Cooperative audit resolution means the use of audit follow-up techniques which promote prompt corrective action by improving communication, fostering collaboration, promoting trust, and developing an understanding between the Federal agency and the non-Federal entity. This approach is based upon:

(a) A strong commitment by Federal agency and non-Federal entity leadership to program integrity;

(b) Federal agencies strengthening partnerships and working cooperatively with non-Federal entities and their auditors; and non-Federal entities and their auditors working cooperatively with Federal agencies;

(c) A focus on current conditions and corrective action going forward;

(d) Federal agencies offering appropriate relief for past noncompliance when audits show prompt corrective action has occurred; and

(e) Federal agency leadership sending a clear message that continued failure to correct conditions identified by audits which are likely to cause improper payments, fraud, waste, or abuse is unacceptable and will result in sanctions.

OK, this does NOT mean that Federal award recipients and the funding agency staff are going to be holding hands and singing “Kumbaya” anytime soon.

But…the days of low levels of accountability for award recipients with repetitive audit findings (same issues year-after-year-after-year) may FINALLY coming to an end with this heightened focus on audit resolution.

#4: Cross-cutting Audit Finding

§ 200.30 Cross-cutting audit finding.

Cross-cutting audit finding means an audit finding where the same underlying condition or issue affects

Federal awards of more than one Federal awarding agency or pass-through entity.

Cross-cutting brings to mind lumberjacks and big evil looking saws….

But cross-cutting audit findings mean that the issues at the awardee or subawardee go so deep that they involve multiple agencies or pass-through entities.

(This is a BAD thing.)

Part of the new grant regulation implementation will be new ways for the Federal government to track audit finding and compare across agencies the results of those findings.

The goal is to use new analytical tools to identify issues and get them resolved.

This new level of scrutiny is made possible by more and more of the data about your Federal award performance going online.

#5: Internal Controls

§ 200.61 Internal controls.

Internal controls means a process, implemented by a non-Federal entity, designed to provide reasonable assurance regarding the achievement of objectives in the following categories:

(a) Effectiveness and efficiency of operations;

(b) Reliability of reporting for internal and external use; and

(c) Compliance with applicable laws and regulations.

While technically the term “internal controls” is NOT new, the fact that everyone working on the award needs to understand and support strong internal controls is a new focus.

No longer hidden away in the audit guidance or an accounting textbook, internal controls are now for everyone.

How are you spreading the word of internal control for the masses at your organization?

#6: Micro-Purchase

§ 200.67 Micro-purchase.

Micro-purchase means a purchase of supplies or services using simplified acquisition procedures, the aggregate amount of which does not exceed the micro-purchase threshold. Micropurchase procedures comprise a subset of a non-Federal entity’s small purchase procedures. The non-Federal entity uses such procedures in order to expedite the completion of its lowest-dollar small purchase transactions and minimize the associated administrative burden and cost. The micro-purchase threshold is set by the Federal Acquisition Regulation at 48 CFR Subpart 2.1 (Definitions). It is $3,000 except as otherwise discussed in Subpart 2.1 of that regulation, but this threshold is periodically adjusted for inflation.

This is a long…explanation highlighting part of the new procurement “bear claw” which sets various purchasing levels with requirements of competition and documentation.

A micro-purchase is the least burdensome of the procurement levels and generally applies to purchases under $3000.

#7: Non-Federal Entity

§ 200.69 Non-Federal entity.

Non-Federal entity means a state, local government, Indian tribe, institution of higher education (IHE), or nonprofit organization that carries out a Federal award as a recipient or subrecipient.

This new term is a “one-size-fits-all” term to describe the main types of organizations that receive Federal awards.

#8: Personally Identifiable Information (PII)

§ 200.79 Personally Identifiable Information (PII).

PII means information that can be used to distinguish or trace an individual’s identity, either alone or when combined with other personal or identifying information that is linked or linkable to a specific individual. Some information that is considered to be PII is available in public sources such as telephone books, public Web sites, and university listings. This type of information is considered to be Public PII and includes, for example, first and last name, address, work telephone number, email address, home telephone number, and general educational credentials. The definition of PII is not anchored to any single category of information or technology. Rather, it requires a case-by-case assessment of the specific risk that an individual can be identified. Non-PII can become PII whenever additional information is made publicly available, in any medium and from any source, that, when combined with other available information, could be used to identify an individual.

The new grant regulations are updated to deal with the fact that more and more personal information is now contained online.

But really…”public sources such as telephone books”?

Is anyone really still using telephone books?

This definition covers the general types of information that can identify a person, and can be public PII or protected PII.

Protected PII is the one you really need to focus on in the new grant regulations Grant Management Dictionary .

#9: Protected Personally Identifiable Information (Protected PII)

§ 200.82 Protected Personally Identifiable Information (Protected PII). Protected PII means an individual’s first name or first initial and last name in combination with any one or more of types of information, including, but not limited to, social security number, passport number, credit card numbers, clearances, bank numbers, biometrics, date and place of birth Grant Management Dictionary , mother’s maiden name, criminal, medical and financial records, educational transcripts. This does not include PII that is required by law to be disclosed. (See also § 200.79 Personally Identifiable Information (PII)).

So what makes PII protected?

It is the combination of information that transforms personally identifiable information into protected PII Grant Management Dictionary .

And remember the reference to internal controls above Grant Management Dictionary ?

This is where the duty to protect PII comes into play because the organization (this means everyone needs to be aware of this duty) must take reasonable measures to safeguard protected personally identifiable information and other sensitive information.

So do you know how and where protected PII is stored, and transmitted?

If not, it’s time you make Grant Management Dictionary | the term “protected personally identifiable information” as common as last year’s new words.

You know the ones:

· Bro hug

· Bestie

· Hyperconnected

· Wackadoodle

Want some help interpreting the new grant regulations?

Check out our articles on the MyFedTrainer.com blog.

We have years of articles about the new grant regulations about a variety of topics related to 2 CFR Part 200.

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Author:

Lucy Morgan CPA, MBA

CEO, Compliance Warrior

Author of “Decoding Grant Management-The Ultimate Success Guide to the Federal Grant Regulations in 2 CFR Part 200” The 2nd Edition is now available on Amazon in Paperback and Kindle versions.