Over the last weeks, we’ve looked at the proposed changes to Administrative Requirements and Cost Principles regulations in the Office of Management and Budget (OMB) “Reform of Federal Policies Relating to Grants and Cooperative Agreements; Cost Principles and Administrative Requirements” released in February 2013.
This week we look at the effect on audits for Grant recipients with 6 things your auditor may not tell you.
(It should be noted that the proposed changes for Grants and Cooperative Agreements have not been enacted yet.)
Here is what could happen in the future:
The Minimalist Guide to Proposed Changes of the Grant and Cooperative Agreement Regulations:
Part Three: Reforms to Audit Requirements
Additional Suggestions about A-133 Audits from the Report
#1 Focus audit resolution and oversight resources on higher risk, higher dollar federal awards including:
• Raise the Single Audit Requirement threshold from $500,000 to $750,000
• Reduce the number of programs designated as “major programs” to focus on areas of the highest risk
• Change the minimum threshold for reporting questioned costs from $10,000 to $25,000
• Streamline some of the A-133 requirements
#2 Streamline some of the A-133 testing requirements to focus on the area most likely to result in improper payments, waste, fraud, or abuse including:
• Allowability of expenditures and amounts claimed for matching
• Cash management, such as procedures to minimize the time elapsing between the
• Transfer of funds from the U.S. Treasury and their final disbursement
• Monitoring of eligibility of program services and benefits
• Supporting documentation for report
• Subrecipient monitoring
(And reduce the focus on Davis Bacon, Equipment and Real Property Management, Suspension and Debarment, Program Income, Real Property Acquisition and Relocation Assistance Auditor Things
#3 Increase the Federal awarding agency responsibilities for audit follow-up
#4 Encourage cross-agency coordination to lower the burden on subrecipients and pass-through entities
#5 Lower audit follow-up requirements on pass-through entities and subrecipients
#6 Additional areas for consideration:
• Shorten the time requirement for audit completion from nine months Auditor Things to three or six months
Stay tuned in the coming month for more updates!
Missed any of the other summaries?
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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.