GASB and Accounting Update

Presented by: Scott Anderson, CPAApril 15, 2015

Describe the changes in accounting guidance that are effective in the current year

List current projects that are being discussed and describe how they could impact their position

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Learning Objectives

Effective GASB Statements

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Periods beginning after December 15, 2013 GASB 69: Government Combinations and Disposal of

Government Operations

Periods beginning after June 15, 2014 GASB 68: Accounting & Financial Reporting for Pensions GASB 71: Pension Transition for Subsequent Contributions

Periods beginning after June 15, 2015 GASB 72: Fair Value Measurement and Application

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GASB Effective Dates

Periods beginning after June 15, 2015 (continued) GASB 73: Accounting and Financial Reporting for Pensions and

Related Assets that are Not within the Scope of GASB Statement 68

Periods beginning after June 15, 2016 GASB 74: Accounting & Financial Reporting for Postemployment

Benefits Other Than Pension Plans

Periods beginning after June 15, 2017 GASB 75: Accounting and Financial Reporting for

Postemployment Benefits Other than Pensions

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GASB Effective Dates (continued)

GASB Statements 68 & 71Accounting and Financial Reporting for PensionsPension Transition for Contributions Made

Subsequent to the Measurement Date

Applies to plans administered through trusts or equivalent arrangements: Contributions to the plan and earnings on those

contributions are irrevocable Plan assets are dedicated to providing pensions to

plan members Plan assets are legally protected from creditors

Does not apply to OPEB

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Scope and Applicability

Measurement of the Net Pension Liability

Total pension liability - actuarial PV of projected benefit payments attributed to past service Determined by valuation no more than 30 months and

1 day earlier than employer’s fiscal year-end

Net pension liability is required to be measured no earlier than end of employer’s prior fiscal year-end, consistently applied (measurement date)8

Employer Net Pension Liability

Measurement date will most likely correspond to year-end of plan.

Employer contributions made directly by the employer subsequent to the measurement date of the net pension liability and before the end of the employer’s fiscal year should be recognized as a deferred outflow of resources.

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Timing of Measurement of Total Pension Liability

Pension Expense(measurement period)

Deferred Outflows of Resources

June 2014 September 2014 June 2015 September 2015

Plan Prior Year-End

Employer Prior Year-End

Measurement Date

Plan Current Year-End

Employer Current Year-End

Several different actuarial cost methods

Actuarial valuation of investments used to determine employer’s AR

Projected benefits only included plan or contractually agreed to benefits

Discount rate based on investment return assumption

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Measurement of TotalPension Liability

GASB 68 (new) GASB 27 (old)Only entry age actuarial cost

methodSeveral different actuarial cost methods

Fair value of investments used to determine employer’s net pension liability

Actuarial valuation of investments used to determine employer’s AR

Projected benefits also includes ad hoc postemployment benefits if substantively automatic

Projected benefits only included plan or contractually agreed to benefits

Discount rate based on long-term expected rate of return only for period that plan’s net position is projected to be sufficient to make benefit payments

Discount rate based on investment return assumption

Single or agent employers without a special funding situation recognize a liability equal to the net pension liability

Single or agent plans with special funding situations and cost-sharing plans recognize proportionate share of the collective net pension liability Proportionate share is determined by comparing

employer’s projected long-term contribution effort to the collective projected long-term contribution effort

Can also use an actuarially determine proportion

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Employer Financial Statements

Items included in pension expense immediately Changes in total pension liability resulting from

current-period service cost and interest on total pension liability

Changes in benefit terms Changes in projected earnings on plan’s investments

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Changes in Net Pension Liability

Defer recognition over a closed period based on service lives of all active and inactive employees Changes of economic and demographic assumptions Differences between actual and expected experience Change in employer’s proportionate share of the

collective net pension liability Difference between employer’s contributions and

proportionate share of total contributions

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Changes in Net Pension Liability

Defer recognition over a five-year closed period Difference between projected earnings on plan

investments and actual experience

Defer recognition for one year only Contributions made subsequent to the measurement

date of the net pension liability, but before the end of the reporting period

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Changes in Net Pension Liability

Comprehensive Implementation Guide updated in October

GASB 68 pension implementation guide issued http://gasb.org/jsp/GASB/Page/GASBSectionPage&cid=1176163026371

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GASB Implementation Guides

GASB  Statement 73

Accounting and Financial Reporting for Pensions and Related Assets that are Not within the Scope of GASB Statement 68

Pensions Without a Trust

An employer that does not have a special funding situation should recognize a liability for the Total Pension Liability

The discount rate should be a yield or index rate for 20-year, tax-exempt general obligation municipal bonds with an average rating of AA/Aa or higher

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Pensions Without a Trust

Any assets accumulated for pensions that are not administered through trusts should not be accounted for as pension plan assets

Information similar to that required by Statement 67 or Statement 68 should be included in notes to financial statements and required supplementary information

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GASB  Statements 74 and 75

Accounting and Financial Reporting for Postemployment Benefits Other than Pensions or Pension Plans

Scope and Applicability

These new standards are similar to GASB 67 & 68 except for OPEBs: Intended to replace current guidance under GASB 45 and

57 (employers’ perspective) and GASB 43 (plan perspective)

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OPEB ‐ Similar to 67 & 68The proposed Statement would require two financial

statements A statement of fiduciary net position A statement of changes in fiduciary net position

Single or agent employers without a special funding situation recognize a liability equal to the Net OPEB Liability

Single or agent plans with special funding situations and cost-sharing plans recognize proportionate share of the collective Net OPEB Liability

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Measurement of Total OPEB Liability

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GASB 75 (new) GASB 43/45 (old)Only entry age actuarial cost

methodSeveral different actuarial cost methods

Fair value of investments used to determine employer’s net liability

Actuarial valuation of investments used to determine employer’s ARC

Projected benefits also includes ad hoc postemployment benefits if substantively automatic

Projected benefits only included plan or contractually agreed to benefits

Discount rate based on long-term expected rate of return only for period that plan’s net position is projected to be sufficient to make benefit payments

Discount rate based on investment return assumption

GASB  Statement 69

Government Combinations and Disposals of Government Operations

PurposeObjective is to improve financial reporting by addressing

accounting and financial reporting for government combinations and disposals of government operations

Guidance previously applied to government combinations was developed for nongovernmental entities and, therefore, addressed conditions and circumstances that would generally not be present in government combinations

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Addresses government combinations between government entities or a government and nongovernmental entity if new or continuing entity is a government Mergers Acquisitions Transfers Disposals

GASB 69

Mergers

Defined: Two or more governments combined and form a new

governmentOR

When a government is dissolved and it’s operations are absorbed into a continuing government

No significant consideration (in relation to assets and liabilities acquired)

Maintain carrying values

Merger Date

New government Date combination becomes effective

Continuing government Beginning of the reporting period, regardless of

the date of the merger As though entities had combined at beginning of

government’s reporting period

AcquisitionsPurchase with significant consideration provided

Acquired entity or operations becomes part of the acquiring government Generally at the price that would be paid for similar assets

(acquisition value) When consideration exceeds net position acquired

• Excess is a deferred outflow When consideration is less than net position acquired

• Reduce value of noncurrent assets acquired unless a contribution is involved

Acquisitions Cont’dValuation: General Rule - Market-based Exceptions - GAAP basis for employee benefit

arrangements and solid waste operations

Acquisition costs should be shown as a period expense

Present a special item in governmental fund operating statement for fund balance acquired, if applicable

Effective date is when control changes

Transfers of Operations

Transfers of operations to continuing governments or new governments Does not involve combinations of legally separate

entities or significant consideration

Transfers may be from government or nongovernmental entities

Net fund position received is recognized as a special item

Transfers Cont’d

Transfers maintain same carrying value at effective transfer date

Transfer Date Continuing government

• Report transfer as transaction in reporting period New Government:

• Initial reporting period begins at effective transfer date

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DisposalsDisposing government should recognize a gain/loss

as a special item

Disposal date is effective date of transfer or date of sale of the operations

Do not include adjustments or costs associated with normal operating activities in the gain/loss

Include costs directly associated with disposing of operations when determining gain/loss

Note DisclosuresFor each government combination A brief description of the government combination,

including identification of the entities involved in the combination and whether the participating entities were included within the same financial reporting entity

The date of the combination

A brief description of the primary reasons for the combination

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New government or continuing government The amounts recognized as of the merger date or the

effective transfer date as follows:• Total assets—distinguishing between current

assets, capital assets, and other assets• Total deferred outflows of resources• Total liabilities—distinguishing between current

and long-term amounts• Total deferred inflows of resources• Total net position by component

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Note Disclosures –Mergers & Transfers

Note Disclosures ‐ Acquisitions In the period in which an acquisition occurs, the

acquiring government also should disclose the following information: A brief description of the consideration provided

The total amount of net position acquired as of the date of acquisition

A brief description of contingent consideration arrangements, including the basis for determining the amount of payments that are contingent

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In the period in which operations are transferred or sold: Disposing government should identify the operations and

provide a brief description of the facts and circumstances leading to the disposal.

Disposing government should identify and disclose, if not separately presented in its financial statements:

• Total expenses, distinguishing between operating and nonoperating, if applicable

• Total revenues, distinguishing between operating and nonoperating, if applicable

• Total governmental fund revenues and expenditures, if applicable

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Note Disclosures ‐ Disposals

GASB  Statement 72

Fair Value Measurement and Application

Fair Value – Defined

Price that would be received to sell an asset or paid to transfer a liability in an orderlytransaction between market participants at the measurement date

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Key Factors

Transaction takes place in the government’s principal market, or most advantageous market in the absence of a principal market.

Fair value would be described as an exit price

Not be adjusted for transaction costs

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Use valuation techniques that are appropriate in the circumstances and for which sufficient data are available to measure fair value. Market approach Cost approach Income approach

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Valuation

Hierarchy

Level 1 being quoted prices (unadjusted) in active markets for identical assets or liabilities

Level 2 being inputs other than quoted prices included within Level 1 that are observable for the asset or liability, either directly or indirectly

Level 3 being unobservable inputs

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When do we use it?

An investment - a security or other asset that a government holds primarily for the purpose of

income or profit AND with a present service capacity

that is based solely on its ability to generate cash or to be sold to generate cash

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Exceptions

Money market investments

2a7-like external investment pools

Investments in life insurance contracts

Equity method investments

Unallocated insurance contracts

Synthetic guaranteed investment contracts

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For recurring and nonrecurring fair value measurements: The fair value measurement at the end of the reporting

period The level of the fair value hierarchy (Level 1, 2, or 3) A description of the valuation techniques used If there has been a change in valuation technique that has

a significant impact on the result, that change and the reason(s) for making it

For fair value measurements categorized in Level 3, other than those that calculate NAV per share or its equivalent, the effect of those investments on investment income for the reporting period

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Disclosures

NAV

The fair value measurement at the reporting date and a description of the significant investment strategies of the investee(s)

The amount of the government’s unfunded commitments

A general description of the terms and conditions upon which the government may redeem investments

Any other significant restriction on the ability to sell

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Exposure Drafts

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ED on GAAP Hierarchy

Current Hierarchy GASBs and Interpretations

GASB Technical Bulletins and AICPA Audit Guides and SOPs if specifically made applicable to state and local government and cleared by GASB

AICPA Practice Bulletins cleared by GASB

Implementation Guides and general practice

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GAAP Hierarchy Cont’d

Possible Changes in Structure Level 1- would require formal GASB approval and

exposed to public comment (statements and interpretations)

Level 2- GASB technical bulletins, GASB implementation guides and AICPA pronouncements cleared by GASB

Nonauthoritative- FASB Codification, GASB Concepts Statements and other accounting literature

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Tax Abatements

Defined - agreement between a government and a taxpayer in which the government promises to forgo tax revenues and the taxpayer promises to subsequently take a specific action that contributes to economic development or otherwise benefits the government or its citizens.

Disclosures General descriptive information (tax being abated, authority,

eligibility criteria etc.) Number of tax abatement agreements Dollar amount of taxes abated during the period Commitments made by a government, other than to abate taxes,

as part of a tax abatement agreement.

Preliminary Views & Other Projects

Fiduciary Responsibilities

Purpose - enhance the consistency and comparabilityof the reporting of fiduciary activities by Clarifying when a government has a fiduciary responsibility

for financial reporting Describing individual fiduciary fund types Clarifying the financial reporting requirements for BTAs

that also are engaged in fiduciary activities Requiring a financial flows statement for all fiduciary fund

types

Leases

Lessees Recognize a lease liability and an intangible lease asset

• Measured at the present value of certain lease payments

• Recognize interest expense Lease asset would be measured at the value of the lease

liability plus any prepayments and certain initial direct costs

• Amortization expense on the lease asset

Leases Cont’d

Lessors Recognize a lease receivable

• Measured at the present value of certain lease payments to be received over the lease term

• Recognize interest revenue Recognize a deferred inflow of resources

• Measured at the value of the lease receivable plus the amount of any payments received at or prior to the beginning of the lease that relate to future periods

• Recognize revenue Would not derecognize the underlying asset in the lease

Leases Cont’d

Short-term lease exception A lease that, at the beginning of the lease, has a

maximum possible term under the contract, including any options to extend, of 12 months or less.

Would not follow the proposed accounting for leases• Lessees - Recognize lease payments as expenses or

expenditures• Lessors - Recognize lease payments as revenue

Other Projects

Irrevocable Charitable Trusts – ED Q2 of 2015

Asset Retirement Obligations – ED Q4 of 2015

External Investment Pools – ED Q2 of 2015

Going Concern - TBD

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Impact of the Uniform Grant Guidance

Overview and Focus on Administrative Principles

Office of Management and Budget (OMB) published the Super Circular on December 26, 2013, in the Federal Register

Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards federalregister.gov/a/2013-30465

Super Circular

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December 19, 2014 Federal Register: OMB published technical corrections Federal awarding agencies published implementing regulations,

including OMB-approved exceptions and clarifying language www.gpo.gov/fdsys/pkg/FR-2014-12-19/pdf/2014-28697.pdf

Crosswalk for exceptions and clarifications: https://cfo.gov/wp-content/uploads/2014/

12/Agency-Exceptions.pdf

Effective December 26, 2014 CFR updated www.ecfr.gov/cgi-bin/text-idx?tpl=%2Findex.tpl

Super Circular

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A-21 Cost Principles for Educational Institutions

A-50 Audit Follow-Up, related to Single Audit

A-87 Cost Principles for State, Local, and Indian Tribal Governments

A-89 Federal Domestic Assistance Program Information

A-102 Awards and Cooperative Agreements with State and Local Governments

A-110 Uniform Administrative Requirements for Awards and Other Agreements with Institutions of Higher Education, Hospitals, and Other Nonprofit Organizations

A-122 Cost Principles for Non-Profit Organizations

A-133 Audits of States, Local Governments and Non-Profit Organizations

Streamlining of Related Circulars and Guidance

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Title 2 in the Code of Federal Regulations (2 CFR) –Grants and Agreements

Part 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards

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About the Law

Subpart A Acronyms and 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

Appendix I Full Text of Notice of Funding Opportunity

Appendix II Contract Provisions for Non-Federal Entity Contracts Under Federal Awards

Appendix III Indirect (F&A) Costs Identification and Assignment, and Rate Determination for Institutions of Higher Education (IHEs)

Appendix IV Indirect (F&A) Costs Identification and Assignment, and Rate Determination for Nonprofit Organizations

Appendix V State/Local Governmentwide Central Service Cost Allocation Plans

Appendix VI Public Assistance Cost Allocation Plans

Appendix VII

States and Local Government and Indian Tribe Indirect Cost Proposals

Appendix VIII

Nonprofit Organizations Exempted From Subpart E—Cost Principles of Part 200

Appendix IX Hospital Cost Principles

Appendix X Data Collection Form (Form SF-SAC)

Appendix XI Compliance Supplement61

Appendices

Effective Date

The regulations just issued by the federal agencies were required in order to adopt the guidance and implement policies and procedures for new awards by the effective date of December 26, 2014.

All federal agencies were expected to implement the guidance in unison to provide for a smooth transition for entities that are required to comply.

Existing Federal awards will continue to be governed by the terms and conditions of the award.

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Federal Agencies

The new federal agency regulations: Are codified under the Title of the CFR specifically applicable to

the agency.• E.g., DHHS is 45 CFR 74, 75, and 92

Detail the exceptions that OMB has allowed for three agencies (USAID, Health and Human Services, Education)

• To comply with existing federal laws • To continue long-standing practices

Detail the clarifications that agencies have issued• How specific aspects of the Uniform Guidance will be implemented

by that agency

Do not create any new policies

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Federal Agencies

Non-federal entities will need to implement the new administrative requirements and Cost Principles for all new federal awards and to additional funding to existing awards (funding increments) made after December 26, 2014.

Per 200.110, 1 year delay to comply with 200.317-200.326 (Procurement Standards), based on recipient’s fiscal year

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Non‐Federal Entities

Some non-federal entities will have funding subject to the old Cost Principles and the new Cost Principles within the same fiscal year.

New compliance supplement will have Part 3.1 for “old” grants subject to previous administrative and

cost principle regulations Part 3.2 for new grants and incremental funding subject to

Uniform GuidanceWe have to determine which requirements apply to

which expenditures Example: Entity has multiple CDBG grants issued in different

years. Expenditures from the “old” grants will need to comply with 3.1 and expenditures from the most recent grant will need to comply with 3.2.

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Non‐Federal Entities cont’d

The audit requirements in Subpart F will be effective for auditee fiscal years beginning on or after December 26, 2014. Calendar year ends – December 31, 2015 June 30 year ends – June 30, 2016 September 30 year ends – September 30, 2016

Early implementation of Subpart F is not permitted.

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Single Audits (Subpart F)

Subpart A ‐ Definitions

This section includes 44 acronyms

IHE – Institutions of Higher Education (new)

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200.00, Acronyms

The 99 definitions are in separate sections

Terms are broad to encompass all requirements (administrative, cost principles, audit) and all types of entities receiving Federal awards

RECOMMENDATION: Scan the list of definitions to see if there are any which are critical to your grants and compare the new definition to the previous definition in the applicable circular(s) to see what has changed and how it might affect you.

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200.1 – 200.99, Definitions

Non-Federal entity State government (200.90)

• 50 States • District of Columbia• Commonwealth of Puerto Rico• U.S. Virgin Islands• Guam• American Samoa• Commonwealth of the Northern Mariana Islands

Local government Indian Tribe (200.54) Institution of Higher Education (IHE) Nonprofit organization

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200.69 Non‐Federal Entity

New guidance uses the term “contractor” rather than vendor Concept is unchanged

Section 200.330 can be used to determine the difference between a subrecipient and contractor Use of the term contract is not a determinant Substance of the transaction rules

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200.23, Contractor 

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 Social security number Passport number Credit card numbers Biometrics Date and place of birth Mother's maiden name Criminal, medical and financial records, educational transcripts

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200.82, Protected Personally Identifiable Information

Gross income earned by the non-Federal entity that is directly generated by a supported activity or earned as a result of the Federal award during the period of performance, except as provided in Sec. 200.307 paragraph (f), which relates to income after the period of performance.

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200.80, Program Income

Tangible personal property Useful life of more than one year Per-unit acquisition cost which equals or exceeds $5,000 or the

capitalization threshold of the non-Federal entity if lower

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200.33, Equipment

200.94, SuppliesTangible personal property other than those described

in Equipment A computing device is a supply if it doesn’t meet capitalization

thresholds

Subpart B ‐ General Provisions

Establishes uniform administrative requirements, cost principles, and audit requirements for all types of non-Federal entities

Federal awarding agencies must not impose additional or inconsistent requirements, unless Requirement based on Federal statute, regulation, or

Executive Order OMB permits an exception in accordance with 200.102 OMB approves information in the Federal award in accordance

with 200.210

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200.100, Purpose

“Must” means “required”

“Should” indicates best practices or recommended approach

RECOMMENDATION: Use the 2015 version of 2 CFR 200 to ensure you have the correct “shoulds” and “musts”

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FAQ 200.303 ‐ “Should” vs. “Must”

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200.101, Applicability

No Exceptions for Subpart F — Audit Requirements

OMB may allow exceptions for classes of Federal awards

Goal is uniformity Exceptions will be permitted only in unusual circumstances Exceptions for classes of Federal awards or non-Federal entities

will be published on the OMB Web site

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200.102, Exceptions

Subpart C ‐ Pre‐Federal Award Requirements and Contents of Federal Awards

Provides more streamlined guidance to federal agencies on information that is required to be provided to non-federal entities for the purpose of applying for and receiving federal awards

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Subpart C

Incorporates new coverage on fixed amount awards Payments are based on meeting specific requirements of the

Federal Award Accountability is based on performance and results Award amount is negotiated using cost principles as a guide No governmental review of the actual costs incurred Significant changes (i.e., principal investigator, project partner or

scope) must receive prior awarding agency written approval

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Fixed Amount Awards

200.204—Agency review of proposal’s merit

200.205—Agency review of applicant’s risk

May Consider Financial stability Quality of management systems History of performance Reports and findings from audits

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Risk Review

Federal or pass-through agencies can use the risk review process to impose additional requirements or conditions to mitigate risk

Some examples Using reimbursements rather than advance payments Requiring approvals to move to next phase of a project Additional prior approvals Additional reporting and/or monitoring

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200.207, Specific conditions

Subpart D ‐ Post Federal Award Requirements

Standards for Financial and Program Management Property Standards Procurement Standards Performance and Financial Monitoring and Reporting Subrecipient Monitoring and Management Record Retention and Access Remedies for Noncompliance Closeout Post Closeout Adjustments and Continuing Responsibilities Collections of Amount Due

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Post Federal Award Requirements

Non-Federal Entity responsible for effective internal control systems

Best Practices “Standards for Internal Control in the Federal Government”

(Green Book) issued by the Comptroller General of the United States

“Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the TreadwayCommission (COSO)

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200.303, Internal controls

Voluntary committed cost sharing is not expected Cannot be used as a factor in merit review

Cost sharing may only be considered by the awarding agency when required by regulation Must be in the notice of funding opportunity Only mandatory cost sharing or cost sharing included on the

project budget must be included in determining indirect cost rate or allocation of indirect costs

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200.306, Cost Sharing or Matching

Generally based on the requirements in A-102 Sections 200.317 through 200.326

States - property and services purchases must follow the same policies and procedures it uses for procurements from its non-Federal funds

All other non-Federal entities (including Subrecipients of a state) — must have written procurement procedures that reflect the procurement standards

1 year delay for NFPs and IHEs to develop compliant policies and procedures

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Procurement Standards

The non-Federal entity must Use its own documented procurement procedures Oversee contractors Avoid acquisition of unnecessary or duplicative items Use only responsible contractors Maintain sufficient records Have written conflict of interest policies

• Including organizational conflicts of interest

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200.318, General Procurement Standards

Approved procurement methods Procurement by micro-purchases (new) Procurement by small purchase procedures Procurement by sealed bids (formal advertising) Procurement by competitive proposals Procurement by noncompetitive proposals

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300.320, Methods of Procurement to be Followed

Permits a non-Federal entity to make fixed amount subawards Not to exceed the Simplified Acquisition Threshold

The prior written approval of the Federal awarding agency is required

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200.332, Fixed Amount Subawards

Use of open and machine readable formats

Must always provide or accept paper versions of Federal award-related information to and from the non-Federal entity upon request

When original records are electronic and cannot be altered, no need to create &retain paper copies

Can convert paper originals to electronic versions Must have periodic quality control reviews Provide reasonable safeguards against alteration Remain readable94

200.335, Methods for Collection, Transmission and Storage of Information

Failure to comply can result in imposing additional conditions (specific conditions) by the Federal awarding agency or pass-through entity

If not effective: Temporarily withhold cash payments pending correction of

the deficiency Disallow all or part of the cost of the activity or action not

in compliance Wholly or partly suspend or terminate the Federal award Initiate suspension or debarment proceedings Withhold further Federal awards for the project or program Take other remedies that may be legally available

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200.338, Remedies for Noncompliance

Federal award may be terminated by Federal awarding agency (or pass-through entity) in whole or in part: Non-Federal entity noncompliance with award terms & conditions For cause With the consent of the non-Federal entity

Non-Federal entity may terminate the award in writing Setting forth the reasons for termination Effective date In the case of partial termination, the portion to be terminated

Still responsible for closeout, post-closeout adjustments and continuing responsibilities

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200.339, Termination

FAQ: https://cfo.gov/wp-content/uploads/2014/08/2014-08-29-Frequently-Asked-Questions.pdf

Crosswalks: http://www.whitehouse.gov/omb/grants_docs Uniform Guidance Crosswalk from Predominant Source in Existing

Guidance (29 pages) Uniform Guidance Crosswalk to Predominant Source in Existing

Guidance (10 pages) Uniform Guidance Cost Principles Text Comparison (174 pages) Uniform Guidance Audit Requirements Text Comparison (46 pages) Uniform Guidance Definitions Text Comparison (76 pages) Uniform Guidance Administrative Requirements Text Comparison (123

pages)

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More Help

Other, various resources: https://cfo.gov/cofar

Crosswalk for Agency exceptions/clarifications:https://cfo.gov/wp-content/uploads/2014/12/Agency-Exceptions.pdf

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Even More Help

What Will Be Different to You?

Grants Track award dates and terms & conditions Comply with correct standards Controls to identify correct standards and ensure compliance

Cost principles New definitions of allowable costs New types of allowable costs

Procurement Document which standards you follow Prepare to implement new standards, if necessary

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What Will Be Different To You?

Correctly determined which of your grants/incremental funding are subject to new requirements

Implemented procedures and controls to ensure grants comply with applicable requirements

People who perform internal controls: Know which requirements apply to which grants Understand the difference in the requirements Correctly apply new requirements and controls to new

grants.101

What Will We Be Looking For?