Single Audit UpdatesUniform Guidance

Uniform Guidance –June 30, 2016 Audit Requirements

Key differences from current requirements

• Increases audit threshold from $500,000 to $750,000

• Type A/B threshold – minimum increases from $300,000 to $750,000

• High-risk Type A and Type B program criteria

• Percentage of coverage down from 50/25% to 40/20%

• Low-risk auditee criteria

• Schedule of expenditures of federal awards changes

• Audit findings (threshold from $10,000 to $25,000)

Uniform Guidance –Greater emphasis on internal controls

Has your school district contemplated each compliance requirement and developed and implemented internal controls to ensure compliance with each?

Do you periodically review and monitor the controls?

Your Responsibilities as an Auditee

Internal Controls (Section 200.303)• Moved from audit requirements to post-award requirements

• Organization must establish and maintain effective internal controlover Federal awards to provide reasonable assurance that awards are being managed in compliance with laws and regulations

• Internal controls should be in compliance with COSO and the Standards for Internal Control in the Federal Government (the “Green Book”)

• Must take prompt action when noncompliance is identified

• Must take reasonable measures to safeguard personally identifiable information and other information deemed sensitive

Uniform Guidance –Greater emphasis on internal controls

17 principles of effective internal control (COSO Framework)

Control Environment

1. Demonstrates commitment to integrity and ethical values

2. Exercises oversight responsibility

3. Establishes structure, authority and responsibility

4. Demonstrates commitment to competence

5. Enforces accountability

Risk Assessment

6. Specifies suitable objectives

7. Identifies and analyzes risk

8. Assesses fraud risk

9. Identifies and analyzes significant change

Control Activities10. Selects and develops control activities

11. Selects and develops general controls over technology

12. Deploys through policies and procedures

Information & Communication

13. Uses relevant information

14. Communicates internally

15. Communicates externally

Monitoring Activities16. Conducts ongoing and/or separate evaluations

17. Evaluates and communicates deficiencies

Uniform Guidance –Standards for Internal Control in the Federal Government (Green Book)

Know what the requirements are!

Matrix of Compliance Requirements (Nutrition Cluster)

Uniform Guidance - Resources

https://cfo.gov/cofar/

Uniform Guidance - Resourceshttp://www.whitehouse.gov/omb/grants

Uniform Guidance - procurement

Purchases using federal funds between $3,000 and $10,000

• Federal guidelines do require competitive procurement methods

• Intended to be relatively simple and informal

• Quotations required from more than one source

• Sources may be online search, public websites, phone quotation, etc.

Uniform Guidance - procurement

Should your District classify equipment purchased with a federal grant costing less than $5,000 as a supply?

NO

Uniform Guidance - procurement

Must maintain written standards of conduct covering conflicts of interest with respect to employees engaged in the selection, award, and

administration of contracts, including disciplinary actions for violations

Definition of supplies revised to include computer equipment with an acquisition cost of less than $5,000

Contracting with small and minority business, women’s business enterprises and labor surplus area firms