In December 2013, the OMB issued Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance). The Uniform Guidance supersedes, streamlines, and consolidates eight existing OMB Circulars, including A-87 and A-133, into one document. In December 2014, a number of federal agencies and departments jointly published an interim final rule, Federal Awarding Agency Regulatory Implementation of Office of Management and Budget’s Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, which implements the Uniform Guidance across federal grant-making agencies. This rule, which is in the December 19, 2014, Federal Register, is necessary in order to incorporate the Uniform Guidance into regulation and thus make it effective. The interim final rule will allow for additional feedback on the rule during a 60-day public comment period. The interim final rule is effective for new awards made on or after December 26, 2014.
Education and Communication
Federal award recipients should be implementing certain changes now, as the Uniform Guidance is effective for both 2015 new awards and funding increments to existing awards. Key items include:
- Understanding the various effective dates.
- Reading and learning the new requirements.
- Prioritizing and focusing on the most significant areas first (e.g. procurement, internal control, subrecipient monitoring, time and effort, indirect cost allocation).
- Making appropriate changes to policies and procedures where necessary. Involving senior management in the process is crucial to its success.
- Communicating and training programmatic personnel on changes to policies and procedures.
Publicly Available Resources
The following resources are available to the public:
- The Federal Register publication of the Uniform Guidance requirements is available here.
- The Federal Register publication for the interim final rule implementing the Uniform Guidance across federal grant-making agencies is available here.
- A September 25, 2014, webinar sponsored by the AICPA Government Audit Quality Center outlining the new cost principles, time and effort reporting, procurement and other administrative requirements is available here.
- The Council on Financial Assistance Reform (COFAR) website (https://cfo.gov/cofar) has several resources including FAQs, crosswalks of the superseded guidance to and from the new guidance, and a webcast training series.
More Guidance is on the Way
Such far-reaching, complex changes automatically dictate a need for even more guidance. Expect the OMB’s 2015 Compliance Supplement to be significantly revised. At a minimum, it would be:
- Updated to reflect the changed audit requirements.
- Updated to address awards made before December 26, 2014, as well as new awards or funding increments made on or after that date.
- Revised to delete the compliance requirements for Davis-Bacon Act and Real Property Acquisition and Relocation Assistance (with discussions throughout changed to refer to 12 compliance requirements).
In addition, we have no doubts that the AICPA and other CPE providers will offer several courses on the Uniform Guidance and/or the 2015 Compliance Supplement.