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CITY OF ROSEVILLE EMERGING ISSUES UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES,AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS (CONTINUED) ' Internal Controls (Section 200.303) Internal controls should comply with: • "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States and the "Internal Control Integrated Framework" issued by the Committee of Sponsoring Organizations of the Treadway Commission(COSO) ' • Federal statutes,regulations and terms and conditions of the Federal award Internal controls must: • Evaluate and monitor compliance • Take prompt action for noncompliance • Take reasonable measures to safeguard PPII and other sensitive information Procurement Standards (Sections 200.317 through 200.326) Guidelines provide five different procurement methods • Micro-purchases • Small purchases • Sealed bids • Competitive proposals • Noncompetitive proposals Entities must have a documented procurement policy, written standards of conduct covering organizational conflicts of interest and must maintain oversight to ensure that contractors perform in accordance with the terms, conditions and specifications of their contracts or purchase orders. Subrecipient Monitoring (Sections 200.330 through 200.332 and 200.521) 1 The pass-through entity must clearly identify the agreements as a subaward and must provide up to 13 different award identification pieces of information within the contract. There are also other required disclosures described for all requirements imposed by the pass-through entity on the ' subrecipient, indirect cost rate, allowing access to records, etc. An evaluation of each subrecipients risk of noncompliance is also required. Cost Principles—Subpart E of Federal Register Following are some of the notable items in the updated Cost Principles. Indirect/Direct Costs (Sections 200.413-200.414) • Salaries of administrative or clerical staff could be directly charged to a federal program if they meet certain conditions. • Any non-federal entity that has never negotiated an indirect cost rate may elect to charge a de minimis rate of 10% of modified total direct costs which may be used indefinitely • Federally negotiated indirect cost rates must be accepted by all federal awarding agencies (usually). • Any non-federal entity that has a federally negotiated indirect cost rate may apply for a one-time extension of a current negotiated indirect cost rates for a period of up to four years. ' 21