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i ' CITY OF ROSEVILLE EMERGING ISSUES UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES,AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS (CONTINUED) Time and Effort Reporting (Section 200.430) Charges to Federal Awards must be based on records that accurately reflect the work performed. ' • Records are to be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated • There is flexibility in process used to meet those standards ' • Personnel activity reports not specifically required • Maintained budget estimates may be used for interim accounting purposes, provided that, the non-federal entity's system of internal controls includes processes to review after-the- fact interim charges made to a Federal Award based on budget estimates to ensure adjustments are made so final amounts to Federal Awards are proper. Audit Requirements—Subpart F of Federal Register Following are some of the notable items in the updated Audit Requirements. • Single Audit threshold raised from $ 500,000 in Federal Awards per year to $ 750,000 in Federal awards per year • Major program determination changes include: • Type A/B program threshold is a sliding scale with a minimum of$ 750,000 • Percentage of coverage rule changes to 40% (50% currently) for non-low risk auditees ' and 20% (25% currently) for low risk auditees • Updated criteria for a low-risk auditee • Going concern is incorporated • Cognizant/oversight agency can no longer waive exception • Reporting for questioned costs threshold raised from $ 10,000 to $ 25,000 Other Items of Interest • List of items requiring prior written approval (Section 200.407) • Advertising and public relations clarified, include program outreach(Section 200.421) • Conference spending clarified (Section 200.432) • Employee "morale" costs eliminated (Section 200.437) Example of Strategy to Implement OMB Grant Reform Changes 1. Understand grant reform changes 2. Assign an internal expert who will be responsible for leading effort(time, resources and availability) 3. Establish a team and include those in program, financial and budget sides of federal grant management 4. Develop a plan and concentrate on areas of most significance first 5. Obtain approval from management and those charged with governance as it relates to policy changes 6. Attain/Provide training on new requirements and new entity specific policies and procedures 7. Monitor plan and focus on areas of most significant change I I 1 22