In an effort to reduce administrative burden, clarify guidance and strengthen oversight of federal awards, the OMB (with the supervision of the Council on Financial Assistance Reform - www.cfo.gov/COFAR) published Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards.  The new guidance, located in Title 2 of the Code of Federal Regulations, is effective for all federal awards received after December 25, 2014 and for Single Audits for years ending on or after December 31, 2015.   

The new guidance supersedes and consolidates eight previously separate circulars (OMB Circulars A-21, A-87, A-110, A-122 and Circulars A-89, A-102, A-133 and A-50) into one "Super Circular."  This effectively eliminates overlapping and conflicting provisions in the circulars and improves the consistency of the federal award application process.  In addition to streamlining the related circulars, the new guidance also changes the perception of  federal awards by adding more stringent contractual guidelines, standardizing performance measurement  and creating more enforceable regulations on how direct recipients must monitor their subrecipients. Although the larger impact is on the direct recipients of federal funds, subrecipients could see significant changes to the current year grant agreements and additional oversight on the grant programs and outcomes throughout the year.   

Here are some key changes under the new guidance.

Brian J. Ferguson, CPA, CITP, CISA is a Manager in the Assurance Services Department at Stone Carlie. He specializes in audits of financial statements and OMB audits for not-for-profits. If you have any questions on the topics covered in this newsletter or other audit-related questions, please do not hesitate to contact Brian directly at bferguson@stonecarlie.com, email any member of Stone Carlie's Not-For-Profit Services Group or call 314.889.1100.