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Among Other Matters Specifically Applicable to Auditors, Changes to the Uniform Guidance Include: <br />• Raising both the threshold that triggers a Single Audit and the threshold for Type A/B program <br />determination to $750,000. <br />• Changing the high -risk program criteria for Type A programs. <br />• Reducing the number of high -risk Type B programs that must be tested as major programs. <br />• Revising the Type B small program floor. <br />• Reducing the percentage of coverage requirement to 40 percent for normal auditees and <br />20 percent for low -risk auditees. <br />• Revising the criteria for low -risk auditee status. <br />• Increasing the threshold for reporting findings to $25,000 in questioned costs and requiring more <br />detailed information to be reported. <br />Effective Dates: <br />Year beginning January 1, 2015 — <br />• All administrative requirements and cost principles will apply to new awards made after <br />December 26, 2014. <br />• Governmental entities are required to comply with the Uniform Guidance once the new <br />regulations are in effect at the Federal government level (December 26, 2014). <br />• Any funding drawdowns made after January 1, 2015 must comply with the Uniform Guidance. <br />• Must document whether the entity is in compliance with the old or new procurement standards <br />listed in Subpart D, Sections 200.317-200.326. The federal government has provided a two-year <br />grace period for implementing the new procurement standards. <br />Year beginning January 1, 2016 — <br />• All administrative requirements and cost principles will apply to new awards made after <br />December 26, 2014. <br />• Subpart F — Audit Requirements are applicable. <br />Year beginning January 1, 2017 — <br />• Must have implemented the new procurement standards of the Uniform Guidance, if the <br />government initially elected the two-year grace beginning January 1, 2015. <br />• At this point, all of the new Uniform Guidance at Title 2 CFR 200 is applicable. <br />Recommended Action Items: <br />We recommend that award recipients familiarize themselves with the new requirements contained in the <br />Uniform Guidance and develop a plan to become compliant with the new regulations. <br />Consider the following — <br />• Attend training on the new uniform administrative requirements. <br />• Identify needed policy and procedure changes, especially in the areas of: <br />o Financial management <br />o Payment <br />o Procurement <br />o Compensation <br />o Travel costs <br />• Identify internal controls that might need to be established or modified. <br />• Determine who within your organization is responsible for each action item. <br />• Determine the timing of each action item. <br />• Determine when you will implement the new procurement standards and document in writing. <br />-23- <br />