Presentation is loading. Please wait.

Presentation is loading. Please wait.

THE SUPER CIRCULAR – “OMNI CIRCULAR” THE ONE-STOP SHOP FOR FEDERAL ASSISTANCE OMB Revised Administrative, Cost, Audit Rules Governing All Federal Grants.

Similar presentations


Presentation on theme: "THE SUPER CIRCULAR – “OMNI CIRCULAR” THE ONE-STOP SHOP FOR FEDERAL ASSISTANCE OMB Revised Administrative, Cost, Audit Rules Governing All Federal Grants."— Presentation transcript:

1 THE SUPER CIRCULAR – “OMNI CIRCULAR” THE ONE-STOP SHOP FOR FEDERAL ASSISTANCE OMB Revised Administrative, Cost, Audit Rules Governing All Federal Grants Presented by Michael Brustein, Esq. Brustein & Manasevit, PLLC

2 Key Dates: Feb 1, 2013NPRM Dec 19, 2013Final Dec 26, 2013Federal Register April 2014New OMB Compliance Supplement June 26, 2014ED Draft EDGAR Changes Dec 26, 2014Final EDGAR Published 2

3 Date of Applicability of Revised Rules OMB stated on 12/20/13All Drawdowns, after December 26, 2014 ? ? ? 3

4 What is covered? A-102 – Administrative Rules State / Local – Part 80 – EDGAR A-110 – Administrative Rules Postsecondary – Part 74 – EDGAR A-87 – Cost Rules – State / Local A-21 – Cost Rules – Rules – Postsecondary A-122 – Cost Rules – Nonprofit A-133 – Audit Rules (>$750,000) 4

5 Who is covered? All “nonfederal entities” expending federal awards 5

6 Reasons for the Change? 1. Simplicity 2. Consistency 3. Obama Executive Order on Regulatory Review  Increase Efficiency  Strengthen Oversight 6

7 Who crafted the changes? “COFAR”  Council on Financial Assistance Reform, and Key Stakeholders  7

8 Inconsistency Between Program Statute and Circular If federal program statute or regulation differs from Omni Circular, then statute / regulation governs. 8

9 Most Significant Change Shift from focus on Compliance to focus on PERFORMANCE!!! 9

10 Performance Auditors (A Federal OIG) and Monitors (Federal and State Pass Through) must look more to “outcomes” than to “process” 10

11 Flexibility The “Omni Circular” adds significant flexibility to way grantee / subgrantee can adopt their own processes 11

12 2 CFR PART Structure of Omni-Circular (p )

13 (p ) 13 Subpart A – Definitions Subpart B – General Provisions Subpart C – Pre Award Requirements Subpart D – Post Award Requirements Subpart E – Cost Principles Subpart F – Audit Requirments

14 Key Definitions 14 Cognizant Agency for Audit (78611) Cognizant Agency for Indirect (78611) Computing Devices (78612) Cooperative Audit Resolution (78612) Cost Objective (78612)

15 15 Internal Control Over Compliance (78615) Major Program (78615) Micro Purchase (78615) Modified Total Direct Cost (78615) Non-Federal Entity (78615)

16 16 Effective Date  (78621)

17 17 Conflict of Interest  (78621)

18 18 Mandatory Disclosures  (78621)

19 19 Financial Management Requirement ( ) Compare to 34 CFR (b)

20 20 Internal Controls  (78625)

21 21 Payment  (78625)

22 22 Program Income  (78627)

23 23 Revision of Budget and Program Plans  (78628)

24 24 Period of Performance  (78629)

25 25 Insurance Coverage  (78629)

26 26 Equipment  (78629)

27 27 Supplies  (78630)

28 Procurement (78631) 28 By states General Procurement Standards Competition Methods of Procurement Cost and Price

29 Monitoring (78635) 29 Contract vs. Grant Pass Through Requirements

30 Record Retention (78636) 30 Retention Collection and Transmission Access

31 Non-Compliance (78637) 31 Remedies Termination Notification Appeals Suspension Collection of Amounts Due

32 32 Subpart E – Cost Principles (78639)

33 33 Policy Guide (78639)

34 Basic Considerations (78640) 34 Composition of Costs Allowability Reasonable Costs Allocability Applicable Credits Prior Written Approval

35 Direct and Indirect Costs (78642) 35 Composition of Costs Direct Costs Indirect Costs

36 36 False Claims Certifications  (78643)

37 37 Promotional Costs  (78645)

38 38 Personnel Compensation  (78646)

39 39 Conferences  (78650)

40 40 Costs of Appeals  (78651)

41 41 Employee Morale  (78652)

42 42 Memberships  (78657)

43 43 Student Activity Costs  (78660)

44 44 Travel Costs  (78661)

45 45 Audits  (78662)

46 46 Audit Requirements  (78662)

47 47 Relation to Other Audits  (78663)

48 48 Audit Findings Follow-Up  (78665)

49 49 Questioned Costs  (78669)

50 50 Major Program Determination  (78670)

51 Questions? 51

52 Disclaimer This presentation is intended solely to provide general information and does not constitute legal advice. Attendance at the presentation or later review of these printed materials does not create an attorney-client relationship with Brustein & Manasevit, PLLC. You should not take any action based upon any information in this presentation without first consulting legal counsel familiar with your particular circumstances. 52


Download ppt "THE SUPER CIRCULAR – “OMNI CIRCULAR” THE ONE-STOP SHOP FOR FEDERAL ASSISTANCE OMB Revised Administrative, Cost, Audit Rules Governing All Federal Grants."

Similar presentations


Ads by Google