Understanding the Uniform Guidance Effective Dates These slides have been excerpted from a GAQC Web event and are intended to help eliminate confusion around the effective dates of the Uniform Guidance

Uniform Guidance Effective Dates For December 31, 2015, year-ends and beyond All single audits performed under Subpart F of the Uniform Guidance Auditees comply with the new administrative requirements and cost principles for federal awards made on or after December 26, 2014, and to incremental funding made on or after that date Auditees comply with the “old” OMB administrative requirements and cost principles for awards made prior to December 26, 2014, until those funds run out With regard to subawards, the effective date of the Uniform Guidance is the same as the effective date of the federal award from which the subaward is made Auditor compliance testing will test against both the old criteria and the new criteria depending on federal award dates

Be Sure to Understand Who Follows What Rule! Auditees Old awards: Old OMB cost principles and administrative requirements (e.g., OMB Circulars A-87, A-110, A-122, etc.) New awards and incremental funding: Subpart D and E of the Uniform Guidance Certain sections of Subpart F (e.g., §200.508 through .512) Auditors For testing compliance: Auditors audit against the criteria that the auditee is required to follow (see auditee section) For performing the audit: Subpart F of the Uniform Guidance The assumption throughout is that the client’s fiscal year end is June 30, 2016, unless otherwise stated.

Uniform Guidance Audit Requirements Effective for audits of fiscal years beginning on or after December 26, 2014 Applicability of UG audit requirements based on the entity’s fiscal year beginning date (and not individual federal award dates) There is no circumstance where the auditor would perform the audit under both OMB Circular A-133 AND the UG Early adoption of the UG audit requirements was not permitted

1 What do Auditees Follow? Client has expended funds under a federal award that was awarded before December 26, 2014. How does the auditee determine the appropriate cost principles and administrative requirements to follow?

1 What do Auditees Follow? The effective date for complying with the UG cost principles and administrative requirements is based on the federal award date. In this example, since the federal award date was before 12/26/2014, the pre-UG cost principles and administrative requirements would apply. Source: 2 CFR 200.110 and COFAR FAQ .110-12

2 What do Auditees Follow? Client has a multi-year federal award that was issued on 1/1/2014 that results in new funding each year. What award date is used to determine the appropriate cost principles and administrative requirements to follow?

2 What do Auditees Follow? Assuming there has been no incremental funding, the federal award date of 1/1/2014 would be used; This means that the multi-year award is subject to the pre-UG requirements for each of the multiple years. Source: 2 CFR 200.110 and COFAR FAQs .110-5, .110-7, .110-12 and .110-13

3 What do Auditees Follow? When is funding considered “incremental funding” and why is it important?

3 What do Auditees Follow? The UG applies to funding increments to existing awards in cases where the federal agency considers the funding increments to be an opportunity to modify the terms and conditions of the award. Existing federal awards that do not receive incremental funding with new terms and conditions will continue to be governed by the terms and conditions of the federal award. Source: COFAR FAQs .110-7, .110-12 and .110-13

4 What do Auditees Follow? Client received a U.S. Department of Housing and Urban Development (HUD) loan in 2010 that has a 40 year restriction on use of the related property. The loan is subject to single audit as it has continuing compliance requirements. Would this loan be subject to the UG or the pre-UG requirements?

4 What do Auditees Follow? If HUD has not indicated otherwise, the HUD loan would continue to be subject to the pre-UG requirements. If there is any doubt about which requirements apply to these or any other loans, the auditee should contact the program official listed in Appendix III of the OMB Compliance Supplement. Source: 2 CFR 200.110 and COFAR FAQs .110-7, .110-12 and .110-13

5 What do Auditees Follow? Client expended funds under two subawards: One received in 10/2014 Second received 10/2015 Would these subawards be subject to the UG or the pre-UG requirements?

5 What do Auditees Follow? Source: COFAR FAQ .110-11 It depends! Effective date of the UG cost principles and administrative requirements for subawards is the same as the effective date of the underlying federal awards. That is, the requirements for a subaward, no matter when made, flow from the requirements of the original federal award date to the pass-through entity (PTE). Need to know the PTE federal award dates to answer this question. Source: COFAR FAQ .110-11

6 What do Auditees Follow? If the 2-year grace period for adopting the UG procurement requirements has been elected by a client, when does it become effective?

6 What do Auditees Follow? Client must implement the procurement standards 2 full fiscal years after the effective date of the UG (i.e., 2 full fiscal years after December 26, 2014) A 12/31 year-end client has to implement procurement standards for its fiscal year beginning 1/1/17 (i.e., its 12/31/17 fiscal year-end) A 6/30 year-end client has to implement the UG procurement standards for its fiscal year beginning 7/1/17 (i.e., its 6/30/18 fiscal year-end) Source: 2 CFR 200.110(a) and COFAR FAQ .110-6

7 What do Auditees Follow? If the client has elected the 2-year grace period for adopting the UG procurement requirements, do they need to notify the federal government?

7 What do Auditees Follow? No. There is no notification requirement under the UG. However, a non-federal entity must document whether it is in compliance with the old or new standards and must meet the documented standard. Source: COFAR FAQ .110-6

8 What do Auditors Follow? Client has several grants awarded before 12/26/14, and several grants awarded after 12/26/14. Does the auditor perform the audit under both Circular A-133 and the UG?

8 What do Auditors Follow? No. There is no circumstance where the auditor would perform the audit under Circular A-133 and the UG. The effective date for the UG audit requirements is based on the client’s fiscal year and not individual federal award dates. Individual award dates are relevant to the auditor in terms of the criteria used to perform testing. Source: 2 CFR 200.110(b) and COFAR FAQ .110-12