1. Uniform Guidance Discussion
SPARC Presentation
Uniform Guidance Discussion

2. Overview of Single Audit Selection
Federal programs are either Type A or Type B.
Type A or B determination performed at statewide level and based on amount of federal expenditures in a given fiscal year.
Type A are higher expenditure programs
Must be audited at least once every 3 years.
Exceptions: Prior year findings; significant changes in personnel or systems.
Type B programs selected based on risk assessment criteria. No 3 year requirement.

3. Planning and Fieldwork Summary
Starting point for planning is the annual Compliance Supplement issued by the Office of Management and Budget (OMB).
We cross-reference to the previous year’s Supplement to determine if any requirement changes.
Not all requirements are tested – only those deemed material. Materiality is based on SEFA expenditures.

4. Planning and Fieldwork Summary (continued)
We conduct risk-assessment meetings as part of planning and throughout fieldwork.
We maintain internal control narratives for all compliance requirements. These are updated annually by the client.
We verify that each control identified has been placed in operation during the fiscal year.

5. Planning and Fieldwork Summary (continued)
Once controls have been identified and verified, we design our test procedures.
For most requirements, we test via sampling procedures.
Sample sizes are based on the risk of material noncompliance. Sizes increased if noncompliance identified.
We design dual-purpose tests of controls and compliance as much as possible for efficiency.

6. For-Profit Subrecipients
Question received:
What is required under Uniform Guidance - how does this differ from other types of subrecipients?
Expectations for flow down requirements and related monitoring for-profit subrecipients.

7. For-Profit Subrecipients
2016 Compliance Supplement: M. SUBRECIPIENT MONITORING
Compliance Requirements
Ensure Accountability of For-Profit Subrecipients
For-profit subrecipients are accountable to the PTE for the use of the Federal funds provided
PTE is responsible for establishing requirements, as necessary, to ensure compliance by for-profit subrecipients for the subaward.

8. For-Profit Subrecipients
2016 Compliance Supplement: M. SUBRECIPIENT MONITORING
Compliance Requirements
Ensure Accountability of For-Profit Subrecipients
The agreement with the for-profit subrecipient must describe applicable compliance requirements  and the for-profit subrecipient's compliance responsibility.
Methods to ensure compliance for Federal awards made to for-profit subrecipients may include pre-award audits, monitoring during the agreement , and post-award audits.

9. For-Profit Subrecipients
Difference from other Subrecipients?
For-profit subrecipients not required to have single audit
Same as other Subrecipients
Must describe applicable compliance requirements
Monitor during agreement
Evaluate risk
See Handout #1

10. For-Profit Subrecipients
Applicable compliance requirements flow down to subrecipients
Monitoring involves judgment
Applicable requirements (complexity)
Risk assessment
Amount or percentage passed through
Types and level of monitoring could vary

11. Subrecipient Risk Assessment
Question received:
Expectations for reliance on the Federal Audit Clearing House (FAC) for single audit status/confirmation, as prescribed by Uniform Guidance, for subrecipient risk assessment

12. Subrecipient Risk Assessment
2016 Compliance Supplement: M. SUBRECIPIENT MONITORING
Compliance Requirements
Evaluate Risk –
Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section (b)).
The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR part 200, subpart F, and the extent to which the same or similar subaward has been audited as a major program;

13. Subrecipient Risk Assessment
Federal Audit Clearinghouse (FAC)
Search for single audits submitted to FAC
Maintain a public database of completed audits
General audit information
Findings information (Yes/No indicators)
Agency information
CFDA, EIN, DUNS
CPA information
Pass-through information
Review single audit reports for results and details.
Note: Single audit results – only one factor of risk assessment

14. Time and Effort Reporting Alternatives
Reference Handout #2 for complete listing of requirements from Part 5 of the Compliance Supplement.
Internal control system must provide assurance charges are accurate, allowable, and properly allocated.
Part 5 wording is broad and gives institutions latitude to design a system that works best for its individual needs.

15. Time and Effort Reporting Alternatives (continued)
Note that the entity’s policies for T&E reporting alternatives are binding, as the entity must comply with its own policies.
Payroll/Project Certifications: Acceptable internal control?
We would need to know more details, but a certification with independent review (i.e. by supervisor) appears to be a well designed control.