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2018 HUD Start Up 2 CFR 200.

Published bySri Irawan Modified over 5 years ago

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Presentation on theme: "2018 HUD Start Up 2 CFR 200."— Presentation transcript:

1 2018 HUD Start Up 2 CFR 200

2 Financial Grant management
Super Circular Policies/ Internal Controls Common Financial Findings

3 Super-Circular Super Circular 2 CFR Part 200
Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Stuff Formerly found in…… A-21, 87, 89, 102, 110, 122 and 133

4 Super Circular Background
12/26/13 – OMB published final guidance on this endeavor 12/26/14 – OMB and Federal Awardmaking Agencies publish joint interim final rule HUD adopted this guidance at 2 CFR Part 2400 HUD amended 24 CFR Parts 84 and 85

5 Super Circular Purpose
Streamline: Administrative Requirements Cost Principles Audit Requirements

6 Super Circular Purpose
Outcomes Anticipated: Improved Performance and Outcomes Ensure Financial Integrity of Taxpayer Dollars when Partnering with non-Federal Stakeholders

7 Super Circular Reforms
Eliminate Duplicative/Conflicting Guidance Focus on Performance Consistent Treatment of Costs Limit Allowable Costs Strengthen Oversight Single Audit Threshold Raised from $500,000 to $750,000

8 Super-Circular Super Circular Let’s Take a Walk 2 CFR Part 200
Subpart A – Acronyms and Definitions Subpart B – General Provisions Subpart C – Pre-Federal Award Requirements and Contents of Federal Awards

9 Super-Circular Super Circular Let’s Take a Walk 2 CFR Part 200
Subpart D – Post-Federal Award Requirements Subpart E – Cost Principles Subpart F – Audit Requirements

10 Highlights of Subpart A
Super-Circular Super Circular Highlights of Subpart A Definitions including such things as…. Non-Federal Entity Pass-Through Entity Cognizant Agency for Audit Supplies Allocation Real Property

11 Highlights of Subpart B
Super-Circular Super Circular Highlights of Subpart B General provisions Basic Purpose of 2 CFR 200 Applicability to Federal Awards (Chart) Conflict of Interest

12 Highlights of Subpart C
Super-Circular Super Circular Highlights of Subpart C Prescribes the instructions and other pre-award information to be used in the funding announcement and application process Don’t be Naughty – Section authorizes Federal Agencies to impose additional conditions on recipients with poor performance

13 Highlights of Subpart D
Super-Circular Super Circular Highlights of Subpart D **This subpart packed with info for you** Performance Measurement Financial Management Internal Controls – including protecting Personally Identifiable Information (PII) Payment Cost Sharing or Matching

14 More Highlights of Subpart D
Super-Circular Super Circular More Highlights of Subpart D Property Standards Equipment Supplies Procurement Standards Monitoring – including subrecipient monitoring Record Retention

15 Highlights of Subpart E
Super-Circular Super Circular Highlights of Subpart E **Read this Subpart** Key Point – This subpart covers the allowability of costs Good News – Most of this info is unchanged Bad News – If you don’t have a handle on this the consequences are painful

16 Highlights of Subpart E
Super-Circular Super Circular Highlights of Subpart E Direct Costs Indirect Costs – includes a new de minimis rate Details on more than 50 specific costs from Advertising to Travel Costs

17 Highlights of Subpart E
Super-Circular Super Circular Highlights of Subpart E Key Costs that may affect You Audit Services Compensation – Personal Services & Fringe Benefits Contributions and Donations Entertainment Costs

18 Highlights of Subpart E
Super-Circular Super Circular Highlights of Subpart E Equipment Lobbying Materials and Supplies Professional Service Costs Publication and Printing Costs Travel Costs

19 Highlights of Subpart F
Super-Circular Super Circular Highlights of Subpart F The End is Near…. Audit Stuff Increased Single Audit Threshold – up to $750,000 Responsibilities, etc.

20 Internal Controls and Compliant Policies
Establishing Internal Controls COSO Internal Control Framework Establish the Control Environment Conduct Risk Assessment Implement Control Activities Implement Information and Communication Systems Monitor Internal Controls Procurement Cost Allocations Documenting Allowable Costs/Match Personnel Activity Reports Conflict of Interest

21 Financial Grant management
Super Circular You Want More? Read Notice SD See HUD Integrity Bulletins Click on the Council of Financial Assistance Reform Page at Read the entire 100 pages of 2 CFR 200

22 Common Findings Common Findings – Recordkeeping 2 CFR 200.403(g)
Costs must be adequately documented in order to be allowable under Federal awards

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