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A U D I T

Single Audit Training – Module II

California State University


Module II

Overview of 14

Standard

Compliance

Requirements


Understanding the Compliance Requirements

A – Activities Allowed

B – Allowable Costs

C – Cash Management

D – Davis Bacon Act

E – Eligibility

F – Equipment Management

G – Matching, Level of Effort,

Earmarking

H – Period of Availability

I – Procurement, Suspension &

Debarment

J – Program Income

K – Real Property Relocation

Assistance

L – Reporting

M – Subrecipient Monitoring

N – Special Tests and Provisions


ACTIVITES ALLOWED/ ALLOWABLE COSTS


A/B Activities Allowed/Allowable Costs

Activities Allowed

• This type of compliance requirement specifies the activities that can or cannot be funded under a specific program.

• The specific requirements for activities allowed or unallowed are unique to each Federal program and are found in the laws, regulations, and the provisions of contract or grant agreements pertaining to the program.


A/B Activities Allowed/Allowable Costs, Con’t

Allowable Costs

• In order to receive cost reimbursement under Federal awards, the department or agency usually submits claims asserting that allowable and eligible costs (direct and indirect) have been incurred in accordance with A-87, A-21 or A-122.

• Applicable OMB Circulars: OMB Circular A‑87, “Cost Principles for State, Local, and Indian Tribal

Governments.”

OMB Circular A-21, “Cost Principles for Educational Institutions.”

OMB Circular A-122, “Cost Principles for Non-Profit Organizations.”

All three circulars establish principles and standards for determining allowable direct and indirect costs for Federal awards.



• Allowability of Costs - General Criteria Reasonable and Necessary - Costs must be reasonable and necessary for the

performance and administration of Federal awards. Allocable - Costs must be allocable to the Federal awards under the

provisions of the cost principles. A cost is allocable to a particular cost objective (e.g., a specific function, program, project, department, or the like) if the goods or services involved are charged or assigned to such cost objective in accordance with relative benefits received.

Consistency - Costs must be given consistent treatment through application of those generally accepted accounting principles appropriate to the circumstances. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances was allocated to the Federal award as an indirect cost.



• Allowability of Costs - General Criteria Con’t Conformity to Laws, Regulations and Sponsored Agreements - Costs must

conform to any limitations or exclusions set forth in the circulars, Federal laws, State or local laws, sponsored agreements, or other governing regulations as to types or amounts of cost items.

Transactions that Reduce or Offset Direct or Indirect Costs - Costs must be net of all applicable credits that result from transactions that reduce or offset direct or indirect costs. Examples of such transactions include purchase discounts, rebates or allowances, recoveries or indemnities on losses, insurance refunds or rebates, and adjustments for overpayments or erroneous charges.

Costs Documentation - Costs must be documented in accordance with OMB Circular A-110 for non-profit organizations and institutions of higher education or the A-102 Common Rule for State, local and Indian tribal governments.



Eligible Costs

• Direct costs are those that can be identified specifically with a particular final cost objective

• Indirect costs are those that have been incurred for common or joint purposes and not readily assignable to the final cost objective. Indirect costs are normally charged to Federal awards by the use of an indirect cost rate.


A/B Time and Effort Reporting (Payroll) —Not-for-Profit A-122

Effort reports are required for all employees (professional and nonprofessional) whose compensation costs are directly charged to federal awards, in whole or in part Must reflect an after-the-fact determination of the actual activity

Required to account for 100 percent of the employee’s time

Must be signed by the individual employee or by a responsible official having first hand knowledge of the employee’s activity

Required to be prepared at least monthly

Documentation of the number of hours worked each day must be maintained for all non-professional employees


A/B Time and Effort Reporting (Payroll) —Higher Ed A-21

• Multiple methods/systems are acceptable, but common criteria include: Must be an “after-the fact” confirmation or determination certified by

the employee or a supervisor with first-hand knowledge of the employee’s work

Must allow for confirmation of activity allocable to each sponsored agreement

Must reflect 100 percent of employee’s effort/salary

• Example methods are: Plan Confirmation, After the Fact Activity Records, and Multiple Confirmation Record


A/B Time and Effort Reporting (Payroll) —Higher Ed A-21 (Con’t)

• Plan Confirmation Professorial and professional staff wages are based on budgeted

work activity

Modification should be made for significant changes in employee’s salary or work activity; modification should be approved by responsible official

Requires an annual signed certification of effort by employee, principal investigator, or responsible official(s)

An institution shall not be required to provide additional support or documentation for the effort actually performed.



• After-the-Fact Activity Record Reflect an after-the-fact reporting of the percentage distribution of activity of

employees

Requires certifications for professorial and professional staff for each academic term (semester, trimester, quarter), but not less frequently than every six months

Requires certifications for all other employees no less frequently than monthly

Certifications must be signed by the employee, principal investigator, or responsible official(s)

Where the institution uses time cards or other forms of after-the-fact payroll documents as original documentation for payroll and payroll charges, such documents shall qualify as records for this purpose, provided that they meet all other requirements



• Multiple Confirmation Record Requires records to reflect distribution of activities between direct and indirect

activities

May use estimates to charge personal service costs to programs so long as adjustments to actual activity are made

Requires certifications for professorial and professional staff signed by employee or direct supervisor each academic term (semester, trimester, quarter), but not less frequently than every six months

Where the institution uses time cards or other forms of after-the-fact payroll documents as original documentation for payroll and payroll charges, such documents shall qualify as records for this purpose, provided that they meet all other requirements


A/B Time and Effort Reporting (Payroll) —State & Local Gov’t A-87

• Employee works solely on a single federal award Periodic certification that the employee worked solely on the award is required

Certification is required at least semi-annually

Must be signed by individual or supervisor having first-hand knowledge of the work performed by the employee

• Employee works on multiple activities Salary Distribution required to be supported by personnel activity report

Must be an “after-the-fact” determination of actual activity.

Must account for 100 percent of employee’s activity/salary.

Required to be prepared monthly.

Must be signed by employee.


A/B Time and Effort Reporting (Payroll) —State & Local Gov’t A-87, Con’t

• Budget estimates determined before the services are performed do not qualify as support but may be used for interim purposes, provided that: The system produces reasonable approximations of the actual activity.

Comparisons of monthly actual to budgeted are made at least quarterly with adjustments to actual being recorded quarterly or annually depending on the accuracy of the estimates.

The budget estimates or other distribution percentages are revised at least quarterly, if necessary, to reflect changed circumstances.


Indirect Costs

• Indirect costs are those costs that benefit common activities and, therefore, cannot be readily assigned to a specific direct cost objective or project.

• Sometimes award-specific indirect cost rates are negotiated that are different from those set forth in negotiated rate agreements. Terms and conditions in an award specific to indirect cost rates take precedence over indirect cost rates set forth in negotiated agreements.


Indirect Costs (Con’t)

• Three different types of indirect cost rates can be approved by the cognizant agency for indirect cost negotiation: Predetermined rates - rates established for the current or multiple future

period(s) based on current data (usually data from the most recently ended fiscal year, known as the base period). Predetermined rates are not subject to adjustment, except under very unusual circumstances.

Fixed rates - rates based on current data in the same manner as predetermined rates, except that the difference between the costs of the base period used to establish the rate and the actual costs of the current period is carried forward as an adjustment to the rate computation for a subsequent period.

Provisional rates - temporary rates used for funding and billing indirect costs, pending the establishment of a final rate for a period.


Indirect Costs – Not-for-Profit A-122

• To recover indirect costs, Not-for Profit Organizations (NPOs) prepare ICRPs. The ICRP is the rate calculation and supporting schedules used to arrive at the indirect cost pool amounts and the base amounts. A NPO which has not previously established an indirect cost rate with a

Federal agency shall submit its initial indirect cost proposal immediately after the organization is advised that an award will be made and, in no event, later than three months after the effective date of the award.

Organizations that have previously established indirect cost rates must submit a new indirect cost proposal to the cognizant agency within six months after the close of each fiscal year.


Indirect Costs – Not-for-Profit A-122 (Con’t)

• While it is not possible to specify the types of costs that will be indirect, there are three major categories of indirect costs for NPOs: Depreciation and Use Allowance - Costs of the organization’s buildings,

capital improvements to land and buildings, and equipment. Interest on debt associated with certain buildings, equipment, and capital improvements.

Operation and Maintenance - Administration, operation, maintenance, preservation, and protection of the organization’s physical plant.

General and Administrative - Overall general executive, and administration of the organization and other expenses of a general nature that do not relate solely to any major function of the organization.


Indirect Costs – Higher Ed A-21

• In order to recover indirect costs, educational institutions must prepare indirect cost rate proposals (ICRPs) in accordance with the guidelines provided in A-21 and submit to the cognizant agency for approval.

• Indirect costs are defined into two broad categories: “Facilities” is defined as depreciation and use allowance, interest in debt

associated with certain buildings, equipment, and capital improvements, operation and maintenance expenses, and library expenses.

“Administration” is defined as general administration and general expenses, departmental administration, sponsored project administration, student administration and services, and all other types of expenditures not listed specifically under one of the facility categories.


Indirect Costs – State & Local Gov’t A-87

• The indirect cost rate proposal (ICRP) provides the documentation prepared by a State/local department or agency, to substantiate its request for the establishment of an indirect cost rate. The indirect costs include: Costs originating in the department or agency carrying out Federal awards,

and

Costs of central governmental services distributed through the State/local-wide central service Cost Allocation Plan (CAP) that are not otherwise treated as direct costs.

• The ICRPs are based on the most current financial data and are used to either establish predetermined, fixed, or provisional indirect cost rates or to finalize provisional rates.


CASH MANAGEMENT


C. Cash Management

• Two basic methods of program payments made to the auditee: Cash Advance Basis

Cost Reimbursement


C. Cash Management, Con’t

• Reimbursement basis - program costs must be paid for by entity funds before reimbursement is requested from the Federal Government.

• Funds are advanced - recipients must follow procedures to minimize the time elapsing between the transfer of funds from the U.S. Treasury and disbursement. When advance payment procedures are used, recipients must

establish similar procedures for subrecipients.


C. Cash Management, Con’t

• Interest will be earned on funds advanced that are not expended Interest earned on advances by local government grantees and

subgrantees is required to be submitted promptly, but at least quarterly, to the Federal agency. Up to $100 (local government) or $250 (not-for-profit) per year may be kept for administrative expenses.


DAVIS-BACON


D. Davis-Bacon Act

• Generally applicable to construction contracts in excess of $2,000 financed by Federal assistance funds.

• Requires all laborers and mechanics to be paid wages not less than those established for the locality of the project (prevailing wage rates) by the DOL.


ELIGIBILITY


E. Eligibility

• Three major categories: Eligibility for Individuals

Eligibility for Group of Individuals or Area of Service Delivery

Eligibility for Subrecipients

• The specific requirements for eligibility are unique to each Federal program and are found in the laws, regulations, and the provisions of contract or grant agreements pertaining to the program.


E. Eligibility, Con’t

For some Federal programs with a large number of people receiving benefits, the non-Federal entity may use a computer system for processing individual eligibility determinations and delivery of benefits.

Often these computer systems are complex and will be separate from the non-Federal entity’s regular financial accounting system.


EQUIPMENT AND REAL PROPERTY

MANAGEMENT


F. Equipment and Real Property Management

• Equipment means tangible nonexpendable property, including exempt property, charged directly to the award having a useful life of more than one year and an acquisition cost of $5,000 or more per unit.

• Title to equipment acquired by a non-Federal entity with Federal awards vests with the non-Federal entity.


F. Equipment and Real Property Management, Con’t

• Equipment records shall be maintained

• Physical inventory of equipment shall be taken at least once every two years and reconciled to the equipment records,

• Appropriate control system shall be used to safeguard equipment

• Equipment shall be adequately maintained

• Equipment no longer needed for a Federal program (with a current per unit fair market value of $5,000 or more) may be retained or sold but the Federal agency has the right to a proportionate share of the current fair market value.


MATCHINGLEVEL OF EFFORT

EARMARKING


G. Matching, Level of Effort & Earmarking

• Matching or cost sharing includes requirements to provide contributions (usually non-Federal) of a specified amount or percentage to match Federal awards. Matching may be in the form of allowable costs incurred or in-kind

contributions (including third-party in-kind contributions).


G. Matching, Level of Effort & Earmarking, Con’t

Basic criteria for acceptable matching: Are verifiable from the non-Federal entity’s records.

Are necessary and reasonable for proper and efficient accomplishment of project or program objectives.

Are allowed under the applicable cost principles.

Are not paid by the Federal Government under another award, except where authorized by Federal statute to be allowable for cost sharing or matching.


G. Matching, Level of Effort & Earmarking, Con’t

• Level of effort includes requirements for:

(a) a specified level of service to be provided from period to period,

(b) a specified level of expenditures from non-Federal or Federal sources for specified activities to be maintained from period to period, and

(c) Federal funds to supplement and not supplant non-Federal funding of services.

• Earmarking includes requirements that specify the minimum and/or maximum amount or percentage of the program’s funding that must/may be used for specified activities, including funds provided to subrecipients. Earmarking may also be specified in relation to the types of participants

covered.


PERIOD OF AVAILABILITY


H. Period of Availability

• Federal awards may specify a time period during which the non-Federal entity may use the Federal funds (i.e., July 1, 2007 through June 30, 2008).

• Where a funding period is specified, a non-Federal entity may charge to the award only costs resulting from obligations incurred during the funding period and any pre-award costs authorized by the Federal awarding agency.

• If authorized by the Federal program, unobligated balances may be carried over and charged for obligations of the subsequent funding period.


• Obligations - means the amounts of orders placed, contracts and subgrants awarded, goods and services received, and similar transactions during a given period that will require payment by the non-Federal entity during the same or a future period

• Non-Federal entities shall liquidate all obligations incurred under the award not later than 90 days after the end of the funding period (or as specified in a program regulation) to coincide with the submission of the annual Financial Status report

• The Federal agency may extend this deadline upon request

H. Period of Availability, Con’t



IF AN OBLIGATION IS FOR -- THE OBLIGATION IS MADE --

(a) Acquisition of real or personal property.

On the date on which the Entity or subgrantee makes a binding written commitment to acquire the property.

(b) Personal services by an employee of the Entity or subgrantee.

When the services are performed.

(c) Personal services by a contractor who is not an employee of the Entity or subgrantee.

On the date on which the Entity or subgrantee makes a binding written commitment to obtain the services.

(d) Performance of work other than personal services.

On the date on which the Entity or subgrantee makes a binding written commitment to obtain the work.



IF AN OBLIGATION IS FOR -- THE OBLIGATION IS MADE --

e) Public utility services. When the Entity or subgrantee receives the services.

(f) Travel. When the travel is taken.

(g) Rental of real or personal property.

When the Entity or subgrantee uses the property.

(h) A pre-agreement cost that was properly approved by the Entity under the applicable cost principles.

On the first day of the subgrant period.


PROCUREMENT SUSPENSION AND

DEBARMENT


I. Procurement, Suspension and Debarment

• Procurement The Entity must use procurement policies that comply with federal

guidelines.

• Suspension and Debarment The Entity is prohibited from contracting with or making

subawards under covered transactions to parties or their principals that are suspended or debarred.

Covered transactions include contracts for goods or services equal to or in excess of $25,000 and all subrecipients


I. Procurement, Suspension and Debarment, Con’t

Methods of procurement to be followed

• Procurement by small purchase procedures. Small purchase procedures are those relatively simple and informal

procurement methods for securing services, supplies, or other property that do not cost more than $25,000

price or rate quotations shall be obtained from an adequate number of qualified sources

• Procurement by sealed bids (formal advertising). Bids are publicly solicited and awarded to the lowest responsible bidder. Preferred method for procuring construction

• Procurement by noncompetitive proposals Solicitation of a proposal from only one source (i.e. sole source).



• Contract cost and price. Must perform a cost or price analysis in connection with every procurement

action including contract modifications.

The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, grantees must make independent estimates before receiving bids or proposals.

A cost analysis must be performed when the offeror is required to submit the elements of his estimated cost, e.g., under professional, consulting, and architectural engineering services contracts.



Administration & Records of Procurement Transactions:

• Grantees and subgrantees will maintain records sufficient to detail the significant history of a procurement. These records will include, but are not necessarily limited to the following:

rationale for the method of procurement,

selection of contract type,

contractor selection or rejection

basis for the contract price.



Suspension and Debarment

• Non-Federal entities are prohibited from contracting with or making subawards to parties that are suspended or debarred or whose principals are suspended or debarred. Procurement contracts for goods and services awarded under a grant or

cooperative agreement that are expected to equal or exceed $25,000

All subawards to subrecipients are considered covered transactions

• This verification may be accomplished by checking the Excluded Parties List System (EPLS)


PROGRAM INCOME


J. Program Income

• Program income is gross income received that is directly generated by the federally funded project during the grant period.

• If authorized by Federal regulations or the grant agreement, costs incident to the generation of program income may be deducted from gross income to determine program income.


J. Program Income, Con’t

• Program income includes, but is not limited to: Income from fees for services performed,

Use or rental of real or personal property acquired with grant funds,

Sale of commodities or items fabricated under a grant agreement,

Payments of principal and interest on loans made with grant funds.


J. Program Income, Con’t

• Program income does not include: Interest on grant funds (covered under “Cash Management”),

Rebates, credits, discounts, refunds, etc. (covered under “Allowable Costs/Cost Principles”),

Interest earned on any of them (covered under “Cash Management”).

Proceeds from the sale of equipment or real property (covered under “Equipment and Real Property Management”).


REAL PROPERTY ACQUISITION AND

RELOCATION ASSISTANCE


K. Real Property Acquisition and Relocation Assistance

• This type of requirement has two elements: Provides for equitable and uniform treatment of persons displaced by

Federally-assisted programs from their homes, businesses or farms

Covers the payments of moving related expenses and reestablishment expenses incurred by displaced businesses and farm operations


REPORTING


L. Reporting

• This type of requirement is specific to the program however generally requires monthly, quarterly and/or annual status reports to be submitted to the funding source

• Reports may be: Financial

Performance

Special reporting


L. Reporting, Con’t

Financial Reporting

• Each recipient must report program outlays and program income on a cash or accrual basis, as prescribed by the Federal awarding agency.

• The reporting requirements for subrecipients are as specified by the pass-through entity. In many cases, these will be the same as or similar to the requirements for recipients.



Performance Reporting

• To be submitted at least annually

• Performance reports generally contain, for each award, brief information on each of the following:1. A comparison of actual accomplishments with the goals and

objectives established for the period.

2. Reasons why established goals were not met, if appropriate.

3. Other pertinent information including, when appropriate, analysis and explanation of cost overruns or high unit costs.



Special Reporting

• Non-Federal entities may be required to submit other reporting which may be used by the Federal agency for such purposes as allocating program funding.


SUBRECIPIENT MONITORING


M. Subrecipient Monitoring

A pass-through entity is responsible for:

• Award Identification - At the time of the award, identifying to the subrecipient the Federal award information (e.g., CFDA title and number, award name, name of Federal agency) and applicable compliance requirements.

• During-the-Award Monitoring - Monitoring the subrecipient’s use of Federal awards through reporting, site visits, regular contact, or other means to provide reasonable assurance that the subrecipient administers Federal awards in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved.

• Pass-Through Entity Impact - Evaluating the impact of subrecipient activities on the pass-through entity’s ability to comply with applicable Federal regulations.


Subrecipient Monitoring, Con’t

Subrecipient Audits:

1. Ensuring that subrecipients expending $500,000 or more in Federal awards during the subrecipient’s fiscal year have met the audit requirements of OMB Circular A-133 and that the required audits are completed within 9 months of the end of the subrecipient’s audit period,

2. Issuing a management decision on audit findings within 6 months after receipt of the subrecipient’s audit report, and

3. Ensuring that the subrecipient takes timely and appropriate corrective action on all audit findings. In cases of continued inability or unwillingness of a subrecipient to have the required audits, the pass-through entity shall take appropriate action using sanctions.


Subrecipient Monitoring, Con’t

Monitoring activities normally occur throughout the year and may take various forms, such as:

• Reporting - Reviewing financial and performance reports submitted by the subrecipient.

• Site Visits - Performing site visits at the subrecipient to review financial and programmatic records and observe operations.

• Regular Contact - Regular contacts with subrecipients and appropriate inquiries concerning program activities.


SPECIAL TESTS AND PROVISIONS


N. Special Tests and Provisions

• The specific requirements for Special Tests and Provisions are unique to each Federal program and are found in the laws, regulations, and the provisions of contract or grant agreements pertaining to the program.

• For programs listed in the Compliance Supplement: Special Tests and Provisions are in Part 4 - Agency Program Requirements

• For programs not listed in the Compliance Supplement: Review the program’s contract and grant agreements and referenced laws

and regulations to identify the compliance requirements which could have a direct and material effect on each program.


Questions and Answers

• Where can we find the suspension and debarment listing? Entity may verify suspension and debarment by checking the Excluded Parties

List System (EPLS) at www.epls.gov

• How often should we check this list? Refer to the attachment document

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