Federal & State Monitoring: The Uniform Guidance

Transcription

1 Federal & State Monitoring: The Uniform Guidance Special Education Directors Conference August

2 Topics of Interest Overview of the Uniform Guidance (also commonly referred to as the Omni Circular) Policies and Procedures Overview Internal Controls Overview Audit and Monitoring Expectations Common Findings Reminders 2

3 What is the Uniform Guidance? In a nutshell: It s a consolidation of 8 OMB Circulars (2 CFR 200) It s called guidance, but it s full of rules and requirements, with some suggestions for best practices It s not a dramatic departure from the previous requirements, but there are some new requirements and flexibilities 3

4 From Circulars to the Uniform Guidance Prior to the Uniform Guidance Circulars A-89, A-102, A-110 Circulars A-21, A-87, A-122 Circulars A-133, A-50 After the Uniform Guidance Uniform Guidance Subparts B, C, and D Uniform Guidance Subpart E Uniform Guidance Subpart F EDGAR Parts 75 to 99 EDGAR Parts and EDGAR Parts 74 and 80 substance Became part of the Uniform Guidance 4

5 Requirements of The Uniform Guidance Enhanced Oversight Requirements of Sub-recipients Risk Assessment and Monitoring Greater Emphasis on Internal Controls and Written Policies Greater Focus on Performance Expectations and Results 5

6 Uniform Guidance Sub-recipient Risk Assessment Prior experience with same or similar awards Results of previous audits Is the LEA required to have a federal single audit New personnel or substantially changed systems Results of federal awarding agency monitoring Written procedures and internal controls Other Factors as identified by federal government, SEA, or other authoritative guidance 6

7 Uniform Guidance Sub-recipient Risk-Based Monitoring Review of financial and performance reports and supporting documentation Assessment of written policies and internal controls Issuance of management decisions for audit findings Ensuring sub-recipient takes timely and appropriate action on noted deficiencies 7

8 Uniform Guidance Risk-Based Monitoring Whether as a result of the risk-based assessment or monitoring, SEA required to impose conditions, including high-risk conditions, on its sub-recipients (2 CFR and ): Increased reporting Reimbursement plan Additional monitoring Mandatory technical assistance Additional prior approvals Other 8

9 Uniform Guidance Applicable for Federal and State Awards Grant Accountability and Transparency Act (GATA) 30 ILCS 708 ( Directs the Governor s Office of Management and Budget (GOMB) to adopt rules which adopt the Uniform Guidance at 2 CFR 200. The rules shall apply to all State and federal pass-through awards effective on and after July 1, (30 ILCS 708/20) 9

10 Policies and Procedures Overview At the heart of internal control environment Polices and Procedures Must Be Specific to Your District The policy must state what you are going to do and why The procedures state What steps are required to be completed Who is going to perform the steps When the process will be completed Who is responsible for review 10

11 Policies and Procedures Overview Specific functions/processes where written policies/internal controls are most essential: Payments/cash management Compensation/personnel expenses Procurement Property management/inventory Financial monitoring Sub-recipient monitoring (contracts/grants) Other, as needed 11

12 Internal Controls Overview Per 2 CFR internal controls are elevated as an accountability measure Grantees must: Establish and maintain effective internal control over federal awards Evaluate and monitor compliance Take prompt action in the event of noncompliance Take reasonable measures to safeguard protected personally identifiable information and other sensitive information Resources Tool kit and PowerPoint Presentation 12

13 Internal Controls Overview Internal controls give reasonable assurance that the organization will achieve its objectives through: Effective and efficient operations Reliable reporting Compliance with applicable laws and regulations 13

14 Internal Controls: Crucial Accountability The elevated role of internal control: Creates a transparent system of accountability for decision making around federal funds The system of accountability applies equally to federal agencies, grantees, and sub-recipients Internal controls are not new to the financial world They may be new to people working on program implementation 14

15 Internal Controls Overview Strong Internal Controls include: Policies and procedures for individual functions Adequate segregation of duties for all functions Supervisory review of expenditures prior to submission Grant and Fiscal staff review of transactions to ensure proper posting of expenditures to grants Procedures to ensure grant objectives are being met Adequate, sufficient supporting documentation 15

16 Equipment/Inventory Example A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. Equipment purchases must be approved in the grant budget Inventory records must include the following components Description Serial number or other identification number Funding source for purchased property Who holds title Acquisition date Cost Location, use and condition Disposition date, if applicable All equipment purchases must be physically located in the grant usage area and must support the intent of the program 16

17 Personal Services Example Increases emphasis on internal controls of sub-recipient for personnel cost Provides less prescriptive guidance on documentation Per 2 CFR (i) Standards for Documentation of Personnel Expenses (1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Please review this section. Critical information may be found which will help you ensure you accurately track and claim personnel expenses This section will help you avoid costly mistakes which will result in questioned costs and audit adjustments 17

18 Audit and Monitoring Monitoring Instrument Expectations Districts responses should be consistent with their approved application Each comment box should contain specific detail to document that the district is in compliance for that specific portion of the grant Submission of the instrument by the required date Comparability Submission of the instrument by the required date Maintain supporting documentation 18

19 Audit and Monitoring Expectations Onsite and Desk Reviews Supporting documentation for all programs to be reviewed Access to staff responsible for the programs being reviewed Audit and monitoring function is collaborative but ultimately independent of program administration function 19

20 Common Fiscal Monitoring Findings Special Education Inaccurate expenditure reports Salaries paid were not approved or were inaccurate Inventory issues Expenditures paid were unallowable or did not support program intent Not maintaining separate accounts in accordance with IPAM for each grant 20

21 Personnel Claim Audit Findings Salaries claimed were incorrect Number of days employed were incorrect FTE s reported were incorrect Failure to deduct federal funds in the claim FTE s of Home Hospital Instructors were incorrect 21

22 Orphanage Claim Audit Findings Misstatement of allowable expenditures on the Tuition Cost Sheet Misstatement of offsetting revenues on the Tuition Cost Sheet Misstatement of tuition paid on the claim Incorrect reporting of transportation cost Misstatement of the pupil days enrolled 22

23 Basic Guidelines for Allowable Expenditures Was the cost included in application/budget? Does the cost meet the requirements of the law? Is the cost necessary, reasonable, allocable, and documented? Is the cost consistently applied? Is the cost adequately documented? Examples: segregated accounts, invoices, payroll detail, cancelled checks, inventory records and other valid supporting documentation Segregated accounts mean Revenue and Expenditure accounts specific to each funding source (Title I, Title II, etc) and different expenditure accounts for each functionobject budgeted/claimed ( , , etc). 23

24 References and Helpful Links United States Department of Education: The Uniform Guidance (2 C.F.R. 200): Uniform Guidance Technical Assistance: Illinois Program Accounting Manual (IPAM): State and Federal Grant Administration Policy and Fiscal Requirements and Procedures: df

25 Contact Information Illinois State Board of Education 100 North First Street Springfield, IL

26 Questions 26