OMB Requests Feedback on Proposed Form Changes under Uniform Guidance

This month, the Office of Management and Budget (OMB) published a Federal Register (FR) notice proposing changes to the data collection form (Form SF-SAC), primarily changes needed to comply with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards at 2 CFR 200 (Uniform Guidance). This FR is intended to give the public an opportunity to review and comment on the proposed changes by submitting a comment letter to the OMB before February 8, 2016. Nonprofit organizations should review the changes and comment if they feel the requirements would be too onerous or difficult to comply with, or conversely, if they agree that it will improve the availability and usefulness of the information contained on the Federal Audit Clearinghouse (FAC) website.

These changes will affect Non-Federal entities (states, local governments, Indian tribes, institutions of higher education and nonprofit organizations) that expend a total amount of Federal awards equal to or in excess of $750,000 in any fiscal year, which are required by the Uniform Guidance to have an audit of their Federal awards and file the resulting reporting package and data collection form (Single Audit) with the FAC.

Because the changes are related to the Uniform Guidance, the new Form and instructions will be applicable for fiscal periods beginning on or after December 26, 2014, to align with the effective date of the Uniform Guidance.

However, organizations should continue using the existing form for audits performed under OMB Circular A-133, Audits of States, Local Governments, and Non-Profit Organizations.

The Changes
The proposed changes make revisions to the Form that “reflect Uniform Guidance requirements; revise some existing data elements; and add data elements that would make the reports easier for Federal agencies, pass-through entities, and the public to use. The changes would also delete data elements that are no longer needed.”

Specific changes include new rules for identifying Catalog of Domestic Federal Assistance (CFDA) numbers on the Form, as well as for identifying whether the program is part of a cluster of programs and the type of cluster. One change nonprofit organizations should take notice of is that for awards that are passed-through from another organization, the form will collect the name of the pass-through entity (PTE)and identifying number of the award assigned by the PTE. Although this information has often been included in the Schedule of Expenditures of Federal Awards (SEFA) it has never been required to be reported in the DCF, nor has it been searchable. This could significantly help organizations that pass through funds to other organizations with their oversight responsibilities.

Other changes include significant enhancements to the certification statements, particularly for the auditee, Special-Purpose Framework Financial Statement Opinion information, enhancement to the information provided on findings that will enhance the ability to search for findings and more. Read the summary and full description on the OMB Grants Management Forms Web page, here.

Finally, it should also be noted that under the Uniform Guidance, the FAC must also make Single Audit Reports publicly available on a website – a change from making only Form SF-SAC data publicly available.

Assessing the Burden
The OMB is requesting feedback on these changes and any burden they may impose on organizations, as well as feedback on its assessment of the time commitment to complete the Form—estimated as 65 hours for the 400 largest respondents and 20 hours for 79,600 smaller respondents (auditees and auditors).

For more information, visit our OMB Uniform Guidance Resource Center.

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