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SINGLE AUDIT UPDATE
JUNE 2, 20201:00PM CENTRAL
2020 NSAA Annual Virtual Event
Tammie Brown, CPANational Single Audit CoordinatorUS. DHHS-OIG
WHAT WE WILL COVER
• Status of Uniform Guidance Updates
• COVID funding and implications
• Status of 2020 Compliance supplement
UNIFORM GUIDANCE UPDATES
Early February Draft provided to various groups including AICPA, NASCT, CIGIE
March 16, 2020 CIGIE Comments Submitted
March 23, 2020 Comments Due
March 6, 2020 PL 116-123
March 18, 2020PL 116-127
March 27, 2020PL 116-136
April 24, 2020PL 116-139
August 2020 Projected Final updated UG
UNIFORM GUIDANCE FAQ’S
• No longer maintained
• Several incorporated into applicable sections
• Uncertainty regarding those not pulled into specific UG sections
• Uncertainty for future guidance
DEFINITIONS BUDGET PERIOD §200.1
New Definition - Budget period means the time interval during which recipients are authorized to expend the current funds awarded and must meet the matching or cost-sharing requirements, if any.
- implications on multi year awards?
2 CFR 200.431 COMPENSATION –FRINGE BENEFITS
Align 2 CFR with Authoritative Sources to allow states to confirm with GAAP, specifically GASB Statement 68, to allow Non-Federal entities to continue to claim pension costs that are both actual and funded.
This Photo by Unknown Author is licensed under CC BY-SA
OFFICIAL FEDERAL COGNIZANT AND OVERSIGHT AGENCY§513(A)(1)
Changed cognizant determination from predominant direct funding, to include a provision for direct less than 25 percent of total funding to base cognizant and oversight for audit determination on the predominant direct funding.
NATIONAL SINGLE AUDIT PROJECT §513(A)(3)(II)Governmentwide project rely on the current and on-going quality control review work performed by Federal Agencies.
Every 6 years beginning with audits submitted in 2021 or at such other interval determined by OMB.
Results must be public.
Advise audit community, auditee, Federal agencies and professional licensing and regulatory bodies of quality deficiencies that result in failed engagements.
UNIFORM GUIDANCE NEW § 183
Implement Never Contract with the Enemy provisions to grants and cooperative agreements, required by subtitle 8 of the National Defense Authorization Act (NDAA) PL 113-291.
Applicable to grants and cooperative agreements expected to exceed $50,000 performed outside the United States and U.S. Territories that are in support of a contingency operation in which members of Armed Forces are actively engaged in hostilities.
Applicable until December 31, 2019, except Access to Records which has no sunset date.
Federal Awarding agencies required to:
check the current list of prohibited or restricted person or entities on the System of Award Management (SAM) exclusions before making a covered grant or cooperative agreement.
Must include Never Contract with the Enemy clause.
Restrict future awards if become aware of a person or entity.
Terminate grant or cooperative agreement upon becoming aware that the Non-Federal recipient failed to exercise due diligence to ensure that none of the award funds are provided directly or indirectly to a covered person or entity.
Notify Non-Federal entities in writing regarding its decision to restrict all future awards and/ or to terminate a grant, administrative review, or restrictions or termination of the grant within 30 days of notification.
ATTENDANCE CHECK
OMB M-20-11 ADMINISTRATIVE RELIEF FOR RECIPIENTS AND APPLICANTS FOR FEDERAL FINANCIAL ASSISTANCE DIRECTLY IMPACTED BY NOVEL CORONAVIRUS (COVID19) DUE TO LOSS OF OPERATIONS.
Issued March 9, 2020 Short Term Administrative, financial management and audit requirements under 2 CFR 200, for entities that support the
continued research and emergency services necessary to respond to COVID – 19 Exceptions time limited for period during period declared by DHHS through the 90 day Public Health Emergency
Declaration (Public Health Emergency Period). Flexibility with SAM registration/ recertification for applicants – relax active SAM registration at time of application Waiver for Notice of Funding Opportunities Publication for less than 30 days Pre-award costs – allowable from Jan 20, 2020 through Public Health Emergency Period and prior to the effective date of a
Federal award No cost extensions on expiring awards Abbreviated non-competitive continuation request for request scheduled between April 1,2020 to December 31, 2020 Expenditure of award funds for salaries and other project activities Waivers from prior approval requirements Exemption of certain procurement requirements - geographical preferences, contracting with small and minority business
and women business enterprises, and labor surplus area firms. 3 month extensions for submissions of financial and other reports Single Audit submissions up to 12 months beyond normal due date and still qualify for a low-risk auditee.
OMB M-20-17 ADMINISTRATIVE RELIEF FOR RECIPIENTS AND APPLICANTS FOR FEDERAL FINANCIAL ASSISTANCE DIRECTLY IMPACTED BY NOVEL CORONAVIRUS (COVID 19) DUE TO LOSS OF OPERATIONS
• Issued March 19, 2020• Expanded scope of recipients affected to include those with ay loss of operational capacity and increased cost due to the COVID-
19 Crisis• Short term relief for administrative, financial management and audit requirement s under 2CFR Part 200
• Flexibility with Sam Registration – 60 days extension for registrations expiring before May 16, 2020
• Flexibility with application dead lines
• Waiver for Notice of Funding Opportunities – publication for less than 30 days
• No –cost extension on expiring awards fore awards active as of March 31 that expire through Dec 31, up to 12 months extension. Performance reports due 90 days following end of extension.
• Abbreviated non-competitive continuation request
• Allowability of salaries and project activities
• Allowability of Cost not normally Chargeable to Awards – cancellation fees, pausing and restarting grant activities
• Prior Approval requirement Waivers
• Exemption of Certain procurement requirements regarding geographical, small and minority business contracting, and labor surplus area firms
• Extend Financial , performance and other reporting requirements 3 months beyond normal due dates., and still draw down funds.
• Extend Current approved indirect cost rates
• Extension of Close out reports up to 1 yare after the award expires
• Single Audit Report Submissions – Unfiled reports with fiscal year ends through June 30, 2020 up to 6 months beyond normal due date. Automatic extension only need to document reason for delay and still qualify as a low-risk auditee under 2 CFR § 200.520(a)
HHS CORONAVIRUS FUNDING
The Coronavirus Preparedness and Response Supplemental
Appropriations Act Signed March 6, 2020
$8.3 billion$6.5 Billion HHS Funding
Public Law 116-123
Families First Coronavirus Response Act
signed march 18, 2020$192 Billion
$1.3 Billion HHS FundingPublic Law 116-127
The Coronavirus Aid, Relief, and Economic Security
(CARES) Act Signed March 27, 2020
$2.3 Trillion$143.2 Billion HHS funding
Public Law 116-136
The Paycheck Protection Program and Health Care
Enhancement ActSigned April 24, 2020
$484 Billion$100 Billion HHS Funding
Public Law 116-139
New Legislation pending – HEROS ACT
FDA, 1%
CDC , 34%
NIH, 9%
CMS, 1%
ACF, 32%
OIG, 0%
HRSA , 8%
IHS, 6%
ACL, 6%SAMSHA, 2%
HHS Phases 1-4, Percentage of Total by Agency (Excluding Office of the Secretary)
FDA CDC NIH CMS ACFOIG HRSA IHS ACL SAMSHA
The Coronavirus Aid, Relief, and Economic Security (CARES) Act
$100 BillionPublic Law 116-136
PROVIDER RELIEF FUND$175 Billion
Paycheck Protection Program and Health Care Enhancement Act
$75 BillionPublic Law 116-139
GENERAL DISTRIBUTION$50 Billion
TARGET DISTRIBUTION$50 Billion
$12 Billion
High Impact Areas
$10 Billion
Rural Health Providers
$400 Million
Indian Health
Services
$27.6 Billion
Remaining Funds
First Distribution$30 Billion
Proportional Share of
Medicare FFS reimbursement
for 2019
Second Distribution$20 Billion
Percentage of net patient
revenue from all payors for
2018
$75 Billion AID TO HOSPITALSDetails (TBD)
2020 COMPLIANCE SUPPLEMENTLast Section submitted to
OMB for final Clearance 4/30/2020
5/22/2020 CS with COVID info in appendix VII and COVID Addendum Later
May 27 OMB Data Call Deadline
- Most sections in OMB Clearance Process or ready for process
- COVID Appendix Information being developed
- COVID Part 4 sections being identified and developed
COMPLIANCE SUPPLEMENT COVID GUIDANCE
Existing Federal ProgramsAppendix VII
Schedule of New COVID Program Identification NumbersGeneral Guidance statementsSEFA and DCF requires separate Identification of COVID fundingRecipient ResponsibilitiesAnticipate large volume of additional Single Audits
General Part 3 GuidancePossible additions to back ground section to incorporate unique COVID requirements
Addendum Part 4 programsFederal agencies developing program specific sections for new programs with highest impact
SINGLE AUDIT APPLICABILITY NEW COVID CFDA’SFederal Agency Program Title CFDA UG Applicable Sections Single
Audit Applicable
Agriculture Coronavirus Food Assistance Program 10.130 none no
Treasury Coronavirus Relief Fund (CRF) 21.019 Subpart F yes
Federal Communications Commission
COVID-19 Telehealth Program 32.600 none no
Small Business Administration OED Resource Partners Training Portal 59.074 none no
Small Business Administration Economic Injury Disaster Loan Emergency Advance 59.072 none no
Small Business Administration Payroll Protection Program Loans 59.073 none No
Education Stabilization Fund 84.425 Subparts B,C,D,E & F yes
Health and Human Services Uninsured COVID Testing and Treatment 93.461 Subparts B,D,E & F yes
Health and Human Services Provider Relief Fund 93.498 Subparts B,D,E and F yes
Health and Human Services New & Expanded Services Under Health Center Program 93.527 Subpart B,C,D,E & F yes
Health and Human Services Emergency Grants to address Mental and Substance use Disorders During COVID 19 Pandemic
93.665 Subparts B,C,D,E & F yes
Health and Human Services Rural Health Clinic Testing 93.697 Subparts B,D,E & F yes
HHS NEW COVID RELATED PROGRAMS
CFDA 93.665 – Emergency Grants to address Mental and Substance Use Disorders During COVID - 19
CFDA 93.498- Provider Relief Fund
CFDA 93.461 – Uninsured COVID Testing and treatment
CFDA 93.527 Grants for New and Expanded Services under the Health Center Program
93.697 Rural Health Clinic Testing
MEDICAID AND COVID – 19
4 types of Flexibilities Emergency State Plan Amendments
Appendix K amendments to approved 1915 (c) waivers
1115 Disaster waivers
1135 Disaster waivers
Additional waivers related to Conditions of Participation (COPS)
Enhanced FMAP: Families First Coronavirus Response Act and termination suspensions
Survey and Certification Funding - $80 million nationwide for COVID-19 activities
Changes to Eligibility rules changes during PHE Section 6004(a)(3)
FMAP for COVID-19 testing group 100 percent
FMAP not 100 percent for other Medicaid eligible groups
EDUCATION STABILIZATION FUND
CFDA 84.425
States, and local Governments
To prevent, prepare for, and respond to COVID- 19 Pandemic
Authorization CARES ACT PL 116-136; $30,750,000,000 estimated Obligations
UG Applicable sections; Subpart B, C,D,E and F
Seven major components for funds to be allocated
CARES ACT EDUCATION STABILIZATION FUND $30,750,000,000
84.428A - Outlying Areas - $153,750,000
84.425 -Bureau of Indian Education - $153,750,000
84.425B - Education Stabilization Fund Discretionary Grants – 307,500,000
84.425M SIP
84.425C – Governor’s Emergency Education Relief Fund- $2,953,230,33384.428E – Emergency Financial Aid to students84.425F- Institutional support
84.425D – Section 180049 (a)(1) - Elementary and Secondary School Emergency Relief Fund – IHEs – $12,557,254,
84.425E – Higher Education Emergency Relief Fund – HBCUs and MSIs - $1,046,437,87584.425J – HBCUs, HBGIs, HBCU masters84.425K TCCU84.425L ANNH, AANAPISI, NASNTI, PBI, DHSI, PPOHA84.425M SIP
84.425 – Higher Education Emergency Relief Fund – FIPSE - $248,812,62584.425N HHERF FIPSE84.425O EERF FIDSE Competitive
CORONAVIRUS RELIEF FUND (CRF) CFDA 21.019
Authorized under the CARES Act PL 116-136 CFDA 21.019 - pending OMB Clearance
Part 4 CS Addendum supplement being developed Subject to UG Sections:
303 internal controls 330 to 332 subrecipient monitoring and management Subpart F – Single Audit
$150 Billion Payments to State, Local, and Tribal governments navigating the impact of the COVID-19 outbreak. Distributions were based on population that exceeds 500,000
Local governments required to submit certifications to Treasury. Payments began Tribal government payments on May 5, 2020
To cover expenses that – are necessary expenditures incurred due to COVID-19; Were not budgeted as of prior to March 27, 2020; and Were incurred between March 1, 2020 and December 30, 2020.
PAYROLL PROTECTION PROGRAM (PPP)
CFDA 59.073
Not subject to Single Audit Provisions
EPA COVID FUNDS 1million for grants under State Environmental Justice Cooperative Agreement Program (SEJCA)/COVID-19- CFDA 66.312
https://www.grants.gov/web/grants/view-opportunity.html?oppId=326650
UG Subparts B, C, D, E and F applicable
7.5 million to clean and disinfect EPA facilities Drinking Water State Revolving Fund CFDA 66.468
Capitalization Grants for Clean Water State Revolving Funds CFDA 66.458
Questions ?