The New Super CircularInaugural Tribal Accounting

ConferenceNovember 16, 2015

Morgan AronsonNational Single Audit

Coordinatormorgan_aronson@doioig.go

v

• Uniform Grant Guidance History• General Compliance Areas

– Procurement– Subrecipient Monitoring

• Audit Report Submission and the Tribal Opt-Out

UGG History

• October 2011 – COFAR created• February 2012 – Advance Notice of

Proposed Guidance issued in the Federal Register

• February 2013 – Proposed Guidance issued in the Federal Register

• December 2013 – Final Guidance issued in the Federal Register

• Throughout 2014 – COFAR webcasts and FAQs

• December 2014 – Joint Interim Final Rule issued

ProcurementMicro-Purchases≤ $3,000

Small Purchases> $3,000≤ $150,000

Sealed Bids and Competitive Proposals> $150,000

Procurement Types

• Micro-Purchase– Competitive quotations not required– Equitable distribution among vendors

• Small Purchase– Quotations obtained from an “adequate”

number of qualified sources– Method of obtaining quotations is at your

discretion

Procurement Types

• Sealed Bids– Formal advertising– Construction projects– Price is the key factor

• Competitive Proposals– Fixed price or cost-reimbursement contracts– Requests for proposals must include evaluation

factors and method for selection– Award goes to “most advantageous” proposal

Procurement Types

• Sole Source – must meet at least one of the following criteria:– Available from a single source– Public emergency– Federal awarding agency or pass-through

entity has provided approval in response to a written request

– After solicitation of a number of sources, competition is determined inadequate

Procurement Grace Period

• Two-year grace period after the effective date of the Uniform Guidance to comply with procurement standards.

• For the first two full fiscal years beginning on or after December 26, 2014, non-Federal entity must document whether it is in compliance with the old or new standard and meet the documented standard.

Subrecipient Monitoring

• Subrecipient vs. Contractor– “Contractor” replaces “Vendor”– Substance over Form

• Award identification• Risk assessment

Award Identification

• Subrecipient name and DUNS number• Federal Award Identification Number (FAIN)• Federal award date of award to the

recipient by the Federal agency• Subaward period of performance start and

end date• Amount of Federal funds obligated and

committed to the subrecipient• Federal award project description

Award Identification

• Name of Federal awarding agency, pass-through entity, and contact information for awarding official of pass-through entity

• CFDA number and name AND dollar amount made available under each Federal award and the CFDA number at time of disbursement

• Whether the award is Research & Development

• Indirect cost rate for the Federal award, including if the de minimus rate is charged

Risk Assessment

Assess risk of subrecipients to determine the nature, timing, and extent of monitoring

– Subrecipient’s prior experience with same or similar subawards

– Results of subrecipient’s previous audits– Whether subrecipient has new personnel or

systems– Extent and results of Federal awarding agency

monitoring

Tribal Opt-Out

• The single audit reporting packages will become publicly available on the FAC web site.

• Indian tribes and tribal organizations may opt not to authorize the FAC to make the reporting package publicly available.

Questions about the Opt-Out

• Do we still have to submit our single audit to the FAC?

• Do we still have to submit our Data Collection Form?

• If we choose to opt-out, do we have to submit our single audit to a pass-through entity?

• Our tribal school, housing authority, and clinic each obtain a separate single audit. Can they all elect to opt-out?