OMB Super-Circular Proposal
FPP Agenda Item
February 8, 2013
OMB Proposal Released
 On January 31, 2013, the Office of Management and Budget
(OMB) released its:
 “Proposed OMB Uniform Guidance: Cost Principles, Audit, and
Administrative Requirements for Federal Awards”
 This notice of proposed guidelines is a detailed, 244-page
document that consolidates a number of key cost circulars
covering the federal cost principles (A-87), the federal
administrative rules (A-102), and non-federal audits (A-133)
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OMB Proposal Released (cont.)
 OMB also provided an 89-page summary and description of
the changes from the notice released last February.
 The documents are posted on www.regulations.gov under
docket number OMB-2013-0001
 Interested parties may submit comments for 90 days (until
April 30th) to the above website.
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Super-Circular
 This proposal would streamline the language from eight
existing OMB circulars into one document.
 Subchapter A – General Provisions
 Subchapter B – Pre-award Requirements
 Subchapter C – Federal Award Notice
 Subchapter D – Inclusion of Terms and Conditions
 Subchapter E – Post Federal Award Requirements
 Subchapter F – Cost Principals
 Subchapter G – Audit Requirements
 Subchapter H - Appendices
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Single Audit Threshold
 Among the issues of intense interest to the grants community
are changes to the single audit requirements.
 One of the most significant proposals would raise the
threshold for single audits from $500,000 to $750,000.
 The original OMB proposal was for a $1 million threshold.
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Other Single Audit Changes
 Major Program Determination:
 This proposal includes changes to all four steps of the riskbased approach to focus on the areas of highest risk and
reduce the number of major programs tested.
 Streamlining of the Compliance Supplement:
 May cut back on number of types of compliance requirements,
but those may move under “Special Tests and Provisions”
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Time and Effort Documentation
 Now titled, “Documentation of Personnel Expenses”
 Uses language from a number of applicable circulars and
combine them into a single set of requirements.
 The type of documentation completed is still dependent on
the number of cost objectives worked on by the employee.
 We will need to review how the recent U.S. Department of
Education guidance matches up with this guidance.
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Informational Webinar
 The Council on Financial Assistance Reform (COFAR) will be
hosting an informational webinar on the proposed guidance
with members of the grant community today (2-8-13).
 However, a recorded version will be available for later viewing.
 www.cfo.gov/cofar
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