Implementing the Super-Circular (PPT)

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Barbara Loescher & Trisha Edwards
Fiscal Integrity & Audit Section
Topics for Today
 Overview of FIAS
 Supercircular
 New administrative requirements
 New cost guidelines
 New audit requirements
 What this means for counties
 Other hot topics
Fiscal Integrity & Audit Section
 Purpose is to monitor compliance with rules,
regulations, licensing requirements and contracts to
ensure that DCF funding is used appropriately
 Created in 2012
 Consists of section chief and 5 auditors
 Basic responsibilities
 Desk reviews
 On-site fiscal reviews
 Internal audits
Overview - Super-Circular
 Combines 8 Circulars
 Published December 26, 2013
 Effective Dates
 December 26, 2014
 Single Audits – December 31,
2015
 Link: See references page
 Additional guidance later
this year
Impact & Objectives
 Reduce administrative burden
 Reduce fraud, waste and abuse
 Improve program integrity
 Strengthen accountability
 Shift from legacy awards to
merit awards
 More oversight required for
pass-through agencies
Administrative Requirements Reforms
 Performance goals &
reporting, cost
effectiveness and
collaboration
 Technology changes
 Computers now supplies
 Flexibility in document
retention
 Standardized requirements
and definitions
Administrative Requirements Reforms
 Stronger oversight
 Conflict of interest
policies
 Internal controls
 How audit results are
treated
 Sub-recipient
monitoring
Cost Principles Reforms
 All entities – same guidance
 Except for-profit agencies
 Indirect/direct costs
 Written cost allocation plan
 No universal rule except
consistency
 Time and effort reporting
 Emphasis on internal
controls rather than PARs
Cost Principles Reforms
 Changes to specific items of cost
 Advertising
 “Employee morale” costs
eliminated
 Entertainment
 Conference spending
 Fines, penalties, damages and
other settlements
 Collection of unallowable costs
 Home offices
 And others
A-133 Audit Reforms
 Single audit threshold
increased
 $500,000 to $750,000
 Type A programs
increased
 $300,000 to $750,000
 Risk criteria has changed
 Questioned costs
threshold increased
 $10,000 to $25,000
A-133 Audit Reforms
 Repeat findings
 Compliance areas
 Still not sure
 Will be published
4/15/2015
 Online publication of
reports
 Federal Audit
Clearinghouse
How Does This Affect Counties?
 Changes to your contracts
with DCF
 Discuss with Executive
committee
 Changes to county contracts
with providers
 New language
 New references
 New allowable cost
requirements
 New audit requirements for
2015 audits
More Ways It Affects Counties
 May be less auditing for A-
133 audits
 Training by DCF for county
financial managers through
rest of 2014
 New State Single Audit
Guidelines for 2015 audits
DCF Oversight of Providers
• FIAS Fiscal Reviews:
• Compliance with laws and
licensing requirements
• Financial stability
• Allowability of costs
• Fiduciary responsibility
• Contract compliance
• Fraud and abuse
• Overpayment recovery
• Includes all agencies
receiving DCF funding
Fiscal Reviews Results
 Insight from the trenches
 Luxury vehicles
 Ghost vehicle
 Lavish trips
 Fraudulent invoices
 Related party transactions
 Personal items
 “Me first” mentality
 Home office
 Holiday parties
 Box Bucks tickets
 Gas allowances
 ATM withdrawals
 Undocumented items
 Donations
 Overdraft charges
 Unreasonable
 Unnecessary
County Fiscal Reviews
 Expanding into county
fiscal reviews
 Scheduling first wave in
coming months
 Review centered on:
 Cost allocation
 Allowable costs
 Sub-recipient
monitoring
Allowable Cost Policy Manual Update
 Major re-write
 Currently being reviewed
internally
 To be discussed with
Executive Committee
 Current (tentative) ETA –
before year end
In Closing
 Read the Super-Circular
 Continue spending
public funds prudently
 Update your contracts
 The ACPM is coming
 And we’ll see you soon!
For Further Information
Barbara Loescher, CIA
Chief, Fiscal Integrity & Audit Section
Department of Children & Families
(608)264-6992
Barbara.Loescher@wisconsin.gov
Trisha Edwards, CPA
Auditor – Senior
Department of Children & Families
(608) 267-2981
Trisha.Edwards@wisconsin.gov
Questions?
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