Single Audit Training – Module II
California State University
AUDIT
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1
Module II
Overview of 14
Standard
Compliance
Requirements
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2
Understanding the Compliance Requirements
A – Activities Allowed
H – Period of Availability
B – Allowable Costs
I – Procurement, Suspension &
C – Cash Management
Debarment
D – Davis Bacon Act
J – Program Income
E – Eligibility
K – Real Property Relocation
F – Equipment Management
G – Matching, Level of Effort,
Earmarking
Assistance
L – Reporting
M – Subrecipient Monitoring
N – Special Tests and Provisions
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3
ACTIVITES ALLOWED/
ALLOWABLE COSTS
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A/B Activities Allowed/Allowable Costs
Activities Allowed
• This type of compliance requirement specifies the
activities that can or cannot be funded under a specific
program.
• The specific requirements for activities allowed or
unallowed are unique to each Federal program and are
found in the laws, regulations, and the provisions of
contract or grant agreements pertaining to the program.
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A/B Activities Allowed/Allowable Costs, Con’t
Allowable Costs
• In order to receive cost reimbursement under Federal awards, the
department or agency usually submits claims asserting that
allowable and eligible costs (direct and indirect) have been
incurred in accordance with A-87, A-21 or A-122.
• Applicable OMB Circulars:
 OMB Circular A-87, “Cost Principles for State, Local, and Indian Tribal
Governments.”
 OMB Circular A-21, “Cost Principles for Educational Institutions.”
 OMB Circular A-122, “Cost Principles for Non-Profit Organizations.”
 All three circulars establish principles and standards for determining allowable
direct and indirect costs for Federal awards.
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A/B Activities Allowed/Allowable Costs, Con’t
• Allowability of Costs - General Criteria
 Reasonable and Necessary - Costs must be reasonable and necessary for
the performance and administration of Federal awards.
 Allocable - Costs must be allocable to the Federal awards under the
provisions of the cost principles. A cost is allocable to a particular cost
objective (e.g., a specific function, program, project, department, or the like) if
the goods or services involved are charged or assigned to such cost objective
in accordance with relative benefits received.
 Consistency - Costs must be given consistent treatment through application of
those generally accepted accounting principles appropriate to the
circumstances. A cost may not be assigned to a Federal award as a direct
cost if any other cost incurred for the same purpose in like circumstances was
allocated to the Federal award as an indirect cost.
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A/B Activities Allowed/Allowable Costs, Con’t
• Allowability of Costs - General Criteria Con’t
 Conformity to Laws, Regulations and Sponsored Agreements - Costs must
conform to any limitations or exclusions set forth in the circulars, Federal laws,
State or local laws, sponsored agreements, or other governing regulations as
to types or amounts of cost items.
 Transactions that Reduce or Offset Direct or Indirect Costs - Costs must be
net of all applicable credits that result from transactions that reduce or offset
direct or indirect costs. Examples of such transactions include purchase
discounts, rebates or allowances, recoveries or indemnities on losses,
insurance refunds or rebates, and adjustments for overpayments or erroneous
charges.
 Costs Documentation - Costs must be documented in accordance with OMB
Circular A-110 for non-profit organizations and institutions of higher education
or the A-102 Common Rule for State, local and Indian tribal governments.
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A/B Activities Allowed/Allowable Costs, Con’t
Eligible Costs
• Direct costs are those that can be identified specifically with a
particular final cost objective
• Indirect costs are those that have been incurred for common or
joint purposes and not readily assignable to the final cost
objective. Indirect costs are normally charged to Federal awards by
the use of an indirect cost rate.
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9
A/B Time and Effort Reporting (Payroll) —Notfor-Profit A-122
Effort reports are required for all employees (professional and
nonprofessional) whose compensation costs are directly charged
to federal awards, in whole or in part
 Must reflect an after-the-fact determination of the actual activity
 Required to account for 100 percent of the employee’s time
 Must be signed by the individual employee or by a responsible official having
first hand knowledge of the employee’s activity
 Required to be prepared at least monthly
 Documentation of the number of hours worked each day must be maintained
for all non-professional employees
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10
A/B Time and Effort Reporting (Payroll) —
Higher Ed A-21
• Multiple methods/systems are acceptable, but common
criteria include:
 Must be an “after-the fact” confirmation or determination certified by
the employee or a supervisor with first-hand knowledge of the
employee’s work
 Must allow for confirmation of activity allocable to each sponsored
agreement
 Must reflect 100 percent of employee’s effort/salary
• Example methods are: Plan Confirmation, After the
Fact Activity Records, and Multiple Confirmation
Record
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A/B Time and Effort Reporting (Payroll) —
Higher Ed A-21 (Con’t)
• Plan Confirmation
 Professorial and professional staff wages are based on budgeted work
activity
 Modification should be made for significant changes in employee’s
salary or work activity; modification should be approved by
responsible official
 Requires an annual signed certification of effort by employee, principal
investigator, or responsible official(s)
 An institution shall not be required to provide additional support or
documentation for the effort actually performed.
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12
A/B Time and Effort Reporting (Payroll) —
Higher Ed A-21 (Con’t)
• After-the-Fact Activity Record
 Reflect an after-the-fact reporting of the percentage distribution of activity of
employees
 Requires certifications for professorial and professional staff for each
academic term (semester, trimester, quarter), but not less frequently than
every six months
 Requires certifications for all other employees no less frequently than monthly
 Certifications must be signed by the employee, principal investigator, or
responsible official(s)
 Where the institution uses time cards or other forms of after-the-fact payroll
documents as original documentation for payroll and payroll charges, such
documents shall qualify as records for this purpose, provided that they
meet all other requirements
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13
A/B Time and Effort Reporting (Payroll) —
Higher Ed A-21 (Con’t)
• Multiple Confirmation Record
 Requires records to reflect distribution of activities between direct and indirect
activities
 May use estimates to charge personal service costs to programs so long as
adjustments to actual activity are made
 Requires certifications for professorial and professional staff signed by
employee or direct supervisor each academic term (semester, trimester,
quarter), but not less frequently than every six months
 Where the institution uses time cards or other forms of after-the-fact payroll
documents as original documentation for payroll and payroll charges, such
documents shall qualify as records for this purpose, provided that they meet
all other requirements
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14
A/B Time and Effort Reporting (Payroll) —
State & Local Gov’t A-87
• Employee works solely on a single federal award
 Periodic certification that the employee worked solely on the award is required
 Certification is required at least semi-annually
 Must be signed by individual or supervisor having first-hand knowledge of
the work performed by the employee
• Employee works on multiple activities
 Salary Distribution required to be supported by personnel activity report
 Must be an “after-the-fact” determination of actual activity.
 Must account for 100 percent of employee’s activity/salary.
 Required to be prepared monthly.
 Must be signed by employee.
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15
A/B Time and Effort Reporting (Payroll) —
State & Local Gov’t A-87, Con’t
• Budget estimates determined before the services are
performed do not qualify as support but may be used
for interim purposes, provided that:
 The system produces reasonable approximations of the actual activity.
 Comparisons of monthly actual to budgeted are made at least quarterly with
adjustments to actual being recorded quarterly or annually depending on the
accuracy of the estimates.
 The budget estimates or other distribution percentages are revised at least
quarterly, if necessary, to reflect changed circumstances.
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16
Indirect Costs
• Indirect costs are those costs that benefit common
activities and, therefore, cannot be readily assigned to a
specific direct cost objective or project.
• Sometimes award-specific indirect cost rates are
negotiated that are different from those set forth in
negotiated rate agreements. Terms and conditions in
an award specific to indirect cost rates take precedence
over indirect cost rates set forth in negotiated
agreements.
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Indirect Costs (Con’t)
• Three different types of indirect cost rates can be approved by the
cognizant agency for indirect cost negotiation:
 Predetermined rates - rates established for the current or multiple future
period(s) based on current data (usually data from the most recently ended
fiscal year, known as the base period). Predetermined rates are not subject to
adjustment, except under very unusual circumstances.
 Fixed rates - rates based on current data in the same manner as
predetermined rates, except that the difference between the costs of the base
period used to establish the rate and the actual costs of the current period is
carried forward as an adjustment to the rate computation for a subsequent
period.
 Provisional rates - temporary rates used for funding and billing indirect costs,
pending the establishment of a final rate for a period.
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18
Indirect Costs – Not-for-Profit A-122
• To recover indirect costs, Not-for Profit Organizations (NPOs)
prepare ICRPs. The ICRP is the rate calculation and supporting
schedules used to arrive at the indirect cost pool amounts and the
base amounts.
 A NPO which has not previously established an indirect cost rate with a
Federal agency shall submit its initial indirect cost proposal immediately after
the organization is advised that an award will be made and, in no event, later
than three months after the effective date of the award.
 Organizations that have previously established indirect cost rates must submit
a new indirect cost proposal to the cognizant agency within six months after
the close of each fiscal year.
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19
Indirect Costs – Not-for-Profit A-122 (Con’t)
• While it is not possible to specify the types of costs that will be
indirect, there are three major categories of indirect costs for
NPOs:
 Depreciation and Use Allowance - Costs of the organization’s buildings,
capital improvements to land and buildings, and equipment. Interest on debt
associated with certain buildings, equipment, and capital improvements.
 Operation and Maintenance - Administration, operation, maintenance,
preservation, and protection of the organization’s physical plant.
 General and Administrative - Overall general executive, and administration of
the organization and other expenses of a general nature that do not relate
solely to any major function of the organization.
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20
Indirect Costs – Higher Ed A-21
• In order to recover indirect costs, educational institutions must
prepare indirect cost rate proposals (ICRPs) in accordance with the
guidelines provided in A-21 and submit to the cognizant agency for
approval.
• Indirect costs are defined into two broad categories:
 “Facilities” is defined as depreciation and use allowance, interest in debt
associated with certain buildings, equipment, and capital improvements,
operation and maintenance expenses, and library expenses.
 “Administration” is defined as general administration and general expenses,
departmental administration, sponsored project administration, student
administration and services, and all other types of expenditures not listed
specifically under one of the facility categories.
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21
Indirect Costs – State & Local Gov’t A-87
• The indirect cost rate proposal (ICRP) provides the documentation
prepared by a State/local department or agency, to substantiate its
request for the establishment of an indirect cost rate. The indirect
costs include:
 Costs originating in the department or agency carrying out Federal awards,
and
 Costs of central governmental services distributed through the State/local-
wide central service Cost Allocation Plan (CAP) that are not otherwise treated
as direct costs.
• The ICRPs are based on the most current financial data and are
used to either establish predetermined, fixed, or provisional
indirect cost rates or to finalize provisional rates.
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22
CASH
MANAGEMENT
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C. Cash Management
• Two basic methods of program payments made to the
auditee:
 Cash Advance Basis
 Cost Reimbursement
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C. Cash Management, Con’t
• Reimbursement basis - program costs must be paid for
by entity funds before reimbursement is requested from
the Federal Government.
• Funds are advanced - recipients must follow
procedures to minimize the time elapsing between the
transfer of funds from the U.S. Treasury and
disbursement.
 When advance payment procedures are used, recipients must
establish similar procedures for subrecipients.
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C. Cash Management, Con’t
• Interest will be earned on funds advanced that are not
expended
 Interest earned on advances by local government grantees and
subgrantees is required to be submitted promptly, but at least
quarterly, to the Federal agency. Up to $100 (local government) or
$250 (not-for-profit) per year may be kept for administrative expenses.
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26
DAVIS-BACON
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D. Davis-Bacon Act
• Generally applicable to construction contracts in
excess of $2,000 financed by Federal assistance funds.
• Requires all laborers and mechanics to be paid wages
not less than those established for the locality of the
project (prevailing wage rates) by the DOL.
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28
ELIGIBILITY
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29
E. Eligibility
• Three major categories:
 Eligibility for Individuals
 Eligibility for Group of Individuals or Area of Service Delivery
 Eligibility for Subrecipients
• The specific requirements for eligibility are unique to
each Federal program and are found in the laws,
regulations, and the provisions of contract or grant
agreements pertaining to the program.
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E. Eligibility, Con’t
 For some Federal programs with a large number of people receiving
benefits, the non-Federal entity may use a computer system for
processing individual eligibility determinations and delivery of benefits.
 Often these computer systems are complex and will be separate from
the non-Federal entity’s regular financial accounting system.
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31
EQUIPMENT AND
REAL PROPERTY
MANAGEMENT
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F. Equipment and Real Property Management
• Equipment means tangible nonexpendable property,
including exempt property, charged directly to the
award having a useful life of more than one year and an
acquisition cost of $5,000 or more per unit.
• Title to equipment acquired by a non-Federal entity with
Federal awards vests with the non-Federal entity.
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33
F. Equipment and Real Property Management,
Con’t
• Equipment records shall be maintained
• Physical inventory of equipment shall be taken at least
once every two years and reconciled to the equipment
records,
• Appropriate control system shall be used to safeguard
equipment
• Equipment shall be adequately maintained
• Equipment no longer needed for a Federal program
(with a current per unit fair market value of $5,000 or
more) may be retained or sold but the Federal agency
has the right to a proportionate share of the current fair
market value.
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34
MATCHING
LEVEL OF EFFORT
EARMARKING
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G. Matching, Level of Effort & Earmarking
• Matching or cost sharing includes requirements to provide
contributions (usually non-Federal) of a specified amount or
percentage to match Federal awards.
 Matching may be in the form of allowable costs incurred or in-kind
contributions (including third-party in-kind contributions).
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G. Matching, Level of Effort & Earmarking,
Con’t
Basic criteria for acceptable matching:
 Are verifiable from the non-Federal entity’s records.
 Are necessary and reasonable for proper and efficient accomplishment
of project or program objectives.
 Are allowed under the applicable cost principles.
 Are not paid by the Federal Government under another award, except
where authorized by Federal statute to be allowable for cost sharing or
matching.
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G. Matching, Level of Effort & Earmarking,
Con’t
• Level of effort includes requirements for:
(a) a specified level of service to be provided from period to period,
(b) a specified level of expenditures from non-Federal or Federal sources for
specified activities to be maintained from period to period, and
(c) Federal funds to supplement and not supplant non-Federal funding of
services.
• Earmarking includes requirements that specify the minimum and/or
maximum amount or percentage of the program’s funding that
must/may be used for specified activities, including funds provided
to subrecipients.
 Earmarking may also be specified in relation to the types of participants
covered.
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PERIOD OF
AVAILABILITY
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H. Period of Availability
• Federal awards may specify a time period during which
the non-Federal entity may use the Federal funds (i.e.,
July 1, 2007 through June 30, 2008).
• Where a funding period is specified, a non-Federal
entity may charge to the award only costs resulting
from obligations incurred during the funding period and
any pre-award costs authorized by the Federal awarding
agency.
• If authorized by the Federal program, unobligated
balances may be carried over and charged for
obligations of the subsequent funding period.
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H. Period of Availability, Con’t
• Obligations - means the amounts of orders placed,
contracts and subgrants awarded, goods and services
received, and similar transactions during a given period
that will require payment by the non-Federal entity
during the same or a future period
• Non-Federal entities shall liquidate all obligations
incurred under the award not later than 90 days after
the end of the funding period (or as specified in a
program regulation) to coincide with the submission of
the annual Financial Status report
• The Federal agency may extend this deadline upon
request
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H. Period of Availability, Con’t
IF AN OBLIGATION IS FOR --
THE OBLIGATION IS MADE --
(a) Acquisition of real or
personal property.
On the date on which the Entity or
subgrantee makes a binding written
commitment to acquire the property.
(b) Personal services by an
employee of the Entity or
subgrantee.
When the services are performed.
(c) Personal services by a
contractor who is not an
employee of the Entity or
subgrantee.
On the date on which the Entity or
subgrantee makes a binding written
commitment to obtain the services.
(d) Performance of work
On the date on which the Entity or
other than personal services. subgrantee makes a binding written
commitment to obtain the work.
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H. Period of Availability, Con’t
IF AN OBLIGATION IS FOR --
THE OBLIGATION IS MADE --
e) Public utility services.
When the Entity or
subgrantee receives the
services.
(f) Travel.
When the travel is taken.
(g) Rental of real or personal
property.
When the Entity or
subgrantee uses the property.
(h) A pre-agreement cost that was
properly approved by the Entity
under the applicable cost principles.
On the first day of the
subgrant period.
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PROCUREMENT
SUSPENSION AND
DEBARMENT
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I. Procurement, Suspension and Debarment
• Procurement
 The Entity must use procurement policies that comply with federal
guidelines.
• Suspension and Debarment
 The Entity is prohibited from contracting with or making
subawards under covered transactions to parties or their
principals that are suspended or debarred.
 Covered transactions include contracts for goods or services
equal to or in excess of $25,000 and all subrecipients
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I. Procurement, Suspension and Debarment,
Con’t
Methods of procurement to be followed
• Procurement by small purchase procedures.
 Small purchase procedures are those relatively simple and informal
procurement methods for securing services, supplies, or other property that
do not cost more than $25,000
 price or rate quotations shall be obtained from an adequate number of
qualified sources
• Procurement by sealed bids (formal advertising).
 Bids are publicly solicited and awarded to the lowest responsible bidder.
 Preferred method for procuring construction
• Procurement by noncompetitive proposals
 Solicitation of a proposal from only one source (i.e. sole source).
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I. Procurement, Suspension and Debarment,
Con’t
• Contract cost and price.
 Must perform a cost or price analysis in connection with every procurement
action including contract modifications.
 The method and degree of analysis is dependent on the facts surrounding the
particular procurement situation, but as a starting point, grantees must make
independent estimates before receiving bids or proposals.
 A cost analysis must be performed when the offeror is required to submit the
elements of his estimated cost, e.g., under professional, consulting, and
architectural engineering services contracts.
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I. Procurement, Suspension and Debarment,
Con’t
Administration & Records of Procurement Transactions:
• Grantees and subgrantees will maintain records
sufficient to detail the significant history of a
procurement. These records will include, but are not
necessarily limited to the following:
 rationale for the method of procurement,
 selection of contract type,
 contractor selection or rejection
 basis for the contract price.
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I. Procurement, Suspension and Debarment,
Con’t
Suspension and Debarment
• Non-Federal entities are prohibited from contracting with or making
subawards to parties that are suspended or debarred or whose
principals are suspended or debarred.
 Procurement contracts for goods and services awarded under a grant or
cooperative agreement that are expected to equal or exceed $25,000
 All subawards to subrecipients are considered covered transactions
• This verification may be accomplished by checking the Excluded
Parties List System (EPLS)
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PROGRAM INCOME
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J. Program Income
• Program income is gross income received that is
directly generated by the federally funded project
during the grant period.
• If authorized by Federal regulations or the grant
agreement, costs incident to the generation of program
income may be deducted from gross income to
determine program income.
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J. Program Income, Con’t
• Program income includes, but is not limited to:
 Income from fees for services performed,
 Use or rental of real or personal property acquired with grant funds,
 Sale of commodities or items fabricated under a grant agreement,
 Payments of principal and interest on loans made with grant funds.
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J. Program Income, Con’t
• Program income does not include:
 Interest on grant funds (covered under “Cash Management”),
 Rebates, credits, discounts, refunds, etc. (covered under “Allowable
Costs/Cost Principles”),
 Interest earned on any of them (covered under “Cash Management”).
 Proceeds from the sale of equipment or real property (covered under
“Equipment and Real Property Management”).
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REAL PROPERTY
ACQUISITION AND
RELOCATION
ASSISTANCE
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K. Real Property Acquisition and Relocation
Assistance
• This type of requirement has two elements:
 Provides for equitable and uniform treatment of persons displaced by
Federally-assisted programs from their homes, businesses or farms
 Covers the payments of moving related expenses and
reestablishment expenses incurred by displaced businesses and farm
operations
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REPORTING
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L. Reporting
•
This type of requirement is specific to the program
however generally requires monthly, quarterly and/or
annual status reports to be submitted to the funding
source
•
Reports may be:

Financial

Performance

Special reporting
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L. Reporting, Con’t
Financial Reporting
• Each recipient must report program outlays and
program income on a cash or accrual basis, as
prescribed by the Federal awarding agency.
• The reporting requirements for subrecipients are as
specified by the pass-through entity. In many cases,
these will be the same as or similar to the requirements
for recipients.
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L. Reporting, Con’t
Performance Reporting
•
•
To be submitted at least annually
Performance reports generally contain, for each award,
brief information on each of the following:
1. A comparison of actual accomplishments with the goals and
objectives established for the period.
2. Reasons why established goals were not met, if appropriate.
3. Other pertinent information including, when appropriate, analysis
and explanation of cost overruns or high unit costs.
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L. Reporting, Con’t
Special Reporting
• Non-Federal entities may be required to submit other
reporting which may be used by the Federal agency for
such purposes as allocating program funding.
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SUBRECIPIENT
MONITORING
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M. Subrecipient Monitoring
A pass-through entity is responsible for:
• Award Identification - At the time of the award, identifying to the
subrecipient the Federal award information (e.g., CFDA title and
number, award name, name of Federal agency) and applicable
compliance requirements.
• During-the-Award Monitoring - Monitoring the subrecipient’s use of
Federal awards through reporting, site visits, regular contact, or
other means to provide reasonable assurance that the subrecipient
administers Federal awards in compliance with laws, regulations,
and the provisions of contracts or grant agreements and that
performance goals are achieved.
• Pass-Through Entity Impact - Evaluating the impact of subrecipient
activities on the pass-through entity’s ability to comply with
applicable Federal regulations.
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Subrecipient Monitoring, Con’t
Subrecipient Audits:
1. Ensuring that subrecipients expending $500,000 or more in
Federal awards during the subrecipient’s fiscal year have met the
audit requirements of OMB Circular A-133 and that the required
audits are completed within 9 months of the end of the
subrecipient’s audit period,
2. Issuing a management decision on audit findings within 6 months
after receipt of the subrecipient’s audit report, and
3. Ensuring that the subrecipient takes timely and appropriate
corrective action on all audit findings. In cases of continued
inability or unwillingness of a subrecipient to have the required
audits, the pass-through entity shall take appropriate action using
sanctions.
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Subrecipient Monitoring, Con’t
Monitoring activities normally occur throughout the year
and may take various forms, such as:
• Reporting - Reviewing financial and performance
reports submitted by the subrecipient.
• Site Visits - Performing site visits at the subrecipient to
review financial and programmatic records and observe
operations.
• Regular Contact - Regular contacts with subrecipients
and appropriate inquiries concerning program
activities.
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SPECIAL TESTS
AND PROVISIONS
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N. Special Tests and Provisions
• The specific requirements for Special Tests and Provisions are
unique to each Federal program and are found in the laws,
regulations, and the provisions of contract or grant agreements
pertaining to the program.
• For programs listed in the Compliance Supplement:
 Special Tests and Provisions are in Part 4 - Agency Program Requirements
• For programs not listed in the Compliance Supplement:
 Review the program’s contract and grant agreements and referenced laws
and regulations to identify the compliance requirements which could have a
direct and material effect on each program.
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Questions and Answers
• Where can we find the suspension and debarment listing?
 Entity may verify suspension and debarment by checking the Excluded
Parties List System (EPLS) at www.epls.gov
• How often should we check this list?
 Refer to the attachment document
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