Changes to the SFA Audit as a Result of the OMB Uniform Grant Guidance and Compliance Supplement

Transcription

1 Changes to the SFA Audit as a Result of the OMB Uniform Grant Guidance and Compliance Supplement TASFAA 2016 EMBASSY SUITES FRISCO, TX OCTOBER 5-7,

2 Instructor Kenneth P. Wood, C.P.A., M.B.A. Audit Partner at TJS Deemer Dana LLP in charge of Education Services Group 25 years in public practice 18 years auditing colleges and universities Licensed in most states (including TX) Approximately 110 college and university clients 2

3 Objectives To identify and discuss general changes to the SFA Audit as a result of OMB Uniform Grant Guidance and Compliance Supplement To identify and discuss specific changes to the SFA Audit as a result of OMB Uniform Grant Guidance and Compliance Supplement 3

4 General Changes Eight OMB Circulars, including A-133, have been combined into one Super Circular that took effect for organizations beginning with December 31, 2015 year-ends The changes specific to OMB Circular A-133 are now included in Subpart F of the new Uniform Grant Guidance All audits will be required to be submitted electronically to the Federal Audit Clearing house, which makes them accessible to all funding agencies 4

5 Threshold for Audit Perhaps the biggest change is the increased threshold for the Single Audit A-133 standards: State, local governments and not-forprofit organizations that expend more than $500,000 in federal funds per fiscal year require a single audit Uniform Grant Guidance: State, local governments and not-forprofit organizations that expend more than $750,000 in federal funds per fiscal year require a single audit Agreed-upon procedures can be used for the grants in the $500,000 to $700,000 range 5

6 Type A/B Major Program Threshold OMB Circular A-133 classifies larger programs as type A programs and smaller programs as type B programs A-133 standards: For organizations that spend between $750,000 and 25 million in total federal awards per fiscal year the type A/B threshold is $300,000 Uniform Grant Guidance: For organizations that spend between $750,000 and 25 million in total federal awards per fiscal year the type A/B threshold is $750,000 6

7 Type A/B Audit Requirements A-133 standards: Type A programs need an audit if they have not been audited as a major program in the past two audit cycles Uniform Grant Guidance: Also states that programs will be tested as a major program if in the previous audit there was a material weakness, a modified opinion, or if questioned costs exceeded 5% of the programs funded by federal grants 7

8 Percentage of Coverage A-133 standards: Low risk entities: percentage of audit coverage is 25% High risk entities: Percentage of audit coverage is 50% Uniform Grant Guidance: Low risk entities: percentage of audit coverage is 20% High risk entities: Percentage of audit coverage is 40% 8

9 Findings Threshold A-133 standards: Findings greater than $10,000 for a compliance requirement for a major program will be reported Uniform Grant Guidance: Findings greater than $25,000 for a compliance requirement for a major program will be reported This could result in fewer findings being reported 9

10 SEFA Changes Schedule of Expenditures of Federal Awards (SEFA) Uniform Grant Guidance: Now required to include two columns on the schedule for the report 1. One column with the total expenditures for the grant 2. One column with the amount of the grant that was passed to the recipient 10

11 SFA Cluster Changes Federal Perkins Loan: June 2015: A school follows up with a disbursement record for that student no more than 30 days before a disbursement is to be paid June 2016: A school follows up with a disbursement record for that student no earlier than 7 calendar days prior to the disbursement date under HCM1 or the date of the disbursement under HCM2 11

12 SFA Cluster Changes Federal Perkins Loan (continued): June 2015: Institutions must report student payment data within 30 calendar days after the school makes a payment, or becomes aware of the need to make an adjustment Schools may do this by reporting once every 30 calendar days, bi-weekly, or weekly. June 2016: Institutions must report student payment data within 15 calendar days after the school makes a payment, or becomes aware of the need to make an adjustment Schools may do this by reporting once every 15 calendar days, bi-weekly, or weekly. 12

13 SFA Cluster Changes Verification: June 2016: On October 2, 2015 ED issued a statement regarding acceptable documents for individuals selected for verification who are not able to obtain a transcript of their tax return from the IRS. ( Applies only to those who used one of the official IRS processes to request a transcript ) These tax filers will need to provide to the institution proof that the IRS was unable to provide the tax return transcript 13

14 SFA Cluster Changes Return of Title IV Funds: June 2015: an institution may credit a student s account for minor prior-award-year charges, if not more than $200 or the payment of minor prior-year charges (in excess of $100) will not prevent the payment of the current year charges June 2016: an institution may credit a student s account for minor prior-award-year charges, if not more than $200 or the payment 14

15 SFA Cluster Changes Enrollment Reporting: June 2015: For both Pell and DL programs, institutions must complete and return within 30 days the Enrollment Reporting roster file placed in the Student Aid Internet Gateway mailboxes sent by ED via NSLDS The institution can decide how often to receive the report with the default set at every 2 months, with a minimum of twice a year June 2016: For both Pell and DL programs, institutions must complete and return within 15 days the Enrollment Reporting roster file placed in the Student Aid Internet Gateway mailboxes sent by ED via NSLDS The institution can decide how often to receive the report with the default set at a minimum of every 60 days 15

16 SFA Cluster Changes Enrollment Reporting (continued): June 2016: NSLDS will send a Late Enrollment Reporting notification if no updates are received by bath or online within 22 days after the date the NSLDS website can be created The Enrollment Reporting Summary Report can be created on the NSLDS website showing the dates the roster files were sent and returned, number of errors, date and number of online updates, and the number of late enrollment reporting notifications sent for overdue Enrollment Reporting rosters 16

17 SFA Cluster Changes Federal Direct Loans: June 2015: Institutions must report all loan disbursements and submit required records to the Direct Loan Servicing System via the COD within 30 days of disbursement June 2016: Institutions must report all loan disbursements and submit required records to the Direct Loan Servicing System via the COD within 15 days of disbursement 17

18 SFA Cluster Changes New Student Eligibility Requirements: 18

19 SFA Cluster Changes New Student Eligibility Requirements (continued): 19

20 SFA Cluster Changes New Student Eligibility Requirements (continued): 20

21 SFA Cluster Changes New Student Eligibility Requirements (continued): 21

22 Questions??? 22

23 Kenneth P. Wood, CPA Partner TJS Deemer Dana LLP Savannah, GA