Is OMB Finding the Best of Bunch?

March 14, 2012 | By Jerry Ashworth | Post a Comment

It’s that time of year again. The time when some people go nuts trying to pick the winners in the NCAA basketball tournament, and many will even call in sick on Thursday and Friday to watch the games (ahem, definitely not me). Some may care less, but personally, I find pretty exciting the process of 68 teams getting winnowed down until finally, you have two teams playing for the national championship.

I tied this whole March Madness thing into a blog post last year asking readers to do the same thing with the 14 compliance requirements in the OMB Circular A-133 Compliance Supplement. In essence, I asked them to rank the compliance requirements as to what they thought were the final four most important ones. I still would like to get some comments on that one.

Interestingly, one of the proposed reforms in OMB’s Feb. 28 notice of proposed guidance would be to streamline the compliance requirements into a subset of the most important requirements that focus on fraud, waste, abuse and program performance. OMB’s listed these particular requirements in its example: allowable or unallowable activities and costs, eligibility, reporting, selection of subrecipients and subrecipient monitoring, special tests and provisions, period of availability of federal funds, and compliance of procurement with suspension and debarment policies.

What do you think about OMB’s subset? Do you think these are the most important? Would reducing the number of compliance requirements help you when going through the single audit process? One of the questions OMB specifically asks for public comment in the notice is, “Which types of currently universal single audit compliance requirements do you think are most essential to identifying and mitigating waste, fraud and abuse?” We urge all stakeholders to send comments to OMB with their response to this question. The streamlining effort concerning the compliance requirements could prove beneficial for grantees and their auditors, but all issues, both good and bad, should be presented to the OMB before the March 29 comment period deadline.

We’d also like to hear your thoughts on the OMB’s proposed subset. Let us know if this is a good idea or not.


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