Get Set, OMB, You’ve Got Some Reading To Do!

April 13, 2012 | By Jerry Ashworth | Post a Comment

Keep ‘em coming, folks, keep ‘em coming! I’ve had a chance to look over many of the comments already submitted to the Office of Management and Budget on the notice of proposed guidance related to grants management and single audit reforms and I have to say, the OMB already has much to consider.

The due date for comments is April 30 so you still have more than two weeks left to respond to the Feb. 28 Federal Register notice. The Federal Grants Management Handbook and Single Audit Information Service will feature excerpts from the comments in the May and June issues.

There are so many issues and so many questions that have been brought up by stakeholders that I don’t see how the OMB can possibly address them all. Some questions and concerns are ones I’d expected, but certain others really stand out. For example, the proposal would establish a three-tiered structure for single audits whereby entities that spend between $1 million and $3 million in federal funds would have a simplified single audit performed. Under this kind of audit, two compliance requirements would be evaluated — allowed and unallowed costs and another requirement chosen by the awarding agency. To this, the U.S. Department of Agriculture, Agricultural Marketing Service — a federal agency, no less — asked who in the agency would have authority to select the second compliance requirement? Great question! It further went on to ask if the agency would be selecting the second compliance requirement for both the recipient and its subrecipients.

Along the same lines, the Virginia Department of Public Accounts asked that if federal agencies under this kind of audit can select a second compliance requirement, can pass-through recipients select additional requirements as they deem most appropriate?

Another good point from the Montana Department of Natural Resources and Conservation Forestry Division: “It is not realistic to expect indirect costs to decline as a ratio of the federal grant amount until or unless the level of detail required in the documentation and overall administration of federal grants is reduced.” I would urge you all to check out Regulations.gov and read through the comments. This is big, and no one with any interest in grants management or single audits should let the opportunity pass them by without letting the OMB know how they feel about the proposed reforms.

Let us know if you have seen any especially interesting issues or questions raised in the comments. We can post those here.

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