Funding Attractions Presents ‘The Return of the Snail’

June 1, 2012 | By Jerry Ashworth | Post a Comment

OK, although I promised myself I wouldn’t go overboard, I had to do this at least once. We present the return of the snail. If you were a follower of our blog posts last spring, you’ll probably remember that we ran a snail picture for several days to mark the Office of Management and Budget’s delay in issuing the 2011 OMB Circular A-133 Compliance Supplement. It was actually amazing that we could find so many different snail pictures. When the OMB finally released it a year ago today, we set the snail free and replaced it with a picture of fireworks.

Today the snail comes back.

OMB officials earlier in May had said they planned to release the 2012 Compliance Supplement by May 31. They now inform us that the document is still in clearance, and they hope to release it “in a couple of weeks.” Remember my blog post last month about the AICPA Not-for-Profit Conference? Again, I say that June 21 is the key target date for the release of the Compliance Supplement.

All that being said, the OMB has released a draft version to key audit stakeholder groups to enable them to prepare for the final version. The draft supplement adds seven programs and deletes eight programs, while making title changes to nine programs and Catalog of Federal Domestic Assistance number changes to two other programs. It also takes out references to the Standard Form 269 and SF-272, which have now been replaced by the SF-425, Federal Financial Report.

The draft also modifies three compliance requirements in Part 3. The section on “Procurement and Suspension and Debarment” now addresses the relationship between the procurement requirements in the grants administrative rules and the changed federal simplified acquisition threshold. The section on “Reporting” eliminates references to outdated financial reports, clarifies certain aspects of subaward reporting under the Federal Funding Accountability and Transparency Act and makes other editorial changes. The section on “Subrecipient Monitoring” adds language concerning subrecipent risk considerations when performing “during-the-award monitoring.” In Appendix VII, there are various changes to audits of American Recovery and Reinvestment Act grants, including new language stating that a Type A program or cluster can be considered low risk if it was audited as a major program in either of the two prior audits.

All of the changes in the draft supplement, as well as the final version, will be explained in further detail in Thompson’s Single Audit Information Service. Be sure to check it out! Oh, and hopefully we can post a fireworks picture in the next couple of weeks.

What do you think about the changes in the draft Compliance Supplement? Let us know.



Post a Comment

Your email is never shared. Required fields are marked *