An Opportunity for Clarity Wasted

June 8, 2012 | By Jerry Ashworth | Post a Comment

In a blog post a year ago today, I complained about the confusing language in a change made in the 2011 OMB Circular A-133 Compliance Supplement. I even offered a much clearer alternative. I mentioned my suggestion to others in the audit community and they favored my phrasing. Could it be that OMB used my suggestion in the draft version of the 2012 supplement? Apparently not.

In last year’s supplement, the OMB “clarified” that, for American Recovery and Reinvestment Act awards, “a subrecipient is not required to be registered in the Central Contractor Registration at the time of the subaward.” It had been my understanding that all first-tier subawardees receiving Recovery Act funds must be registered in CCR. The “Subrecipient Monitoring” section in Part 3 of the 2011 supplement states that a pass-through entity is responsible for identifying to first-tier subrecipients of Recovery Act awards the requirement to register in the CCR, and that “this requirement pertains to the ability to report pursuant to Section 1512 of ARRA and is not a pre-award eligibility requirement.” Huh?

I suggested rewording this to say “A first-tier subawardee is not required to be registered in the CCR prior to receiving a Recovery Act subaward, but once it receives the subaward, it must register in the CCR.” That makes much more sense, don’t you think? However, after scanning the draft version of the 2012 supplement, the confusing language from last year unfortunately remains.

Although I’m waiting for the final version of this year’s supplement to really delve into the changes, OMB has used the term “clarified” again when referring to changes made to the “Reporting” section in Part 3. One would hope this change would be clearer than last year’s attempt at clarity!

Have you had a chance to look at the draft version of the 2012 supplement? Are any of the changes this year confusing? Let us know.


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