A Show Not To Be Missed

February 5, 2013 | By Jerry Ashworth | Post a Comment

As former NFL receiver Terrell Owens said, “Get your popcorn ready!” because the Office of Management and Budget will present a not-to-be-missed show this Friday for everyone in the grants community. (Editor’s note: Hmm, my blog posts do seem to have a food theme lately, don’t they?)

OMB officials will host an informational webinar Friday at 11 a.m. EST at the Council on Financial Assistance Reform website on its newly released proposed grants reform guidance. No advanced registration is required. I think it is critical that anyone involved in any aspect of the grants lifecycle — from pre-award to closeout to single audit — should take the time to view this webinar. OMB issued a massive amount of new information last week as part of its proposal, and this webinar will be a good chance to assess the highlights of what could change. Have a pen ready to take notes!

Now that OMB has published its proposed guidance, it now hopes to issue final guidance by the end of the year. That means this is your last chance to comment before the reforms are finalized. Comments are due May 2 and should be submitted electronically at Regulations.gov under docket OMB-2013-0001. OMB has stressed that comments will be most useful if they are presented in the same sequence and with same section number as the section of the guidance to which they apply. It also is requesting information regarding the cost implications of any particular proposal. It further advised commenters not to include any confidential business information, or information of a personal-privacy nature.

So if you’re wondering if your comments really matter of if the proposal is a “done deal,” consider this: In OMB’s advanced notice of proposed guidance issued in February 2012, OMB proposed a three-tiered structure on the Circular A-133 single audit threshold. After receiving significant feedback from the audit community arguing against this structure, OMB’s new proposal now would simply raise the single audit threshold from the current $500,000 to $750,000.

Although OMB states that this change can free thousands of entities from submitting single audits while still maintaining single audit coverage over more than 99 percent of federal funds, there are some potential concerns. Even if an organization expending some $700,000 annually no longer has to be subject to a single audit, it likely will have to pay for other internal and performance audits. At least under the current guidance, the single audit can be charged to the grant. That no longer would be case. Ergo, there are pros and cons with any potential change.

A lot of reading and careful consideration is needed over the next couple of months to ensure that grantees provide the most useful comments. However, the first step is to attend the webinar. Don’t miss it! I know I won’t.

Let us know if you have any immediate questions or concerns about the proposed guidance. 


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