Perhaps the Dumbest Provision in OMB’s Grants Proposal

June 13, 2013 | By Jerry Ashworth | Post a Comment

1026325_silhouetteLadies and gentlemen, I proudly introduce to you — “Someone!” Look familiar? No, not to me either. Could be a man; could be a woman. It’s hard to tell. Yet our friend “Someone” here, under the Office of Management and Budget’s proposed grant reform guidance, would play a key role in determining the quality of Circular A-133 single audits.

As my daughter, who is taking elementary-level Spanish emersion, often says to me, “Qué???”

In Section __.718, Subchapter G, of the proposal, an auditor would be required to prepare and provide documentation and reports for the single audit that are “sufficiently detailed to enable someone having no previous connection to the audit to understand.” OK, I get it. The main point here is to make audits less complicated, which is a truly worthy endeavor. However, to use the word “someone” is definitely the wrong term of choice. “Someone” could be another auditor with years of experience reviewing grant programs, or “someone” could be a 1-year-old child trying to learn to walk and talk. If there ever was a broad term that OMB has ever used in its guidance, the use of the word “someone” here definitely takes the cake.

The American Institute of Certified Public Accountants, in its comments to the proposed guidance, called this provision “problematic.” No kidding, that’s an understatement if you ask me. AICPA continued on to say, “We question whether an auditor could ever meet the proposed requirement to prepare documentation so that any person, regardless of whether they are experienced in auditing, could understand it. We recommend that OMB delete the proposed requirement for audit documentation.”

AICPA noted that this provision would differ from its professional standards, which would call for the auditor to prepare audit documentation to be understandable to “an experienced auditor having no previous connection with the audit.” This is a much better wording for the requirement. I think OMB should adopt this language in the final version. I think “Someone” might agree with me (assuming they understand what I’m talking about).

How do you feel about this proposed requirement? Do you agree with me on this wording issue? Let us know.


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