Taking Another Look at Ranking Compliance Requirements

March 18, 2014 | By Jerry Ashworth | Post a Comment

1127276_basketball_hoopAlbert Einstein once quoted that immortal line that I’m quite sure you’ve heard before, “Insanity is doing the same thing over and over again and expecting different results.” Well, this slogan is appropriate now that it’s March Madness time again. How many years have you been filling out the NCAA basketball tournament brackets thinking that this will be the year that you win the office pool only to be let down, yet again? After the completion of the tournament, we should have a clear ranking of the number one team in the land.  

A couple of years ago, we posted a blog post asking readers to send in their ranking of the 14 compliance requirements in the Office of Management and Budget Compliance Supplement. In essence, we asked readers to rank the compliance requirements as to what they thought were the final four most important ones. Although we really didn’t get any response back then, we’d like to offer up another opportunity to get some response to this.

One of the changes in the proposed grant reform guidance OMB issued last year would be to streamline the compliance requirements into a subset of the most important requirements that focus on fraud, waste, abuse and program performance. It sought to reduce the number of compliance requirements from 14 to seven, keeping activities allowed or unallowed; allowable costs/cost principles; cash management; eligibility; reporting; subrecipient monitoring; and special tests and provisions. Those it considered eliminating would be Davis-Bacon; equipment and real property management; matching, level of effort and earmarking; period of availability of federal funds; procurement and suspension and debarment; program income; and real property acquisition and relocation assistance.

However, when OMB issued the final version in December 2013, it deferred a decision on reducing these compliance requirements due to stakeholder concerns about implementation. It postponed its decision about reducing the number of compliance requirements, and will re-evaluate it for future updates to the Compliance Supplement.

What do you think about OMB’s subset? Do you think these are the most important? How would you rank them? Would reducing the number of compliance requirements help you when going through the single audit process? Don’t get insane or mad, let us know how you feel.


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