OMB’s Uniform Grant Guidance Single Audit Effective Date – Simplified!

June 13, 2014 | By Jerry Ashworth | Post a Comment

calendar-1-1150170-mWe’ve spent a great amount of effort in our articles and handbook updates explaining that the Office of Management and Budget’s uniform grant guidance becomes effective for federal funds awarded on or after Dec. 26, 2014. However, things haven’t been quite so clear for the auditors conducting single audits. When does the new guidance take effect for these audits?

I have to hand it to Terry Ramsey, senior technical advisor at the Department of Health and Human Services, for trying to add some clarification to this effective date. Speaking at the American Institute of Certified Public Accountants’ Not-for-Profit Conference yesterday, Ramsey explained the effective dates for the uniform guidance, actually titling one of his slides “Effective Date – Are You Sure You Get It??”

Here’s how he put it:

  • For June 30, 2014, Sept. 30, 2014 and Dec. 31, 2014 year-ends – no impact from the uniform grant guidance for nonfederal entities and auditors.
  • For March 31, 2015, June 30, 2015 and Sept. 30, 2015 year-ends – nonfederal entities will have to adopt new administrative requirements and cost principles relating to all new federal awards and additional funding to existing awards. Single audit requirements continue to use “old” regulations, but auditor compliance testing will be affected by client adoption of “new” requirements (i.e., will likely have to test some awards subject to the old requirements and some according to the new requirements).
  • December 31, 2015 year-ends and beyond – new administrative requirements, cost principles and new single audit requirements apply.

There, does that make it any clearer? It’s all still a bit complicated. However, what is even more daunting is that Ramsey asked the audience of a few hundred attendees if they had read the new guidance. A fair number raised their hand. Then he asked if they had begun developing their policies and procedures according to the guidance and almost every raised hand came down. Time is now to start preparing for the guidance and getting your house in order. We here at Thompson are ready to help you stay in compliance with the new guidance. There are many changes so don’t get left behind.

Does this explanation of the single audit effective dates help? Let us know.


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