Sneak Preview: DOL Rules Allow Financial Report Format Decision

March 6, 2015 | By Jerry Ashworth | Post a Comment

xgran_bookshot(The following was excerpted from a recent article in the Federal Grants Management Handbook). The Department of Labor (DOL), when stipulating the requirements for financial reports from nonfederal entities, will continue to inform its recipients whether the report will be submitted on a cash or on an accrual basis. This provision was one of several revisions the agency made to its grant regulations when adopting the Office of Management and Budget’s (OMB’s) uniform grant guidance.

DOL adopted the uniform guidance located under Title 2 of the Code of Federal Regulations (2 C.F.R. Part 200) into its agency regulations for financial assistance administration, which are found at 2 C.F.R. Part 2900. While most of the grant regulations are found under Title 2 of the C.F.R., DOL still retains some programmatic and administrative regulations under Titles 20 and 29 of the C.F.R., including 29 C.F.R. Parts 95 and 97 relating to administrative requirements for state and local governments, institutions of higher education, hospitals, nonprofits, foreign governments and international organizations, and 20 C.F.R Parts 1-1099, relating to employee benefits. This organization is explained in §2900.4 of DOL’s regulations. Most other federal awarding agencies superseded prior grant administrative rules when they issued their rules under the uniform guidance, however, there are a few exceptions outside of Title 2, such as DOL.

The uniform grant guidance is located under Title 2 of the C.F.R, as are most agency regulations relating to grants. The uniform guidance in §200.327 states that “unless otherwise approved by OMB, the federal awarding agency may solicit only the standard, OMB-approved governmentwide data elements for collection of financial information.” However, DOL received OMB approval to allow DOL awarding agencies to prescribe whether the report will be on a cash or an accrual basis. In §2900.14, DOL explains that if the awarding agency requires reporting on an accrual basis and the recipient’s accounting system is not on an accrual basis, “the recipient will not be required to convert its accounting system, but must develop and report such accrual information through best estimates based on an analysis of the documentation on hand.” This is a continuation of previous DOL requirements under the OMB circulars.

(The full version of this story has now been made available to all for a limited time on Thompson’s Grants Compliance Expert site).

 

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