Sneak Preview: Comments Sought on Draft Data Collection Form

February 5, 2016 | By Jerry Ashworth | Post a Comment
xsass_bookshot(The following was excerpted from a recent article in the Single Audit Information Service.) The Office of Management and Budget (OMB) is seeking comments on a draft Data Collection Form for Reporting on Audits of States, Local Governments and Nonprofit Organizations (SF-SAC) for single audits and program-specific audits of auditee fiscal years (FYs) beginning on or after Dec. 26, 2014. The draft SF-SAC, which is planned for final release later this year, would comply with audits under Subpart F of the OMB’s uniform grant guidance. The SF-SAC is Appendix X of the uniform guidance.

The Federal Audit Clearinghouse (FAC) website (www.harvester.census.gov/sac) currently contains a SF-SAC form and instructions for audits for FYs 2013, 2014 and 2015 under former Circular A-133. (The FAC also still makes available the SF-SAC for audits of FYs 2010, 2011 and 2012 for late submissions.)

Nonfederal entities that expend $750,000 or more in federal awards during a fiscal year are required to obtain a single audit under Subpart F of the uniform guidance (§200.501) for audit periods beginning on or after Dec. 26, 2014 (§200.110(b)). The SF-SAC is used to report audit results, audit findings and questioned costs. Auditees must submit to the FAC a completed SF-SAC when they submit a single audit or program-specific audit reporting package. The proposed revisions in the draft SF-SAC revise some existing data elements and delete others that are no longer needed.

For audits using the existing SF-SAC for FYs 2013, 2014 and 2015, a senior-level representative of the auditee (e.g., state controller, director of finance, chief executive officer or chief financial officer) must sign and date a certification statement indicating that the information included in the SF-SAC is accurate and complete, and that the audit was performed in accordance with Circular A-133. However, under the draft SF-SAC, a senior-level representative of the auditee has more responsibilities, including verifying that the SC-SAC:

  • does not include protected personally identifiable information (§200.512(b)(1);
  • does not include business identifiable information;
  • complies with Subpart F of the uniform guidance and the accompanying instructions to the SF-SAC;
  • is accurate and complete;
  • ensures that the auditor has completed the audit and presented a signed audit report that was conducted according to the uniform guidance.

Under the uniform guidance, the FAC is authorized to make the Data Collection Form and the reporting package publicly available on a website (§200.510(b)(1)) unless an eligible tribal government or organization as defined in the Indian Self-Determination, Education and Assistance Act, 25 U.S.C. 450(l) has opted out of the electronic posting (§200.512(b)(2)).

(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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