We here at Thompson are always trying to keep an eye on the future of grants and as we prepare to head into 2018, we are very curious to see what will develop as two provisions of the Office of Management and Budget’s (OMB) uniform grant guidance are addressed in the coming year.
In perhaps one of the shortest provisions in the guidance, OMB states in §200.109, Review date, that “OMB will review this part at least every five years after Dec. 26, 2013.” According to our calendar, that means that OMB is slated to review the effectiveness of the uniform guidance as of next December. What exactly will this review look like? We’re not sure. And OMB has been somewhat silent in our attempts to find out more about how detailed this review will be and when it would be completed. All we can say is stay tuned.
Another interesting provision is contained in §200.513 related to federal agency audit responsibilities. According to §200.513(a)(3)(ii), the cognizant agency for audit responsibilities must “obtain or conduct quality control reviews on selected audits made by nonfederal auditors, and provide the results to other interested organizations. Cooperate and provide support to the federal agency designated by OMB to lead a governmentwide project to determine the quality of single audits by providing a statistically reliable estimate of the extent that single audits conform to applicable requirements, standards, and procedures; and to make recommendations to address noted audit quality issues, including recommendations for any changes to applicable requirements, standards and procedures indicated by the results of the project. This governmentwide audit quality project must be performed once every six years beginning in 2018 or at such other interval as determined by OMB, and the results must be public.”
Again, here is another reference in the uniform guidance to 2018. And again, we’re not exactly sure when such an audit quality review would actually begin or end during the year. One hopes the results are better than those included in a 2007 report from the President’s Council on Integrity and Efficiency and the Executive Council on Integrity and Efficiency entitled, “Report on National Single Audit Sampling Project,” which provided a statistically reliable measure of the quality of single audits at the time. The report, which is available at http://grants.complianceexpert.com/sites/grants/files/pdffiles/NatSamProjRptFINAL2.pdf, concluded that about 52 percent of single audits sampled were of limited reliability, or were unacceptable and could not be relied upon. In response to report, both the OMB and the American Institute of Certified Public Accountants formed work groups to evaluate possible amendments to the single audit requirements, which ultimately influenced to the development of the audit provisions in the uniform guidance, including the provision at §200.513(a)(3)(ii)).
We’ll be watching to see what occurs over the next year as these reviews take shape and will let our subscribers know what they may mean for them down the road. We always love it when there’s something to look forward to in the new year.
Let us know what you expect to see in these reviews. We’d love to hear from you.