OMB Uniform Guidance 2014 Implementation at the University of Washington Northwest Chapter of Internal Auditors August 5th , 2014 Ted Mordhorst Asst. Dir. For Post Award Financial Compliance Research Accounting and Analysis University of Washington OMB Uniform Guidance 2014 Final Guidance document published in the Federal Register Dec 26, 2013. Codified in 2 CFR 200 Replaces 8 previous OMB Circulars: Circular A-110 Circular A-21 Circular A-102 Circular A-87 Circular A-89 Circular A-102 Circular A-133 Circular A-50 OMB Uniform Guidance 2014 Applicable to Direct Federal Grants, Cooperative Agreements and Cost-reimbursable contracts. Each federal awarding agency must implement Effective for new $ received on or after Dec. 26, 2014 Audit effective for the entities first full fiscal year after 12/26/14. Example: Entities fiscal year ends June 30th New audit requirements apply to fiscal year that ends June 30, 2016 University of Washington Approach A Core Team has been assembled • Sponsored by Mary Lidstrom, Vice Provost for Research and Susan Camber, Associate Vice President, Financial Management The team has representatives from: OR, OSP, GCA, MAA, School of Medicine, College of Arts and Sciences, Procurement Services, and Internal Audit, The AG office Additional sub-teams have been formed to review some of the more complex areas. University of Washington Presenter’s Office Uniform Guidance Working Group The working groups compared the new regulation to the existing regulations in A-110, A-21 and A-133 Identify changes Map changes to university policy and procedures Identifying possible changes to IT systems both central and in units Propose changes to policy, procedures necessary to maintain compliance University of Washington Presenter’s Office Uniform Guidance Working Group Develop internal Communication plan. Develop protocol for making changes to policies and procedures. Develop training for campus personnel. Modify existing training material for faculty and staff. University of Washington Presenter’s Office Uniform Guidance Working Group Timeline APRIL 15 DISCOVERY (initial discovery of what changed complete) MAY 15 DISCOVERY (impact to UW systems complete) JUNE 01 DISCOVERY (map to UW policy & procedure complete) JUNE 26 FEDERAL PLANS RELEASED (Federal agencies release their respective implementation plans)(Has not happened.) SEPT 30 DRAFT OF CHANGES TO UW POLICY (comprehensively address & publish all changes to UW policy) DEC 01 UW READY TO IMPLEMENT CHANGES (changes to UW policy & procedure approved & published) DEC 26 FEDERAL IMPLEMENTATION BEGINS University of Washington Presenter’s Office Uniform Guidance Working Group We established a web page for the team at: http://www.washington.edu/research/topics/uniformgrant-guidance/ Contains links to the Final Uniform Guidance document Links to other documents and presentations Continues to be updated as more information becomes available. Uniform Guidance Working Group There are Open Issues… Agency deviations – how will these be policed? Conflict of Interest – agency plans are key Research Terms and Conditions – (FDP) a lot to do in little time Internal Controls – audit repercussions, if any? Procurement – could be most significant new burden Subrecipient Monitoring – could be second most significant Closeouts – not a major change in the Uniform Guidance, but the pressure for timely closeouts has raised profile Uniform Guidance Working Group Other Issues… The UW is working with the Council on Governmental Relations to obtain clarification from OMB on a number of areas: Conflict of Interest – Institutional or individual Program Income – Treatment of Royalties or other IP Income Equipment – “Conditional Title” Procurement – Small purchase threshold – required competition Uniform Guidance Working Group Challenges: Conflicting Priorities for team members Differing interpretations OMB/COFAR slow response to questions Pending clarification issues Agency implementation plans not published Uniform Guidance Working Group A lot of questions remain but some of the more visible changes will have little impact on our policy and procedure. Effort Certification – No change planned Direct Charging of Administrative & Clerical Salaries – Little or no change planned Electronic Records – Already moving to a paperless environment Subrecipient Monitoring – Just revamped our processes Uniform Guidance Implementation University of Washington Questions?