Precision Experience Assurance

Accounting For Grants

FGFOA Beginner Boot Camp, Tuesday, November 19, 2013 Hyatt Regency, Sarasota FL

Bert Martinez CPA, Senior Audit ManagerPurvis Gray & Company, LLP

Tallahassee / Gainesville / Ocala / Sarasota

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Precision Experience Assurance

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Grant Accounting – Scope of Presentation

1. Regulatory Environment2. Grant Compliance Resources3. Internal Controls4. Administrative Requirements5. Cost Principles6. Single Audit

Precision Experience Assurance

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Regulatory Environment

The grantee should have an understanding of the external factors and regulators regarding grant oversight and/or single audits.

1. AICPA2. GAO3. PCAOB4. OIGS5. OMB

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Grant Compliance Resources

1. Grant Agreement2. Federal Clearinghouse3. Florida Single Audit Act4. Compliance Matrix5. Statutes, Regulations and Program

Requirements

Precision Experience Assurance

Grant

Cooperative Agreement

Grant

Cooperative Agreement

Contract

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Grant Agreement

1. Obtain and read your grant agreement and amendments

2. Summarize the important terms and conditions for compliance

3. Keep it readily available for review

Precision Experience Assurance

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Federal Audit Clearinghouse

The Federal Audit Clearinghouse homepage• Single audit reference materials• Links to several resources to assist the auditors

and auditees with Federal compliance requirements

• Single audit basics and where to get help for Federal grant recipients provided by the Grants Management Committee of the United States Government Chief Financial Officers Council

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Florida Single Audit Act

The grants manager should be familiar with applicable state compliance requirements as designated by the Executive Office of the Governor in Section 215.97, Florida Single Audit Act.

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Compliance Matrix

1. The Federal matrix of compliance requirements for federal programs is updated annually and can be found as part of the OMB A-133 Compliance Supplement link from the Federal Audit Clearinghouse homepage

2. As part of the Florida Single Audit Act, the state also updates the State Projects Compliance Supplement matrix of compliance requirements.

Precision Experience Assurance

Compliance Requirements

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A. Activities Allowed or UnallowedB. Allowable Costs/Cost PrinciplesC. Cash ManagementD. Davis-Bacon ActE. EligibilityF. Equipment and Real Property ManagementG. Matching, Level of Effort, EarmarkingH. Period of AvailabilityI. Procurement and Suspension and DebarmentJ. Program IncomeK. Real Property Acquisition/Relocation AssistanceL. ReportingM. Subrecipient MonitoringN. Special Tests and Provisions

Precision Experience Assurance

Statutes, Regulations & Program Requirements

• CFDA and CSFA• Grant Agreement• Public Policy Requirements• Special Conditions or Restrictions• Program Guidance

• CFDA and CSFA• Grant Agreement• Public Policy Requirements• Special Conditions or Restrictions• Program Guidance

Precision Experience Assurance

Internal Controls

• The Grant Manager should establish written policies and procedures regarding internal controls over each of the Compliance Requirement areas that may include:–approvals and authorization– segregation of duties– record retention–management review–documentation

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Precision Experience Assurance

Administrative Requirements

• Organization Circular

• State, Local, or Indian Tribal Governments A-102

• Institutions of Higher Education, Hospitals, and Other Non-Profits A-110

• Commercial Organizations (optional per federal agency) A-110

Precision Experience Assurance

Administrative Requirements

- Financial administration- Equipment/supplies/real property- Reporting requirements

Precision Experience Assurance

Administrative Requirements

• Equipment– Must be used to program acquired for– If no longer needed, may be used for any other

project paid for with federal dollars– Must be tracked until fair market value is below

the threshold for capital equipment– If above FMV, may be retained or sold but

proceeds go to federal agency– What threshold to use

Precision Experience Assurance

ReportingCompliance

The Grant Manager:• should have an understanding of the reporting requirements for

the applicable program• should have policies and procedures in place to ensure that

reporting – financial, performance and special, as applicable, is accurate and timely

• Electronic versions of standard forms are located on OMB’s homepage – (http://www.whitehouse.gove/omb/grants/grant-forms.html

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Precision Experience Assurance

Administrative Requirements

• Records Retention Period–Federal government: 3 years–State government or your agency

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OMB Circulars

• Cost Principles

• Audits

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Cost Principles

Organization Circular

State or Local Governments A-87

Educational Institutions A-21

Non-Profit Organizations A-122

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Financial Compliance Financial Compliance

• Cost Principles– Allocable– Necessary and reasonable– Treated consistently (direct or

indirect)– In accordance with GAAP– Net of all applicable credits

• Cost Principles– Allocable– Necessary and reasonable– Treated consistently (direct or

indirect)– In accordance with GAAP– Net of all applicable credits

Precision Experience Assurance

Financial Compliance (continued)Financial Compliance (continued)• Cost Principles (OMB Circular A-87)– Not used for cost sharing or matching

requirement for another federal award– Adequately documented– Authorized or not prohibited under under

state or local laws and regulations– In conformance with limits or exclusions on

types of amounts of costs– Consistent with recipient’s policies and

procedures

• Cost Principles (OMB Circular A-87)– Not used for cost sharing or matching

requirement for another federal award– Adequately documented– Authorized or not prohibited under under

state or local laws and regulations– In conformance with limits or exclusions on

types of amounts of costs– Consistent with recipient’s policies and

procedures

Precision Experience Assurance

Financial Compliance (continued)Financial Compliance (continued)

• Cost Principles (OMB Circular A-87)

– Selected items of cost

– Salaries charged to grants

• Cost Principles (OMB Circular A-87)

– Selected items of cost

– Salaries charged to grants

Precision Experience Assurance

Single Audit ActSingle Audit Act

• Single Audit Act (SAA)

[Auditor and auditee’s responsibilities]

• Compliance Supplement

• Single Audit Act (SAA)

[Auditor and auditee’s responsibilities]

• Compliance Supplement

Precision Experience Assurance

An Effective GrantCompliance Program

An Effective GrantCompliance Program

• Written grant procedures• Checklists• Grant monitoring and auditing• Formal and informal grant training program• Quarterly newsletter• Web page on County’s Intranet

• Written grant procedures• Checklists• Grant monitoring and auditing• Formal and informal grant training program• Quarterly newsletter• Web page on County’s Intranet