Federal & State Monitoring: The Uniform Guidance · 2016. 8. 1. · Uniform Guidance – No Longer...

Title Grants Division

Illinois State Board of Education

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Federal & State Monitoring: The Uniform Guidance

Technical Assistance Workshop 2016



Topics of Interest • Overview of the Uniform Guidance (also

commonly referred to as the Omni Circular)

• Policies and Procedures Overview • Internal Controls Overview • Audit and Monitoring Expectations • Common Findings • Reminders

2 Federal and State Monitoring Division



What is the Uniform Guidance? • In a nutshell: It’s a consolidation of 8 OMB

Circulars (2 CFR 200) • It’s called guidance, but it’s full of rules and

requirements, with some suggestions for “best practices”

• It’s not a dramatic departure from the previous requirements, but there are some new requirements and flexibilities

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From Circulars to the Uniform Guidance

Prior to the Uniform Guidance After the Uniform Guidance

Circulars A-89, A-102, A-110 Uniform Guidance Subparts B, C, and D

Circulars A-21, A-87, A-122 Uniform Guidance Subpart E

Circulars A-133, A-50 Uniform Guidance Subpart F

EDGAR Parts 75 to 99 EDGAR Parts 75 – 79 and 81 – 99

EDGAR Parts 74 and 80 substance Became part of the Uniform Guidance

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The Uniform Guidance • Enhanced Oversight Requirements of

Sub-recipients – Risk Assessment and Monitoring

• Greater Emphasis on Internal Controls and Written Policies

• Greater Focus on Performance Expectations and Results

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Federal and State Monitoring Division



Uniform Guidance – Sub-recipient Risk Assessment

• Prior experience with same or similar awards • Results of previous audits • Is the LEA required to have a federal single audit • New personnel or substantially changed systems • Results of federal awarding agency monitoring • Written procedures and internal controls • Other factors as identified by federal government,

SEA, or other authoritative guidance




Uniform Guidance – Sub-recipient Risk-Based Monitoring

• Review of financial and performance reports and supporting documentation

• Assessment of written policies and internal controls

• Issuance of management decisions for audit findings

• Ensuring sub-recipient takes timely and appropriate action on noted deficiencies




Uniform Guidance – Risk-Based Monitoring

• Whether as part of the risk-based assessment or monitoring, SEA can impose conditions, including high risk conditions, on its sub-recipients (2 CFR 200.207 and 3474.10): – Increased reporting – Reimbursement plan – Additional monitoring – Mandatory technical assistance – Additional prior approvals – Other




Uniform Guidance – No Longer Only for Federal Awards

• Grant Accountability and Transparency Act (GATA) – 30 ILCS 708 (www.ilga.gov) – Directs the Governor’s Office of Management

and Budget (GOMB) to adopt rules which adopt the Uniform Guidance at 2 CFR 200.

– The rules shall apply to all State and federal pass-through awards effective on and after July 1, 2015. (30 ILCS 708/20)

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http://www.ilga.gov/



Policies and Procedures Overview • At the heart of internal control environment • Polices and Procedures Must Be Specific to

Your District • The policy must state what you are going to do and

why • The procedures state

• What steps are required to be completed • Who is going to perform the steps • When the process will be completed • Who is responsible for review

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Policies and Procedures Overview • Specific functions/processes where written

policies/internal controls are most essential: – Payments/cash management – Compensation/personnel expenses – Procurement – Property management/inventory – Financial monitoring – Sub-recipient monitoring (contracts/grants) – Other, as needed




Internal Controls Overview • Per 2 CFR 200.303 internal controls are

elevated as an accountability measure – Grantees must:

• Establish and maintain effective internal control over federal awards • Evaluate and monitor compliance • Take prompt action in the event of noncompliance • Take reasonable measures to safeguard protected personally

identifiable information and other sensitive information – Resources

• Tool kit and PowerPoint Presentation – http://www2.ed.gov/policy/fund/guid/uniform-guidance/internal-controls.html

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http://www2.ed.gov/policy/fund/guid/uniform-guidance/internal-controls.html

http://www2.ed.gov/policy/fund/guid/uniform-guidance/internal-controls.html



Internal Controls Overview • Internal controls give reasonable

assurance that the organization will achieve its objectives through: – Effective and efficient operations – Reliable reporting – Compliance with applicable laws and

regulations

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Internal Controls: Crucial Accountability

• The elevated role of internal control – Creates a transparent system of accountability for

decision making around federal funds – The system of accountability applies equally to

federal agencies, grantees, and sub-recipients • Internal controls are not new to the financial

world – They may be new to people working on program

implementation

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Internal Controls Overview • Strong Internal Controls include:

– Policies and procedures for individual functions – Adequate segregation of duties for all functions – Supervisory review of expenditures prior to

submission – Grant and Fiscal staff review of transactions to

ensure proper posting of expenditures to grants – Procedures to ensure grant objectives are being

met – Adequate, sufficient supporting documentation




Inventory Example Items to Consider

• Procedures must be in place to ensure the control of equipment and materials both in the LEA and those in private schools

• Equipment purchases must be approved in the grant budget • Inventory records must include the following components

• Description • Serial number or other identification number • Funding source for purchased property • Who holds title • Acquisition date • Cost • Location, use and condition • Disposition date, if applicable

• All equipment purchases must be physically located in the grant usage area and must support the intent of the program




Audit and Monitoring Expectations

• Monitoring Instrument – District responses should be consistent with their approved

application – Each comment box should contain specific details to document

that the district is in compliance for that specific portion of the grant

– Submission of the instrument by the required date

• Comparability • Submission of the instrument by the required date • Maintain supporting documentation




Audit and Monitoring Expectations

• Onsite and Desk Reviews – Supporting documentation for all programs to

be reviewed – Access to staff responsible for the programs

being reviewed – Audit and monitoring function is collaborative

but ultimately independent of program administration function




Common Programmatic Monitoring Findings – Title I

• Parental Involvement • Comparability of Services • Allocation of Funds • Private School Participation • Supporting Documentation for Programs • Compliance with Requirements for

Selection of Eligible Attendance Centers

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Common Fiscal Monitoring Findings – Title I

• Inaccurate/Untimely Expenditure Reports • Salaries paid were not approved or were

inaccurate • Inventory Issues • Expenditures paid were unallowable or did

not support the program intent • Expenditures were not within the grant

period 20




• Was the cost included in application/budget? • Does the cost meet the requirements of the law? • Is the cost necessary, reasonable, allocable, and

documented? • Is the cost consistently applied? • Is the cost adequately documented?

– Examples: segregated accounts, invoices, payroll detail, cancelled checks, inventory records and other valid supporting documentation

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Basic Guidelines for Allowable Expenditures




References and Helpful Links • United States Department of Education: http://www.ed.gov • The Uniform Guidance (2 C.F.R. 200): http://www.ecfr.gov/ • Uniform Guidance Technical Assistance:

http://www2.ed.gov/policy/fund/guid/uniform-guidance/index.html

• Illinois Program Accounting Manual (IPAM): http://www.isbe.net/sfms/html/ipam.htm

• State and Federal Grant Administration Policy and Fiscal Requirements and Procedures: http://www.isbe.net/funding/pdf/fiscal_procedure_handbk.pdf

• http://www.isbe.net/e-bulletins/default.htm • http://isbe.net/grants/default.htm • http://isbe.net/ea/default.htm


http://www.ed.gov/

http://www.ecfr.gov/



http://www.isbe.net/sfms/html/ipam.htm

http://www.isbe.net/funding/pdf/fiscal_procedure_handbk.pdf

http://www.isbe.net/funding/pdf/fiscal_procedure_handbk.pdf

http://www.isbe.net/e-bulletins/default.htm

http://isbe.net/grants/default.htm

http://isbe.net/ea/htm/checklist.htm



Contact Information Illinois State Board of Education Federal and State Monitoring Division 100 North First Street Springfield, IL 62777 217-782-7970




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Federal & State Monitoring: The Uniform Guidance · 2016. 8. 1. · Uniform Guidance – No Longer...

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