Archive for May, 2011
Grant recipients (both pass-through entities and subrecipients) may want to take note of an interesting item in OMB’s recent guidance on implementation of the Improper Payments Elimination and Recovery Act (PL 111-204).
OMB says that for grant programs, agencies must consider payment recapture audits at the grant recipient level. “Federal agencies should work with state and local governments to ensure that they have enough resources to conduct payment recapture audits (for example, through direct funding, allowable administrative expenses, or contingency contracts),” OMB writes. It continues, “[G]enerally, federal agencies should not look to pass-through entities for repayment of improper payments identified by payment recapture audits for funds they pass-through until repayment has been made by the sub-recipient or the final payee.”
On this last point, I think it’s important to note that OMB is only referring to monies that were identified in recapture audits.
How agencies will implement this memo remains to be seen, but I thought some might find OMB’s take on the matter interesting.
You can view the complete OMB memo guidance here.
So are we.
Nearly two months ago I wrote in this blog that OMB might be close to meeting its goal of releasing the 2011 Circular A-133 Compliance Supplement by the end of March. But it’s now May and OMB has yet to publish the annual audit guidance.
In fact, at the recent National Grants Management Association annual conference, OMB’s Gil Tran said it might be “several weeks” before the document is released. This would put the publication date well into mid- or late May. Auditors, grantees. and federal program personnel who rely on the guidance — which will be effective for audits of fiscal years beginning after June 30, 2010 — will have to wait a little longer.
Keep watching this post for further information. You can also learn more about A-133 audit developments and other grants management issues at Management Concepts’ Federal Grants Update seminar. Click here for more on the topics, dates, locations, and registration information.