What to Expect in 2016?
Last month, one of my blog posts examined some of the significant developments for grants administration in 2015. Last year was, to put it mildly, a very busy year. In addition to implementing and complying with 2 CFR 200, the grants community also had to prepare for the implementation of the Digital Accountability and Transparency Act (DATA Act) and the Federal Awardee Performance and Integrity Information System (FAPIIS). Adding to the workload were multiple amendments to the Uniform Guidance and a host of proposed rules affecting Federal grants.
So, what does 2016 have in store for the grant community?
Here’s a look at some of the key events I’m keeping an eye out for:
Final Agency Implementation of 2 CFR 200
To date, only about half of the Federal grant making agencies have adopted a final rule implementing 2 CFR 200. While all new Federal awards must be in compliance with the Uniform Guidance, it will be beneficial once all agencies have adopted a final rule. This will enable grant recipients to know of any agency-specific exceptions or additional requirements.
Internal Control Guidance
In the 2015 Compliance Supplement, the Office of Management and Budget (OMB) removed guidance on internal control. In Part 6 of the 2015 Compliance Supplement, OMB indicated that there was insufficient time to develop new guidance and that non-Federal entities and auditors should refer to the “Internal Control-Integrated Framework” or to the “Green Book” for guidance. OMB plans on incorporating internal control guidance, compliant with 2 CFR 200, in the 2016 Compliance Supplement. This guidance will be an important resource for non-Federal entities to ensure internal business systems meet 2 CFR 200 requirements.
In July 2015, OMB published final guidance to implement FAPIIS for grant awards. As of January 1, 2016, Federal awarding agencies are required to review FAPIIS before making a grant award over the simplified acquisition threshold. It will be interesting to see the extent in which the new FAPIIS requirements affect the grants community. Additionally, it will be important to review any agency guidance discussing agency-specific implementation.
The audit requirements found under Subpart F of 2 CFR 200 apply during a non-Federal entity’s first full fiscal year after December 26, 2014. This means for entities with a fiscal year beginning on January 1, their single audit for fiscal year 2015 will be conducted under the new requirements. Under 2 CFR 200, single audit reporting packages will be publicly available on the Federal Audit Clearinghouse, and this will provide the grants community a first look at some of the findings auditors are reporting under the Uniform Guidance. Additionally, audit reports from Offices of Inspectors General should also begin to reflect compliance concerns under 2 CFR 200. This information will be valuable for the grants community to identify common problems and to develop mitigation plans.
2 CFR 200 Metrics
The Council on Financial Assistance Reform (COFAR) established metrics to evaluate the extent to which the Uniform Guidance is achieving its goals of easing administrative burden and strengthen oversight over Federal funds to reduce risks of waste, fraud, and abuse. OMB Memorandum M-14-17 identifies the metrics that OMB and the COFAR will use to “gauge the success of [2 CFR 200] and the performance of the Federal government’s work in the management of Federal financial assistance.” Hopefully within the next year, the grants community will have evidence and data to determine how well 2 CFR 200 has been implemented and to identify any changes that may need to be made.
These are just a few items that I am eagerly anticipating for 2016. What are some of the things you are waiting to see? Let us know in the comments section below!