On July 24, 2017, the Office of Management and Budget (OMB) released an updated listing of the Frequently Asked Questions (FAQ) that accompany the regulations found at 2 CFR Part 200 for the Uniform Guidance (UG). These FAQ largely clarify earlier topics covered by the UG. Examples include: clarification of the difference between indirect costs and administrative costs; calculating total direct costs; allowability of certain rental costs; calculating non-federal shares in awards; indirect cost issues with pass through entities; and, documentation for indirect cost rates and de minimis rates, among other topics. OMB is also extending the time period for an additional year for non-federal entities to bring their procurement policies in line with the UG. A link to the updated FAQ can be found at: http://files.constantcontact.com/eed4cac7201/255cfbae-2b3f-418d-976c-ac98cd8f05fa.pdf
On August 14, 2017, OMB also published a notice of availability of the 2017 Single Audit Act requirements. We recommend that you share this Single Audit Act Supplement with your outside auditors, as the standards will impact the fieldwork they conduct as part of the annual audit. Comments can be submitted through October 31, 2017. Of particular note is that the 2017 Supplement is extended to cover grant programs under the “477 Program Cluster” which include a range of Indian education, social service, family assistance, and training grants. A link to this Supplement can be found at: https://www.federalregister.gov/documents/2017/08/14/2017-17054/uniform-administrative-requirements-cost-principles-and-audit-requirements
Please let us know if we may provide additional information about the Office of Management and Budget’s updated FAQs for the Uniform Guidance or 2017 Single Audit Act requirements.
