Information on Uniform Guidance Review Slowly Trickles In

Jerry Ashworth
August 14, 2019 at 07:45:04 ET
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While on a recent vacation, my family and I decided to take a 30-minute hike up a trail in the woods to find a waterfall that we had identified on our guide map. After an exhausting uphill trek in 90-degree heat, we arrived at said “waterfall” to find that there really wasn’t much to see. As we later found out, when there’s a drought, the falls turned from a beautiful cascade to just a mere trickle … which is pretty much all we saw. Still, while the waterfall aspect turned out to be a bust, it still was enjoyable to sit back and enjoy the natural scenery around us.

This trickle reminded me about how we feel around here when getting information about the Office of Management and Budget’s five-year review of the uniform guidance. We know it’s required, as per §200.109 of the uniform guidance, but what we don’t know is just how much will be included in the review. We did get a trickle of information in April, which we provided in a blog post at the time. An OMB official explained that the intent of the proposed revisions is to address administrative priorities to reduce recipient burden, fix inconsistent terminology, resolve conflicts within the regulation and address statutes enacted since the final guidance was issued.

A bit more of a trickle of information came this week at the American Institute of Certified Public Accountants’ Governmental Accounting and Auditing Update Conference in Washington, D.C. OMB’s Gil Tran reiterated that the review is not a complete overhaul of the uniform guidance, essentially calling it Uniform Guidance Version 1.1, not Version 2.0. However, he did add that one issue that OMB may better clarify is pass-through responsibilities when evaluating subrecipient single audit findings.

He also provided a little bit more clarity on the timing. OMB plans to release the proposed revisions in October for public comment. After evaluating these comments, OMB expects to release the final version in December.

Another item of note: There is a requirement for OMB to perform a governmentwide audit quality project once every six years beginning in 2018 or at such other interval as determined by OMB to determine the quality of single audits conducted, and make the results public (§200.513(a)(3)(ii)). Tran said that OMB plans to propose delaying this requirement to better reevaluate it.

We'll continue to keep tabs on the uniform guidance review and will let our subscribers know the latest information and how it will affect their federal awards.

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