U S Department of Homeland Security Uniform Administrative

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U. S. Department of Homeland Security Uniform Administrative Requirements, Cost Principles, and Audit Requirements

U. S. Department of Homeland Security Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Super Circular) Presented by: Andrea Brandon, Director Financial Assistance Policy and Oversight December 2, 2014 Procurement Sensitive – For Official Use Only 1

Super Circular Objectives • Eliminate duplicative and conflicting guidance • Focus on performance over

Super Circular Objectives • Eliminate duplicative and conflicting guidance • Focus on performance over compliance for accountability • Encourage efficient use of information technology and shared services • Provide consistent and transparent treatment of costs 2

Super Circular Objectives, cont’d • Encourage non-Federal entities to have family-friendly policies • Strengthen

Super Circular Objectives, cont’d • Encourage non-Federal entities to have family-friendly policies • Strengthen oversight • Target audit requirements on risk of waste, fraud, and abuse 3

Super Circular Logistics • Combines Circulars A-21, A-50, A-87, A-89, A-102, A 110, A-122.

Super Circular Logistics • Combines Circulars A-21, A-50, A-87, A-89, A-102, A 110, A-122. and A-133 • Can be found at 2 CFR 200 • Will take effect December 26, 2014 • Requires that awarding agencies adopt the circular and issue a regulation by the December, 2014 date 4

DHS Activities on the Super Circular • Developed in-depth analysis of operational changes in

DHS Activities on the Super Circular • Developed in-depth analysis of operational changes in the new circular • Has been submitted to the Council of Heads of Financial Assistance Activities (CHFAA) for review and comment • Is available to DHS financial assistance operational staff on the DHS Connect Share. Point site. 5

DHS Activities on the Super Circular • Prepare a DHS FAQ to assist financial

DHS Activities on the Super Circular • Prepare a DHS FAQ to assist financial assistance Component operational staff • DHS-wide webcasts to keep the Components informed • Continue to update analysis of the Super Circular based on feedback from the Components 6

DHS Activities on the Super Circular • Develop DHS performance metrics for outcome related

DHS Activities on the Super Circular • Develop DHS performance metrics for outcome related requirements specified in the new guidance • Determine new risk areas and control points as they relate to the new guidance. • A-123 Internal Control Guidance on various points of the grants management process 7

Some Key Changes found in the Super Circular • Streamlines salaries and wages reporting

Some Key Changes found in the Super Circular • Streamlines salaries and wages reporting requirements for grantees • Internal controls for grant recipient reporting • Updates policies on direct vs. indirect cost • Creates a de minimis 10% indirect cost rate for grantees without a negotiated rate • Cost sharing only allowed by program statute or publically announced by the head of the agency • Cost sharing criteria cannot be considered in the peer review process • Clarification of allowable and unallowable costs for entertainment, employee morale, participant incentives, etc. • More rigorous pre-award fiscal analysis of applicants • Single Audit threshold raised to $750, 000 • Single Audits publically available for review on the Federal Audit Clearinghouse (FAC) 8

Questions: • Is this only related to OMB circulars or does it also make

Questions: • Is this only related to OMB circulars or does it also make changes to the CFR or other guidance, rules and regulations? • Highlight the differences between the Super Circular and the 44 CFR. • What kind of recipient does the Super Circular Apply to? • What is the date that it becomes applicable to grantees? • What is FEMA doing to prepare for the Implementation? • How will FEMA assist the states in this transition? • Will there be changes for sub recipients as well? 9

Super Circular Questions? Contact: Andrea Brandon 202 -447 -0675 Andrea Brandon@hq. dhs. gov 10

Super Circular Questions? Contact: Andrea Brandon 202 -447 -0675 Andrea Brandon@hq. dhs. gov 10