Uniform Guidance Audit Overview Timeline and Contacts RAS

Uniform Guidance Audit: Overview, Timeline and Contacts RAS Friday - May 17 th, 2019 Nuala Mc. Gowan, Sr. Director of Research Finance and Compliance, FAS Christyne Anderson, Manager, Training and Compliance, OSP

Agenda - Uniform Guidance (UG) Audit: • What is it and why do we have one? • What is tested in the UG Audit? • Timeline of the Harvard University UG Audit • Contacts Pw. C 2

What is a UG Audit? • Office of Management and Budget (OMB) Uniform Guidance (UG) requires an annual external audit of non-profit organizations expending more than $750, 000 in federal funds • Requirements are to test internal controls and compliance over financial reporting as well as test compliance and internal controls over major programs (two different levels) • A sample of federal awards and their direct cost transactions are selected for testing to determine if expenditures and procedures are appropriate (i. e. , in accordance with sponsor terms and conditions, and the CFR – Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements. Pw. C 3

Why is the UG Audit Important? • All federal and non-federal sponsors look at the UG Audit report as a ‘report card’ of how the University spends their money • Findings are reported to the federal government, become public record, and are distributed to all federal agencies through a clearinghouse • Each department performing sponsored research is accountable for ensuring that the reported expenditures are appropriate with the terms and conditions of the award and federal cost principles (CFR - 200) Pw. C 4

What is tested in the Uniform Guidance Audit? • Internal controls • Financial & non-financial reporting • Equipment • Subrecipient monitoring • Cost transfers • Service centers • Cost sharing • F&A rate application • Program income • Activities allowed / unallowed (direct costs, effort, etc) • Procurement and Suspension and Debarment Note: Direct attribution (linkage between cost and purpose of the project) must be established and demonstrated through supporting documentation.

What’s involved? • Direct Cost selection- Orientation in June • Deep dive into one grant within your department • 3 -15 individual transactions selected for review • Completion of the Compliance Control Questionnaire (CCQ)- a comprehensive document evaluating departmental procedures and internal controls • Supporting documentation and CCQ due in mid-July • Other selections (Cost Transfers, Cost Sharing, Procurement, etc. ) • Typically selected in April • Supporting documentation due in May Additional testing takes place between Pw. C and OSP (LOC, FFRs, etc. )

Contacts Alan Berkeley Manager, Research Compliance & Training, RAS – FAS Berkeley@fas. Harvard. edu Christyne Anderson Manager, Training and Compliance, OSP Christyne_Anderson@Harvard. edu

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