I. Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance)
On December 26, 2013, OMB released the Uniform Grant Guidance (formally titled 2 CFR Chapter I, Chapter II, Part 200, et al. Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards; Final Rule).
For fiscal years beginning on or after December 26, 2014, the Uniform Grant Guidance contains the set of cost principles and audit requirements that apply to grants and subgrants awarded to non-federal entities.
2 CFR Part 200 Subpart E — Cost Principles supersedes 2 CFR Part 225, “Cost Principles for State, Local and Indian Tribal Governments” (OMB Circular A 87). Pursuant to §200.110(a) - Effective/applicability date, “The standards set forth in this part which affect administration of Federal awards issued by Federal awarding agencies become effective once implemented by Federal awarding agencies or when any future amendment to this part becomes final. Federal awarding agencies must implement the policies and procedures applicable to Federal awards by promulgating a regulation to be effective by December 26, 2014 unless different provisions are required by statute or approved by OMB. For the procurement standards in §§200.317-200.326, non-Federal entities may continue to comply with the procurement standards in previous OMB guidance (superseded by this part as described in §200.104) for two additional fiscal years after this part goes into effect. If a non-Federal entity chooses to use the previous procurement standards for an additional two fiscal years before adopting the procurement standards in this part, the non-Federal entity must document this decision in their internal procurement policies.”
2 CFR Part 200 Subpart F — Audit Requirements supersedes OMB Circular A-133. The standards set forth in this part will apply to audits of fiscal years beginning on or after December 26, 2014. One of the major changes included in this part is the audit threshold was increased to $750,000 in federal award expenditures. In addition, changes were made to the major program determination process and auditees will be required to include in the SEFA the amount of federal funds provided to subrecipients.
2 CFR Part 200, Appendix XI — Compliance Supplement 2 CFR part 200, subpart F, describes the non-Federal entity’s responsibilities for managing Federal assistance programs (2 CFR section 200.508) and the auditor’s responsibility with respect to the scope of audit (/2 CFR section 200.514). Auditors are required to follow the provisions of 2 CFR part 200, subpart F, and the Supplement.
Additional information regarding Grants Management Circulars.
II. Schedule of Expenditures of Federal Awards (SEFA)
Schedule of Expenditures of State Financial Assistance
Important Note: It is imperative that the SEFA accurately identifies all federal programs. To this end, please report the proper Catalog of Federal Domestic Assistance (CFDA) numbers and account codes for all grant programs listed. Attachment I contains a table that lists the CFDA title and number in addition to the CSDE award name and CORE-CT number. Please refer to this information when preparing the SEFA. The 2017-2018 Grant Award Listings are available on the CSDE web site at the Bureau of Grants Management’s (BGM) Grant Payment Reports page.
In our audit instructions, Attachment II contains instructions for accessing and printing the 2017-2018 Grant Award Listings.
Attachment I and III contain tables that list the CFDA title and number (for federal awards) in addition to the award name and number (for both federal and state awards). Please refer to this information when preparing the SEFA and the Schedule of Expenditures of State Financial Assistance.
In addition, pursuant to OMB Circular A-133 Section __.400(d)(2), CSDE requires all grantees to list individual Federal Awards separately. For example, in addition to listing individual Federal programs within a cluster of programs; when a Federal program has multiple award years, the auditee will list the amount of Federal awards expended for each award year separately. This information and the identifying numbers assigned to these grants are readily available in the aforementioned Grant Listing.
III. Submission of Audit Reports in Digital Format
As stated in Part iii - Audit Report Submission Information of the 2018 Compliance Supplement,
“ELECTRONIC AUDIT REPORT SYSTEM (EARS)
"EARS is a web site made available by the Municipal Finance Services Section of the Office of Policy and Management (OPM) to provide independent auditors an electronic process for uploading audit reports of their clients on-line. State grantor agencies and the public will be able to access and view the reports that have been filed on EARS.
"The filing on EARS for all parts of the audit reporting package to be submitted to OPM is mandatory. On occasion, management letters and corrective action plans may not be available by the time the financial and State Single Audit reports are issued. In such circumstances, when these items are unavailable to be filed with the remaining portions of the State Single Audit Report package, they may be filed separately at a later date with OPM by the auditee’s independent auditor by uploading such items on EARS using the “Upload a Management Letter” or “Upload a Corrective Action Plan” feature.
"Although EARS was first developed for the filing of State Single Audit reports, it has been reconfigured to allow for the filing of financial audit reports and federal single audit reports that would normally be filed with OPM or other state agencies whether or not a State Single Audit report is being filed. Further information is available on the EARS website.
"In regard to the filing of State Single Audit reports, OPM as the cognizant state agency for most entities that are required to file a State Single Audit report does still require that a hardcopy of the audit report package to be submitted to its Office by the required filing date in state law. State grantor agencies have agreed to use the State Single Audit Report package filed on-line on EARS in lieu of receiving a hardcopy of the reporting package from their grantees. State Single Audit reports should be filed on-line no later than the required filing date under state law (6-months subsequent to the entity’s fiscal year end or the extension date granted by the cognizant state agency).
"The Electronic Audit Reporting System (EARS) can be accessed by going to the EARS website at: https://www.appsvcs.opm.ct.gov/Auditing/Home.aspx. Please contact the Municipal Finance Services Section of the Office of Policy and Management at 860-418-6400 if you should encounter any problems or have any questions."
If you have any questions, please contact the Office of Internal Audit at 860-713-6540.
IV. Additional Reporting Requirement for Charter Schools
All State Charter Schools must submit to SDE a copy of their IRS Form 990 – Return of Organization Exempt from Income Tax for fiscal year ending June 30, 2018.
If an extension to file has been requested, please submit a copy of IRS Form 8868 – Extension of Time to File. IRS Form 990 should then be submitted to SDE at the end of the extension period.