Nuala McGowan Sr Director of Research Finance and Compliance FAS Christyne Anderson Manager Training and Compliance OSP RAS Friday May 17 th 2019 Agenda Uniform Guidance UG Audit ID: 1047719
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1. Uniform Guidance Audit:Overview, Timeline and ContactsNuala McGowan, Sr. Director of Research Finance and Compliance, FASChristyne Anderson, Manager, Training and Compliance, OSPRAS Friday - May 17th, 2019
2. 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 AuditContacts2
3. What is a UG Audit?3Office of Management and Budget (OMB) Uniform Guidance (UG) requires an annual external audit of non-profit organizations expending more than $750,000 in federal fundsRequirements 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.
4. 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 moneyFindings are reported to the federal government, become public record, and are distributed to all federal agencies through a clearinghouseEach 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)4
5. What is tested in the Uniform Guidance Audit?Internal controlsEquipment Cost transfersCost sharingProgram incomeProcurement and Suspension and DebarmentFinancial & non-financial reportingSubrecipient monitoringService centersF&A rate applicationActivities allowed / unallowed (direct costs, effort, etc)Note: Direct attribution (linkage between cost and purpose of the project) must be established and demonstrated through supporting documentation.
6. What’s involved? Direct Cost selection- Orientation in JuneDeep dive into one grant within your department3-15 individual transactions selected for reviewCompletion of the Compliance Control Questionnaire (CCQ)- a comprehensive document evaluating departmental procedures and internal controlsSupporting documentation and CCQ due in mid-JulyOther selections (Cost Transfers, Cost Sharing, Procurement, etc.)Typically selected in April Supporting documentation due in May Additional testing takes place between PwC and OSP (LOC, FFRs, etc.)
7. Contacts Alan Berkeley Manager, Research Compliance & Training, RAS – FASBerkeley@fas.Harvard.eduChristyne AndersonManager, Training and Compliance, OSPChristyne_Anderson@Harvard.edu
8. Questions / Comments