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OMB Uniform Guidance 2014 Implementation at the University of Washington

OMB Uniform Guidance 2014 Implementation at the University of Washington. Northwest Chapter of Internal Auditors August 5 th , 2014 Ted Mordhorst Asst. Dir. For Post Award Financial Compliance Research Accounting and Analysis University of Washington. OMB Uniform Guidance 2014.

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OMB Uniform Guidance 2014 Implementation at the University of Washington

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  1. OMB Uniform Guidance 2014Implementation at the University of Washington Northwest Chapter of Internal Auditors August 5th , 2014 Ted Mordhorst Asst. Dir. For Post Award Financial Compliance Research Accounting and Analysis University of Washington

  2. OMB Uniform Guidance 2014 • Final Guidance document published in the Federal Register Dec 26, 2013. • Codified in 2 CFR 200 • Replaces 8 previous OMB Circulars: • Circular A-110 Circular A-21 • Circular A-102 Circular A-87 • Circular A-89 Circular A-102 • Circular A-133 Circular A-50

  3. OMB Uniform Guidance 2014 • Applicable to Direct Federal Grants, Cooperative Agreements and Cost-reimbursable contracts. • Each federal awarding agency must implement • Effective for new $ received on or after Dec. 26, 2014 • Audit effective for the entities first full fiscal year after 12/26/14. • Example: Entities fiscal year ends June 30th • New audit requirements apply to fiscal year that ends June 30, 2016

  4. University of Washington Approach • A Core Team has been assembled • Sponsored by Mary Lidstrom, Vice Provost for Research and Susan Camber, Associate Vice President, Financial Management • The team has representatives from: • OR, OSP, GCA, MAA, School of Medicine, College of Arts and Sciences, Procurement Services, and Internal Audit, The AG office • Additional sub-teams have been formed to review some of the more complex areas. University ofWashington Presenter’s Office

  5. Uniform Guidance Working Group • The working groups compared the new regulation to the existing regulations in A-110, A-21 and A-133 • Identify changes • Map changes to university policy and procedures • Identifying possible changes to IT systems both central and in units • Propose changes to policy, procedures necessary to maintain compliance University ofWashington Presenter’s Office

  6. Uniform Guidance Working Group • Develop internal Communication plan. • Develop protocol for making changes to policies and procedures. • Develop training for campus personnel. • Modify existing training material for faculty and staff. University ofWashington Presenter’s Office

  7. Uniform Guidance Working Group • Timeline • APRIL 15 DISCOVERY (initial discovery of what changed complete) • MAY 15 DISCOVERY (impact to UW systems complete) • JUNE 01 DISCOVERY (map to UW policy & procedure complete) • JUNE 26 FEDERAL PLANS RELEASED (Federal agencies release their respective implementation plans)(Has not happened.) • SEPT 30 DRAFT OF CHANGES TO UW POLICY (comprehensively address & publish all changes to UW policy) • DEC 01 UW READY TO IMPLEMENT CHANGES (changes to UW policy & procedure approved & published) • DEC 26 FEDERAL IMPLEMENTATION BEGINS University ofWashington Presenter’s Office

  8. Uniform Guidance Working Group • We established a web page for the team at: • http://www.washington.edu/research/topics/uniform-grant-guidance/ • Contains links to the Final Uniform Guidance document • Links to other documents and presentations • Continues to be updated as more information becomes available.

  9. Uniform Guidance Working Group • There are Open Issues… • Agency deviations – how will these be policed? • Conflict of Interest – agency plans are key • Research Terms and Conditions – (FDP) a lot to do in little time • Internal Controls – audit repercussions, if any? • Procurement – could be most significant new burden • Subrecipient Monitoring – could be second most significant • Closeouts – not a major change in the Uniform Guidance, but the pressure for timely closeouts has raised profile

  10. Uniform Guidance Working Group • Other Issues… • The UW is working with the Council on Governmental Relations to obtain clarification from OMB on a number of areas: • Conflict of Interest – Institutional or individual • Program Income – Treatment of Royalties or other IP Income • Equipment – “Conditional Title” • Procurement – Small purchase threshold – required competition

  11. Uniform Guidance Working Group • Challenges: • Conflicting Priorities for team members • Differing interpretations • OMB/COFAR slow response to questions • Pending clarification issues • Agency implementation plans not published

  12. Uniform Guidance Working Group • A lot of questions remain but some of the more visible changes will have little impact on our policy and procedure. • Effort Certification – No change planned • Direct Charging of Administrative & Clerical Salaries – Little or no change planned • Electronic Records – Already moving to a paperless environment • Subrecipient Monitoring – Just revamped our processes

  13. Uniform Guidance ImplementationUniversity of Washington Questions?

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