The Office of Management and Budget (OMB) released the Uniform Administrative Requirements (UAR) which is effective for any federal grants awarded after December 26, 2014. The UAR condenses many Circulars, including A-21, A-122, and A-133, into one set of guidance. With these requirements comes some new focus and verbiage in regards to internal controls. There have been a lot of conversations and discussions surrounding the use of “must” versus “should” in the UAR. The OMB has further released guidance defining “must” as absolutely required, while “should” refers to best practices.
All nonprofit organizations have always been required to have a sound internal control environment. The UAR says that any non-federal organizations received federal awards must maintain strong internal controls in place in regards to those federal awards to ensure that they are being administered properly. Theguidance goes on further to state that these organizations should be following either the COSO Framework or the Green Book, issued by the U.S. Government Accountability Office.
Many organizations receiving these federal awards will find that they have these required controls over the administration of the federal awards, but they may not be documented. The audit over the federal awards that fall after December 26, 2014, will be much more focused on the documentation of these internal controls.
We encourage you to work closely with your auditors to determine your next step to verify that you are in compliance with the new UAR in regards to internal controls. For additional information regarding the UAR and the requirements of your organization for 2015 and beyond, please watch the following 7 minute video:
If you have any questions regarding the Uniform Administrative Requirements issued by the Office of Management and Budget, please do not hesitate to contact Gary Dubas at GDubas@macpas.com, or Janice Snyder at JSnyder@macpas.com.