Accounting & Auditing Update What s Now, New and Next

Transcription

1 Accounting & Auditing Update What s Now, New and Next Presented by: Dan Barron, Partner Grant Thornton LLP dan.barron@us.gt.com Neely D. Duncan, Principal Lane Gorman Trubitt, PLLC nduncan@lgt cpa.com

2 Agenda Issued and Effective pronouncements Pronouncements on the Horizon AICPA A&A Guide NFP Entities Update AICPA Clarity Project OMB Circular A133 Update

3 Issued and Effective Pronouncements

4 Issued Effective Pronouncements Fair Value Measurement Classification of the sake proceeds of donated financial assets in statements of cash flows Refundable advance fees

5 FASB ASU No Fair Value Measurement Topic 820 Amendments to Achieve Common Fair Value Measurement and Disclosure Requirements in U.S. GAAP and IFRS Update represents the continued development of guidance related to fair value measurements in US GAAP and is the result of FASB and IASB working to align their guidance with respect to fair value measurements

6 Effective date FASB ASU No Fair Value Measurement Public entities: Interim and annual periods beginning after December 15, 2011 Nonpublic entities: Annual periods beginning after December 15, 2012

7 FASB ASU No Fair Value Measurement New disclosures required For fair value measurements categorized within Level 3 of the fair value hierarchy: The valuation processes used by the reporting entity A narrative description of the sensitivity of the fair value measurement to changes in the unobservable inputs and the interrelationships between those unobservable inputs, if any. (Not applicable to nonpublic entities.)

8 FASB ASU Classification of the Sale Proceeds of Donated Financial Assets in the Statement of Cash Flows Purpose to address the diversity in practice about how to classify cash receipts arising from the sale of certain donated financial assets, such as securities, in the statement of cash flows of not for profit entities (NFPs). Some NFPs classify the cash receipts arising from the sale of donated financial assets in the statement of cash flows as investing cash inflows Other entities classify the cash receipts from the sale of donated financial assets as either operating cash inflows or financing cash inflows, consistent with their treatment inflows arising from cash contributions

9 FASB ASU Classification of the Sale Proceeds of Donated Financial Assets in the Statement of Cash Flows Effective prospectively for fiscal years and interim periods within those years, beginning after June 15, 2013 Retrospective application to all prior periods presented upon the date of adoption is permitted. Early adoption from the beginning of the fiscal year of adoption is permitted. For fiscal years beginning before October 22, 2012, early adoption is permitted only if an NFP s financial statements for those fiscal years and interim periods within those years have not yet been made available for issuance.

10 FASB ASU Classification of the Sale Proceeds of Donated Financial Assets in the Statement of Cash Flows Require an NFP to classify cash receipts from the sale of donated financial assets consistently with cash donations received in the statement of cash flows IF those cash receipts were from the sale of donated financial assets that, upon receipt, were directed without any NFP imposed limitations for sale and were converted nearly immediately into cash Cash receipts from the sale of those financial assets should be classified as cash inflows from operating activities, unless the donor restricted the use of the contributed resources to long term purposes. In this case, those cash receipts should be classified as cash flows from financing activities. Otherwise, cash receipts from the sale of donated financial assets should be classified as cash flows from investing activities by the NFP.

11 No Health Care Entities (Topic 954): Continuing Care Retirement Communities Refundable Advance Fees Clarify that an entity should classify an advance fee as deferred revenue when a continuing care retirement community has a resident contract that provides for payment of the refundable advance fee upon reoccupancy by a subsequent resident, which is limited to the proceeds of the re occupancy. Refundable advance fees that are contingent upon re occupancy by a subsequent resident but are not limited to the proceeds of reoccupancy should be accounted for and reported as a liability. Affects continuing care retirement communities that have resident contracts that provide for a payment of a refundable advance fee upon re occupancy. For nonpublic entities, the amendments are effective for fiscal periods beginning after December 15, 2013.

12 Pronouncements on the Horizon

13 Pronouncements on the Horizon FASB Developments Leases Revenue recognition Proposed ASU personnel services received from an affiliate Proposed ASU for Financial Instruments Nonpublic entity definition Going concern project FASB NFP Advisory Council (NAC) AICPA Not for Profit Expert Panel Update

14 FASB Exposure Draft: Lease Accounting

15 Lease Accounting Exposure Draft: The Highlights Major proposed changes: FASB Exposure Draft Lease Accounting No operating leases Lessee obligations recognized on statement of financial position, with a corresponding right of use asset, for substantially all leases Interest expense on debt using the interest method, rather than straight line lease expense (Front loads expenses related to leases) Amortization of right to use asset (generally on a straight line basis) Lessor records receivable and either removes the leased asset (de recognition) or records deferred revenue (performance obligation), depending on facts Exposure draft issued 3Q 2012 Exposure draft expected to be issued 2Q 2013 Effective date TBD New model would apply to all leases within the scope of proposed guidance no grandfathering

16 FASB Exposure Draft Lease Accounting Key provisions of proposed guidance:

17 FASB Exposure Draft Lease Accounting Decisions made at September 2012 meeting: Allow non public entities to use a risk free rate as a practical expedient Exempt non public entities from disclosing a reconciliation of beginning and ending balance of the liability to make lease payments Re confirmed the right to use model

18 FASB Exposure Draft Lease Accounting Effect on NFP organizations: Potential significant effect on the statement of financial position, which could affect ratios used in debt covenants: Total assets and total liabilities increased by a similar amount Effect on the statement of activities: Expense for lease payments replaced by amortization of the right to use asset and front loaded interest expense Change in net assets would remain approximately the same

19 Revenue Recognition Exposure draft highlights: The proposed standards would affect any entity that either enters into a contract to sell goods or services that are an output of an entity's ordinary activities or enters into a contract to sell nonfinancial assets (for example. Real estate and equipment)

20 Revised draft Revenue Recognition

21 Revenue Recognition Potential Not for Profit implications of this project The proposal guidance leaves open some questions about how notfor profit organizations would apply the principles to their unique revenues: Grants and contracts (contribution vs. exchange) Contracts that provide ongoing services vs. product delivery (NFP cost reimbursements) NFP contracts for the projects that are not profitable Reconsidering the completed contract approach Considering practical expedient use

22 Revenue Recognition Timeline Q Q Q TBD Revised exposure draft Roundtables Final standard expected Effective date

23 Not-for-Profit Entities (958): Personnel Services Received from an Affiliate for Which the Affiliate Does Not Seek Compensation Would require a recipient not for profit entity to recognize in its standalone financial statements all personnel services received from an affiliate that directly benefit the recipient not for profit entity Services would be measured at the cost recognized by the affiliate for the personnel providing those services Applied on a prospective basis The effective date will be determined after the Task Force considers feedback on the proposed update

24 Not-for-Profit Financial Reporting Financial Statements Not for profit Financial Reporting: Financial Statements FASB ADDED TO THEIR AGENDA IN November 2011 Scope Not for profit entitites Objective Re examine existing standards for financial statement presentations, focusing on improving: Net asset classification requirements Information provided in financial statements and notes about liquidity, financial performance and cash flows

25 Proposed ASU Accounting for Financial Instruments Classification and measurement Hedging Impairment

26 Proposed ASU Accounting for Financial Instruments No general fair value option for financial assets For public entities, fair value of financial instruments measured at amortized cost would be parenthetically displayed on the face of the statement of financial position For all entities, amortized cost of liabilities measured at fair value would be parenthetically displayed on the face of the statement of financial position

27 Proposed ASU: Clarifying the Scope and Applicability of a Particular Disclosure to Nonpublic Entities Proposed changes: Nonpublic entities not required to disclose level of fair value hierarchy for items disclosed (not measured) at fair value in financial statements Effects nonpublic entities with assets of $100 million or more Proposed changes effective upon issuance of final ASU Final ASU issued 2/7/13

28 Definition of a Non-public Entity Project Re examine definition of a non public entity Determine which companies will be included in the Private Company Decision Making Framework project Determine nonpublic not for profit entity

29 Going Concern Project Project objective Entity's assessment of ability to continue as going concern Information on timing, nature and extent of disclosures Recent decisions Management s assessment done at each reporting period Disclosures required when more likely than not that the entity may be unable to meet its obligations in the ordinary course of business Management would assert substantial doubt is probable Timing Exposure draft to be issued late March/early April

30 FASB NFP Advisory Council (NAC) Created by FASB/FAF (FAF Financial Accounting Foundation FASB and GASB s parent organization) in October 2009 to serve as a standing resource for the FASB in obtaining input from the NFP sector on: Existing guidance Current and proposed technical agenda projects Longer term issues affecting those organizations 17 members plus 3 participating observers NFP financial officers, auditors, foundation and other donors, creditor, watchdog agency, charities regulator, attorney Also created NFP Resource Group to supplement work of NAC and staff

31 FASB NAC Marquis project: three subgroups worked to identify potential improvements in NFP financial reporting, discussed at the September 2011 NAC meeting Objectives: Enhanced clarity and consistency Improved understandability for users Better presentation of operations (business model and how revenues fund expenses), liquidity, resource availability and use

32 FASB NAC Subgroups Reporting financial performance Statements of Activities and Cash Flows and related notes: operating measures, net asset classes, functional and natural expenses, cash flow presentation, etc. Reporting liquidity/financial health Balance sheet and related notes: liquidity, other financial health measures Telling the story MD&A functional expense reporting/segment reporting, summary financials

33 FASB NFP Advisory Council (NAC) In October 2011, the NAC identified four areas for improving NFP financial reporting for agenda consideration by the FASB. Their obligation would be: 1. To improve the current net asset classification scheme, in conjunction with improving how liquidity is portrayed in an NFP s statement of financial position and related notes. 2. To improve the statements of activities and cash flows to more clearly communicate financial performance, by better disaggregation and classification of information within the statement of activities and better cohesiveness between the statements.

34 FASB NFP Advisory Council (NAC) 3. To develop a framework for an NFP s directors and management to provide commentary and analysis about the organization s financial health, operations, and liquidity 4. To review existing NFP specific disclosure requirements to streamline where possible and otherwise improve their relevance and understandability Additionally, the NAC identified some educational efforts that could be carried out by the FASB staff, the NAC, or other organizations (e.g. the AICPA).

35 FASB NFP Advisory Council (NAC) In November 2011, the FASB announced the addition of two agenda projects: Standard setting project: focus on the financial statements and related notes that are unique to not forprofit organizations Research projects: study other means of communication that not for profit organizations currently use in telling their financial story

36 FASB NFP Advisory Council February 28 and March 1 st Meeting Highlights Focus on the development of an intermediate operating measure for not for profit entities The NAC discussed defining, presenting, and disclosing an intermediate operating measure applicable to a broad range of NFPs. In a breakout session, NAC members explored the potential underlying bases for an intermediate operating measure. They also explored what might be included in or excluded from such a measure with respect to: Endowment management and Capital campaigns, bequests, and other planned giving programs. The NAC considered factors that might serve as bases for distinguishing between transactions and other events and circumstances that are and are not operating items, including: The NFP s core mission; that is, their ongoing, day to day major and/or central activities directed at achieving the NFP s purpose(s) The time period in which the day to day activities are carried out The time period for which the activities/resources are expected to benefit e.g., expenses for activities directed at generating support for future periods and/or resource in flows to support future periods The nature of the transaction or event, such as nonrecurring or unusual rather than on going day today activities.

37 FASB NFP Advisory Council February 28 and March 1 st Meeting Highlights Discussions on Accounting and Government Assistance and Financial Instruments Accounting for government assistance and financial instruments Some NAC members expressed support for the Board pro viding guidance that clarifies which types of government assistance should be accounted for as contributions rather than as exchange transactions. NAC members observed that current U.S. GAAP requires judgment, that some diversity exists in practice, and that guidance would be helpful for government assistance involving cost sharing, partnering, and certain other forms of collaborative agreements. Accounting for Financial Instruments, both Classification and Measurement, and Impairment (or Credit Loss). Members compared the current practices regarding reserving for uncollectible loans receivable and pledges receivable to the proposed Current Expected Credit Loss (CECL) model and suggested that the CECL model could result in a similar accounting outcome.

38 FASB NFP Advisory Council February 28 and March 1 st Meeting Highlights EITF issue 12 B, "Services Received from Personnel of an Affiliate for Which the Affiliate Does Not Seek Compensation". NAC members discussed EITF Issue 12 B. NAC members supported the recognition of all uncompensated services received from personnel of an affiliate that directly benefit the recipient NFP. Those services would include services received from personnel of a for profit affiliate or personnel hired by an individual who meets the definition of an affiliate. NAC members generally supported measuring the value of those services at cost; however, they also generally sup ported a fair value measurement alternative when the cost information is not readily available or reflective of fair value.

39 AICPA Not-for-Profit Expert Panel Update

40 AICPA Not-for-Profit Expert Panel Update Expert Panel Roles & Responsibilities Mission Identifying emerging industry issues financial reporting, audit and attest services, and regulatory matters and proposing solutions Liaising with regulators, standard setters, external industry groups, federal or state agencies, and other AICPA committees/expert panels Providing industry accounting and auditing guidance/information through various AICPA vehicles such as: Publications Webinars/webcasts Conferences

41 AICPA Not-for-Profit Expert Panel Update Expert Panel Roles & Responsibilities Members Responsibilities Accounting and Audit Guide conforming changes Accounting and Audit Guide overhaul Audit Risk Alert Task Force Issue Committees White Papers (Issue Papers) Technical Practice Aids Assisting AICPA Technical Hotline Participating in AICPA NFP Conference

42 AICPA Not-for-Profit Expert Panel Update AICPA NFO Audit Risk Alert Economic and industry developments Legislative and regulatory developments Payments in lieu of taxes Audit and attestation issues and developments Audit risks for NFPs Supplementary and other information Going concern risks Related party transactions Higher education issues Fair value measurements

43 AICPA Not-for-Profit Expert Panel Update AICPA NFP Audit Risk Alert Selected 2012 ARA Topics Audit and attestation issues and development continued Pension plan reporting Service organizations Accounting issues and developments Reporting related entities Credit quality and allowance for credit losses Recent pronouncements Auditing, ASU s and TPA s On the horizon Guide overhaul project Resource central

44 AICPA Not-for-Profit Expert Panel Update Current Projects and Issues: Gifts in Kind (GIK) Task Force Valuation and revenue recognition challenges related to non financial assets that are not subsequently sold Distributions to beneficiaries free of charge Issues identified Limited resources of fair value information Increasingly complex valuation standards Bargain purchase with or without donative intent Reporting GIK in agency transactions Lack of consistency and comparability in NFP s financials

45 AICPA Audit and Accounting Guide Notfor-Profit Entities update Chapter 8, Programmatic Investments Including loans, equity instruments, guarantees, and other interests Chapter 9, Property, Plant, and Equipment Use of PP&E owned by others, capitalized interest, other Chapter 10, Debt and Other Liabilities Expanded section on municipal bond financing, IRS considerations, 3 rd party credit enhancements, extinguishments and debt modifications, classification Tax liabilities, refunds due to and advances from third parties, split interest agreements, amounts held for other under a agency transaction, other

46 AICPA Audit and Accounting Guide Notfor-Profit Entities update Chapter 11, Net Assets and Reclassifications of Net Assets Expanded guidance on fiduciary responsibility to meet donor restrictions and expiration from restrictions Changing net asset classification reported in a prior year Chapter 12, Revenues and Receivables from Exchange Transactions Expanded guidance and disclosures Recognition, measurement, and display of revenue

47 AICPA Audit and Accounting Guide Notfor-Profit Entities update Chapter 13, Expenses, Gains, and Losses Expanded discussion about contributions made, reporting, contributed use of facilities Encourages reporting of major programs Chapter 14, Reports of Independent Auditors Reserved (chapter not utilized)

48 Issues Referred to the FASB in Updating the AICPA Audit and Accounting Guide, Not-for- Profit Entities Reporting the Contribution Portion of Charitable Gift Annuities Whether an NFP should report the contribution portion of a charitable gift annuity as unrestricted regardless of state requirements regarding required levels of annuity reserves and allowable types of related investments To be considered as part of the Not for Profit Financial Reporting: Financial Statements project, which is expected to review the current net asset classification scheme

49 Issues Referred to the FASB in Updating the AICPA Audit and Accounting Guide, Not-for- Profit Entities Reporting Investment Expenses How investment expenses should be presented and disclosed by a not for profit entity. (Whether they should be presented gross on the face of the statement of activities or disclosed if netted against investment return and whether they should be included and functionalized in the statement of functional expenses.) The FASB Chairman recommended that the presentation of investment expenses on the statement of functional expenses be addressed as part of the FASB s ongoing project that addresses corrections and improvements to the Codification. The disclosure of investment expenses should be considered as part of the Not for Profit Financial Reporting: Financial Statements project, as that project is expected to review existing NFP specific disclosure requirements.

50 Issues Referred to the FASB in Updating the AICPA Audit and Accounting Guide, Not-for- Profit Entities Recognition of Beneficial Interests in Trusts Held by Others When Information to Measure Is Unavailable When an NFP should recognize its beneficial interest in specified assets if it is the beneficiary of a split interest agreement held by a third party but determines it does not have the information available to measure the fair value of that beneficial interest. The FASB Chairman recommended that the FASB address this issue as part of the FASB s existing project that addresses corrections and improvements to the Codification

51 Issues Referred to the FASB in Updating the AICPA Audit and Accounting Guide, Not-for- Profit Entities Subsequent Measurement of Other Investments Whether the NFP subsector guidance for subsequent measurement of other investments in Section should be amended to conform the guidance for all NFPs. The FASB Chairman recommended that the Board consider this issue as part of its current projects on Accounting for Financial Instruments, Investment Companies, and Investment Property Entities, with a focus on conforming the impairment analysis.

52 Issues Referred to the FASB in Updating the AICPA Audit and Accounting Guide, Not-for- Profit Entities Classification of Gifts of Securities Immediately Sold in the Statement of Cash Flows How NFPs should classify the sale of donated securities that immediately upon receipt are directed for sale and conversion to cash in the statement of cash flows. This issue was added to the EITF agenda was discussed at the March 15, 2012 EITF meeting. Consensus reached, ratified by FASB, just exposed for public comment as proposed ASU. Comments were due July 16, 2012.

53 Issues Referred to the FASB in Updating the AICPA Audit and Accounting Guide, Not-for- Profit Entities Employee Services Contributed by an Affiliate Whether recipient NFPs should apply the contributed services guidance in paragraph for recognizing personnel costs incurred on its behalf by an affiliate. If not, what recognition and measurement guidance should the recipient NFP apply. At the June 21, 2012 EITF meeting, the Task Force reached a consensus for exposure that a recipient NFP should not apply the contributed services guidance in paragraph for recognizing personnel services received from an affiliate for which the affiliate does not seek compensation. Instead, the recipient NFP should recognize all personnel service received from an affiliate at the cost incurred by the affiliate. The Task Force clarified that the personnel services received from an affiliate must directly benefit the recipient NFP in the way that is similar to the way in which benefit is gotten from personnel directly engaged by the recipient NFP. The scope of the Issue would be limited to personnel services that are received from an affiliate, which is defined as a party that directly or indirectly through one or more intermediaries, controls, is controlled by or is under common control with the recipient NFP.

54 Issues Referred to the FASB in Updating the AICPA Audit and Accounting Guide, Not-for- Profit Entities Statement of Functional Expenses Whether the statement of functional expenses should be required for more types of donor supported not forprofit organizations. To be considered as part of the Not for Profit Financial Reporting: Financial Statements project.

55 AICPA Audit and Accounting Guide Notfor-Profit Entities update The AICPA Financial Reporting Executive Committee (FinREC), Not for Profit Entities Expert Panel, and the Not for Profit Guide Task Force are expected to release for comment a new comprehensive revision of the Audit and Accounting Guide Not for Profit Entities on August 15, 2012, expected final issuance in 2013.

56 AICPA Audit and Accounting Guide Notfor-Profit Entities update Chapter 1, Introduction Conformed scope with Healthcare Guide Other changes and scope issues Chapter 2, General Auditing Guidance Updated and to be conformed with Clarity project Other chapters focus on NFP specific guidance

57 AICPA Audit and Accounting Guide Notfor-Profit Entities update Chapter 3, Financial Statements, the Reporting Entity and General Financial Reporting Matters Expanded coverage of financial statements, related entities, mergers and acquisitions, collaborative arrangements, the use of fair value measurements, and financial statement disclosure not discussed elsewhere in this guide. Expanded identification of related parties including officers, board members, founders, certain substantial contributors, and their immediate family members: other entities subject to significant influence by officers, board members, founders, and substantial contributors; supporting orgs and affiliated entities; parties concentrations in revenues and receivables

58 AICPA Audit and Accounting Guide Notfor-Profit Entities update Chapter 4, Cash, Cash Equivalents, and Investments Expanded coverage interest in other entities due to unique NFP investment options, other assets, fair value, investment pools, endowment funds, disclosures For segregated asset, disclose type of asset(s) comprising the line item: purpose for which the asset is segregated: act causing asset to be segregated (i.e., specific asset is donor restricted, related net assets are donor restricted, or governing board designated) Recognition and measurement of investments

59 AICPA Audit and Accounting Guide Notfor-Profit Entities update Chapter 5, Contributions Received and Agency Transactions Increased focus on core recognition principles Additional guidance on fair value measurements New section on naming opportunities New sections on reporting and valuing noncash gifts including gifts in kind, fundraising and information materials, advertising, media time or space, below market loans, bargain purchases

60 AICPA Audit and Accounting Guide Notfor-Profit Entities update Chapter 6, Split Interest Agreements and Beneficial Interests in Trust New coverage of life interests in real estate Many technical enhancements and clarifications Chapter 7, Other Assets Clarified reporting sale of inventory gross vs. net Expanded discussion of prepaid and deferred costs including production of revenue producing assets

61 AICPA Audit and Accounting Guide Notfor-Profit Entities update Chapter 15, Tax and Regulatory Considerations Expanded discussion about laws and regulations, IRS exempt organization considerations, exempt issues, income tax positions, UPMIFA, securities regulation, Sarbanes Oxley and governance policies, executive compensation Chapter 16, Fund Accounting Enhancements and clarifications

62 AICPA Clarity Project

63 AICPA Clarity Project Started in 2004 Purpose is to make GAAS easier to read, understand, and apply Redrafted SASs and make them more principles based (Consistent with ISAs) Effective for all audits for periods ending on or after December 31, 2012

64 AICPA Clarity Project Format for clarified SASs Introduction Objective Definitions Requirements Application and Other Explanatory Material

65 AICPA Clarity Project Introduction Explains purpose and scope of the standard Objective Defines the contest in which the requirements of the standard are set Supports the overall objective and responsibilities of the auditor Definitions Explains specific meaning of terms in the standard

66 AICPA Clarity Project Requirements Notes the requirements of the clarified SASs Includes terms such as must, is required, and should Moves relevant requirements from previously different SASs into one Application and Other Explanatory Material Provide additional guidance

67 AICPA Clarity Project Key changes: Terms of Engagement (AU C section 210) Cannot accept an audit engagement where a managementimposed scope of limitation would likely result in a disclaimer of opinion on the financial statements Does not affect audit engagements required by law or regulation, such as employee benefit plan audits Initial Audits (AU C section 510) Review of a predecessor auditor s audit documentation cannot be the only procedure performed to obtain sufficient appropriate audit evidence regarding opening balances

68 AICPA Clarity Project Key changes, cont. Management representations (AU C section 580) New representation regarding the results of management s assessment of the risk that the financial statements may be materially misstated as a result of fraud Reporting (AU C section 700, 705 and 706) Change in report language (see example provided) Restricted Use Reports (AU C section 905) Required to be included under an appropriate header

69 OMB Circular A133 Update

70 2013 Compliance Supplement Changes Refer to Appendix V for changes to the Compliance Supplement Part 1 background, Purpose, and Applicability Updated for 2013 Part 2 Matrix of Compliance Requirements Updated to reflect addition/deletion of programs Eliminated the applicability of the following compliance requirements in a number of programs based on the lack of materiality of those requirements to the affected program: Equipment and Real Property Management Procurement and Suspension and Debarment Program Income

71 2013 Compliance Supplement Changes Part 3 Compliance Requirements Procurement and Suspension and Debarment Modified to clarify compliance requirements and testing for compliance Simplified acquisition threshold may be $150,000 for some programs Reporting Eliminated FFATA reporting requirements Part 4 Agency Program Requirements Modified to add/delete programs Removed certain ARRA related program

72 2013 Compliance Supplement Changes Part 5 Cluster of Programs Student Financial Assistance Updated to remove ARRA programs and to update various compliance requirements Other Updated clusters Other areas No major changes except to update based on addition/deletion of programs

73 Proposed OMB Uniform Guidance: Cost Principles, Audit, and Administrative Requirements for Federal Awards

74 Proposed Uniform Guidance Issued January 31, 2013 Proposed broad revisions to OMB Circular A 133 Follow up to 2012 OMB Advance Notice 90 day comment period (March 8 th to GAQC) Purpose Reform grant policies to increase the efficiency and effectiveness of federal programs Eliminate unnecessary and duplicative requirements Focus in on areas that emphasize achieving better outcomes in a lower cost

75 Proposed Uniform Guidance Key Changes Single audit threshold for audit proposed to increase to $750,000 Change to the major program determination process Type A/B program determination revised to $500,000 High risk Type A program criteria Type B testing requirement Criteria for low risk auditee status change

76 Proposed Uniform Guidance Key Changes, cont. Percentage of coverage changes 50% (normal) and 25% (low) to 40% (normal) and 20% (low) Reduction in types of compliance requirements to be tested From 14 to 6 Allowability (could include period of availability and matching) Cash management Eligibility Reporting Subrecipient Monitoring Special tests and provisions

77 Proposed Uniform Guidance Key Changes, cont. Findings reporting change Questioned costs threshold increased from $10,000 to $25,000 Streamlining OMB Circulars

78 Proposed Uniform Guidance For more information, see GAQC Alert at: AuditQuality/NewsAndPublications/GAQCALERT /2013/Pages/GAQCAlertNo211.aspx

79 Questions & Discussions