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Auditing Head Start Under the New
Program Performance Standards and
Revised 2017 Compliance Supplement
A Governmental Audit Quality Center Web Event
June 15 2017
Governmental Audit Quality Center
Administrative Notes
Please ensure your pop-up blocker is disabled
Note the interactive toolbar at the bottom of your screen
Download slides and materials by clicking this icon
Ask questions by entering your question in the ldquoQampArdquo box
Please click the ldquoHelprdquo andor ldquoContact Usrdquo at the bottom of
your screen
Call AICPA Member Service at 8887777077
2
Governmental Audit Quality Center
Trouble Shooting
Troubleshooting Tips
No Audio
bull Ensure that your computer speakers are turned on that the
volume is appropriately set
bull Check to ensure that audio streaming is enabled on your
computer
If the presentation slides stop advancing during the
presentation
bull Close out of the presentation and re-launch the webcast
If you are still having audio or other technical
difficultybull Check with your IT personnel at your firm or state audit organization (SAO) to ensure that
this event is not being blocked by a firewall
bull Call the AICPA Service Center at 8887777077
3
Governmental Audit Quality Center
Continuing Professional Education
You must answer at least 75 of the random
attendance checks to earn CPE credit
Please respond to the attendance checks during the
live presentation
You are not eligible to earn CPE by watching the
archive of this event
At the end of todayrsquos presentation we will provide
steps for obtaining your CPE certificate
4
Governmental Audit Quality Center
Presenters
Stephen W Blann CPA CGFM CGMA
Rehmann
Terry Ramsey CPA
Technical Advisor on Single Audit
Administration for Children and Families
Belinda Rinker JD
Senior Policy Analyst
Office of Head Start
Moderator Mary Foelster CPA
AICPA
5
Governmental Audit Quality Center
What We Will Cover
Overview of the Head Start Program
Auditing the Head Start Program
bull New program compliance requirements and auditor
guidance in 2017 Office of Management and Budget
(OMB) Compliance Supplement (Supplement)
bull Program risks
bull Auditor best practices and tips
Resources
6
EMPHASIS POINT Access the Final Draft 2017 Supplement section for CFDA No 93600 under the Handouts tab and refer to during this presentation
Governmental Audit Quality Center
2017 Compliance Supplement - Status
OMB is delayed in issuing the final Supplement
A final draft of the 2017 Supplement has been
released to the GAQC for auditors to use for
planning purposes only
bull CFDA 93600 is available at the link above (look under HHS tab)
bull No major changes expected in final Supplement for Head Start
Final issuance of Supplement not expected until
GAQC will announce issuance of final Supplement
7
EMPHASIS POINT This presentation based on the final draft of the CFDA 93600 program section that was entered into OMB clearance Upon its issuance auditors should review the final 2017 Supplement to ensure no significant changes made during the clearance process
Governmental Audit Quality Center
Overview of the Head
Start Program
8
Head Start Basics
9
Purpose Of Head Start
bull To promote the school readiness of low income children by enhancing their cognitive social and emotional development ndash
ndash in a learning environment that supports childrens growth in language literacy mathematics science social and emotional functioning creative arts physical skills and approaches to learning and
ndash through the provision of health educational nutritional social and other services that are determined based on family needs assessments to be necessary
10
50+ Years of Head Start
11
1965 - 2015
Click the star to seea Head Start timeline
Head Start Program Offerings
Head Start (HS)ndash Serves children ages 3-5 years old and their families
Early Head Start (EHS)ndash Serves pregnant mothers and children ages birth to 3 years
old and their families
Early Head Start ndash Child Care Partnerships (EHS ndash CCP) ndash Early Head Start delivered in partnership with providers
receiving child care subsidies
HS and EHS may be delivered in either center-based or home-based models EHS ndash CCP is center-based only but includes family child care homes
12
Head Start Enrollment
13
In 2015 Head Start served nearly one millionchildren ages 0 ndash 5 and pregnant women
Location of Grantees
14
Grantees and Grant Awards
bull Number of Granteesndash 1600 Head Start and Early Head Start grantees
nationwide including territories
bull Number of Grants ndash 2000 Head Start and Early Head Start grant awards
bull Award Amounts ndash Head Start awards range from
$150000 - $130000000
ndash Early Head Start awards range from $80000 -$18000000
15
Organization Types
16
Regional Offices
17
bull The Head Start Act 42 USC 9801 et seqespecially Sec 642
bull 45 CFR Part 75 Uniform Administrative Requirements Cost Principles and Audit Requirements for HHS awards (the Uniform Guidance)
bull Head Start Program Performance Standards (HSPPS) 45 CFR Part 1303
ndash Subpart B Financial Requirementsndash Subpart E Facilitiesndash Definitions 45 CFR 13052ndash Effective November 7 2016
Financial Laws and Regulations
ACF Administration for Children and
Families
US DEPARTMENT
OF HEALTH AND HUMAN SERVICES
1 Log No ACF-IM-HS-14-07 2 Issuance Date 12172014
3 Originating Office Office of Head Start
4 Key Words Grants Management Grants Administration
Administrative Requirements Cost Principles Audit
Requirements
INFORMATION MEMORANDUM
TO All Head Start and Early Head Start Grantees and Delegate Agencies
SUBJECT New Uniform Administrative Requirements Cost Principles and Audit Requirements for
Federal Awards INFORMATION The Office of Management and Budget (OMB) has issued new uniform administrative
requirements cost principles and audit requirements effective Dec 26 2014 which are
applicable to all Head Start and Early Head Start agencies and sub-recipients including
delegate agencies The Office of Head Start (OHS) is providing general guidance to assist
grantees in planning for implementation of the new requirements
Non-Federal Entities
The new uniform administrative requirements cost principles and audit requirements
(collectively the new fiscal regulations) replace use of the terms grantee grant funded
organization delegate agency and sub-recipient with uniform use of the inclusive term
non-federal entity (NFE) This Memorandum will use the terms non-federal entity receiving
Head Start funds or NFE to refer to all covered entities
Effective Date The new fiscal regulations are effective for awards (or award increments) made on or after
Dec 26 2014 Adoption of the regulations prior to Dec 26 2014 is not allowed After Dec 26
2014 NFEs may establish a single program-level effective date for application of the
regulations to existing Head Start awards for ease of implementation and administration The
program-level effective date must be reflected in the granteersquos fiscal policies and within
effective dates for application of the new regulations to affected awards
Audit Threshold The regulation has increased the single audit threshold from $500000 to $750000 NFEs
receiving at least $750000 in federal funding from all sources (including Head Start Early
Head Start and Early Head Start-Child Care Partnership awards) are subject to the single
audit requirement for fiscal years beginning on or after Dec 26 2014
Supersession and Impact on the Head Start Act and Performance Standards
The new regulations when effective supersede all current audit circulars and cost principle
guidance currently codified under Title 2 Code of Federal Regulations (2 CFR 215 2 CFR 220
2 CFR 225 and 2 CFR 230) Grants management regulations at 45 CFR Part 74 and 45 CFR
Part 92 are also superseded NFEs should implement the new regulations as written but
anticipate codifying regulations from the Department of Health and Human Services (HHS) to
be found at a new 45 CFR Part 75 An issuance date is not known at this time Fiscal
18
Audits in Head Start
bull Sec 647 of the Head Start Act (HSA) requires that all entities receiving Head Start fundsndash keep records necessary to facilitate an effective audit
ndash submit a copy of the audit within 30 days of completion
bull Sec 641 of the HSA includes annual audits (going concern) within the criteria for competition under the Designation Renewal System implemented at 45 CFR Part 1303 ndashSubpart B
19
Audits in Head Start
bull Sec 642 of the HSA addresses responsibilities of the grantee governing body (board) and policy council includingndash Governing body has legal and fiscal responsibility
for the agency and shallbull be responsible for selection of the auditor who shall
report to the governing body
bull review and approve policies relating to the financial audit
bull monitor the agencyrsquos action to correct any audit findings
20
Audits in Head Start
bull Both the governing body and the policy council must be provided with a copy of the annual financial audit
bull Each agency must make available to the public a report published at least once in each fiscal year that discloses the results of the annual financial audit
21
Streamlined requirements Reduced the number of regulations Made them easier to understand Grouped related requirements Eliminated redundancy Reduced administrative burden Provided greater flexibility to
determine how best to achieve goals
22
Performance Standard Outcomes
Importance of Definitional Changes
bull An important difference in the new HSPPS is that all definitions are collected at 45 CFR sect13052
ndash Some definitions are the same some are brand new and some longstanding terms have new definitions
23
Example - New Definitions
bull Federal interest is a property right which secures the right of the federal awarding agency to recover the current fair market value of its percentage of participation in the cost of the facility in the event the facility is no longer used for Head Start purposes by the grantee or upon the disposition of the property When a grantee uses Head Start funds to purchase construct or renovate a facility or make mortgage payments it creates a federal interest The federal interest includes any portion of the cost of purchase construction or renovation contributed by or for the entity or a related donor organization to satisfy a matching requirement
bull Repair means maintenance that is necessary to keep a Head Start facility in working condition Repairs do not add significant value to the property or extend its useful life
24
Example - Changed Definitions
bull Old Major renovation means a structural change to the foundation roof floor or exterior or load-bearing walls of a facility or extension of an existing facility to increase its floor area Major renovation also means extensive alteration of an existing facility such as to significantly change its function and purpose even if such renovation does not include any structural change to the facility Major renovation also includes a renovation of any kind which has a cost exceeding the lesser of $200000 adjusted annually to reflect the percentage change in the Consumer Price Index for All Urban Consumers (issued by the Bureau of Labor Statistics) beginning one year after June 22003 or 25 percent of the total annual direct costs approved for the grantee by ACF for the budget period in which the application is made
bull New Major renovation means any individual or collecti[ve] renovation that has a cost equal to or exceeding $250000 It excludes minor renovations and repairs except when they are included in a purchase application
25
Early Childhood Learning and Knowledge Center (ECLKC)
OHS Early Childhood Learning and Knowledge Center
Click thestar to access ECLKC byhyperlink
Or go tohttpseclkcohsacfhhsgovhslc
26
Governmental Audit Quality Center
Auditing the Head Start
Program
29
Governmental Audit Quality Center
Event Materials Highlight Requirements
Unique to Head Start
The following basic single audit knowledge
is assumed
bull Auditing standards (GAAS and Government Auditing
Standards)
bull Uniform Administrative Requirements Cost
Principles and Audit Requirements for Federal
Awards at 2 CFR 200 (UG or Uniform Guidance)
bull OMB Compliance Supplement
bull Federal Audit Clearinghouse reporting
30
Governmental Audit Quality Center
Information Provided is not a Substitute for
Compliance Supplement or UG
Session focuses on program changes and
areas identified as common risks for Head
Start programs
bull An individual entityrsquos risk may be different
Auditor must still comply with the UG and
consider all requirements identified in the
Compliance Supplement
31
Governmental Audit Quality Center
2017 Updated Compliance Supplement
for Head Start An Overview
Program Objectives and Program Procedures
Matrix
Compliance Requirements - Updates
bull A Activities Allowed or Unallowed
bull E Eligibility for Subrecipients
bull F Equipment amp Real Property Management (Head Start
property requirements move to Special Tests and Provisions
bull J Program Income ndash Deleted
bull L3 Special Reporting (new report)
bull N Special Tests and Provisions (Property amp program
governance)
IV Other Information ndash Areas of risk
32
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
Administrative Notes
Please ensure your pop-up blocker is disabled
Note the interactive toolbar at the bottom of your screen
Download slides and materials by clicking this icon
Ask questions by entering your question in the ldquoQampArdquo box
Please click the ldquoHelprdquo andor ldquoContact Usrdquo at the bottom of
your screen
Call AICPA Member Service at 8887777077
2
Governmental Audit Quality Center
Trouble Shooting
Troubleshooting Tips
No Audio
bull Ensure that your computer speakers are turned on that the
volume is appropriately set
bull Check to ensure that audio streaming is enabled on your
computer
If the presentation slides stop advancing during the
presentation
bull Close out of the presentation and re-launch the webcast
If you are still having audio or other technical
difficultybull Check with your IT personnel at your firm or state audit organization (SAO) to ensure that
this event is not being blocked by a firewall
bull Call the AICPA Service Center at 8887777077
3
Governmental Audit Quality Center
Continuing Professional Education
You must answer at least 75 of the random
attendance checks to earn CPE credit
Please respond to the attendance checks during the
live presentation
You are not eligible to earn CPE by watching the
archive of this event
At the end of todayrsquos presentation we will provide
steps for obtaining your CPE certificate
4
Governmental Audit Quality Center
Presenters
Stephen W Blann CPA CGFM CGMA
Rehmann
Terry Ramsey CPA
Technical Advisor on Single Audit
Administration for Children and Families
Belinda Rinker JD
Senior Policy Analyst
Office of Head Start
Moderator Mary Foelster CPA
AICPA
5
Governmental Audit Quality Center
What We Will Cover
Overview of the Head Start Program
Auditing the Head Start Program
bull New program compliance requirements and auditor
guidance in 2017 Office of Management and Budget
(OMB) Compliance Supplement (Supplement)
bull Program risks
bull Auditor best practices and tips
Resources
6
EMPHASIS POINT Access the Final Draft 2017 Supplement section for CFDA No 93600 under the Handouts tab and refer to during this presentation
Governmental Audit Quality Center
2017 Compliance Supplement - Status
OMB is delayed in issuing the final Supplement
A final draft of the 2017 Supplement has been
released to the GAQC for auditors to use for
planning purposes only
bull CFDA 93600 is available at the link above (look under HHS tab)
bull No major changes expected in final Supplement for Head Start
Final issuance of Supplement not expected until
GAQC will announce issuance of final Supplement
7
EMPHASIS POINT This presentation based on the final draft of the CFDA 93600 program section that was entered into OMB clearance Upon its issuance auditors should review the final 2017 Supplement to ensure no significant changes made during the clearance process
Governmental Audit Quality Center
Overview of the Head
Start Program
8
Head Start Basics
9
Purpose Of Head Start
bull To promote the school readiness of low income children by enhancing their cognitive social and emotional development ndash
ndash in a learning environment that supports childrens growth in language literacy mathematics science social and emotional functioning creative arts physical skills and approaches to learning and
ndash through the provision of health educational nutritional social and other services that are determined based on family needs assessments to be necessary
10
50+ Years of Head Start
11
1965 - 2015
Click the star to seea Head Start timeline
Head Start Program Offerings
Head Start (HS)ndash Serves children ages 3-5 years old and their families
Early Head Start (EHS)ndash Serves pregnant mothers and children ages birth to 3 years
old and their families
Early Head Start ndash Child Care Partnerships (EHS ndash CCP) ndash Early Head Start delivered in partnership with providers
receiving child care subsidies
HS and EHS may be delivered in either center-based or home-based models EHS ndash CCP is center-based only but includes family child care homes
12
Head Start Enrollment
13
In 2015 Head Start served nearly one millionchildren ages 0 ndash 5 and pregnant women
Location of Grantees
14
Grantees and Grant Awards
bull Number of Granteesndash 1600 Head Start and Early Head Start grantees
nationwide including territories
bull Number of Grants ndash 2000 Head Start and Early Head Start grant awards
bull Award Amounts ndash Head Start awards range from
$150000 - $130000000
ndash Early Head Start awards range from $80000 -$18000000
15
Organization Types
16
Regional Offices
17
bull The Head Start Act 42 USC 9801 et seqespecially Sec 642
bull 45 CFR Part 75 Uniform Administrative Requirements Cost Principles and Audit Requirements for HHS awards (the Uniform Guidance)
bull Head Start Program Performance Standards (HSPPS) 45 CFR Part 1303
ndash Subpart B Financial Requirementsndash Subpart E Facilitiesndash Definitions 45 CFR 13052ndash Effective November 7 2016
Financial Laws and Regulations
ACF Administration for Children and
Families
US DEPARTMENT
OF HEALTH AND HUMAN SERVICES
1 Log No ACF-IM-HS-14-07 2 Issuance Date 12172014
3 Originating Office Office of Head Start
4 Key Words Grants Management Grants Administration
Administrative Requirements Cost Principles Audit
Requirements
INFORMATION MEMORANDUM
TO All Head Start and Early Head Start Grantees and Delegate Agencies
SUBJECT New Uniform Administrative Requirements Cost Principles and Audit Requirements for
Federal Awards INFORMATION The Office of Management and Budget (OMB) has issued new uniform administrative
requirements cost principles and audit requirements effective Dec 26 2014 which are
applicable to all Head Start and Early Head Start agencies and sub-recipients including
delegate agencies The Office of Head Start (OHS) is providing general guidance to assist
grantees in planning for implementation of the new requirements
Non-Federal Entities
The new uniform administrative requirements cost principles and audit requirements
(collectively the new fiscal regulations) replace use of the terms grantee grant funded
organization delegate agency and sub-recipient with uniform use of the inclusive term
non-federal entity (NFE) This Memorandum will use the terms non-federal entity receiving
Head Start funds or NFE to refer to all covered entities
Effective Date The new fiscal regulations are effective for awards (or award increments) made on or after
Dec 26 2014 Adoption of the regulations prior to Dec 26 2014 is not allowed After Dec 26
2014 NFEs may establish a single program-level effective date for application of the
regulations to existing Head Start awards for ease of implementation and administration The
program-level effective date must be reflected in the granteersquos fiscal policies and within
effective dates for application of the new regulations to affected awards
Audit Threshold The regulation has increased the single audit threshold from $500000 to $750000 NFEs
receiving at least $750000 in federal funding from all sources (including Head Start Early
Head Start and Early Head Start-Child Care Partnership awards) are subject to the single
audit requirement for fiscal years beginning on or after Dec 26 2014
Supersession and Impact on the Head Start Act and Performance Standards
The new regulations when effective supersede all current audit circulars and cost principle
guidance currently codified under Title 2 Code of Federal Regulations (2 CFR 215 2 CFR 220
2 CFR 225 and 2 CFR 230) Grants management regulations at 45 CFR Part 74 and 45 CFR
Part 92 are also superseded NFEs should implement the new regulations as written but
anticipate codifying regulations from the Department of Health and Human Services (HHS) to
be found at a new 45 CFR Part 75 An issuance date is not known at this time Fiscal
18
Audits in Head Start
bull Sec 647 of the Head Start Act (HSA) requires that all entities receiving Head Start fundsndash keep records necessary to facilitate an effective audit
ndash submit a copy of the audit within 30 days of completion
bull Sec 641 of the HSA includes annual audits (going concern) within the criteria for competition under the Designation Renewal System implemented at 45 CFR Part 1303 ndashSubpart B
19
Audits in Head Start
bull Sec 642 of the HSA addresses responsibilities of the grantee governing body (board) and policy council includingndash Governing body has legal and fiscal responsibility
for the agency and shallbull be responsible for selection of the auditor who shall
report to the governing body
bull review and approve policies relating to the financial audit
bull monitor the agencyrsquos action to correct any audit findings
20
Audits in Head Start
bull Both the governing body and the policy council must be provided with a copy of the annual financial audit
bull Each agency must make available to the public a report published at least once in each fiscal year that discloses the results of the annual financial audit
21
Streamlined requirements Reduced the number of regulations Made them easier to understand Grouped related requirements Eliminated redundancy Reduced administrative burden Provided greater flexibility to
determine how best to achieve goals
22
Performance Standard Outcomes
Importance of Definitional Changes
bull An important difference in the new HSPPS is that all definitions are collected at 45 CFR sect13052
ndash Some definitions are the same some are brand new and some longstanding terms have new definitions
23
Example - New Definitions
bull Federal interest is a property right which secures the right of the federal awarding agency to recover the current fair market value of its percentage of participation in the cost of the facility in the event the facility is no longer used for Head Start purposes by the grantee or upon the disposition of the property When a grantee uses Head Start funds to purchase construct or renovate a facility or make mortgage payments it creates a federal interest The federal interest includes any portion of the cost of purchase construction or renovation contributed by or for the entity or a related donor organization to satisfy a matching requirement
bull Repair means maintenance that is necessary to keep a Head Start facility in working condition Repairs do not add significant value to the property or extend its useful life
24
Example - Changed Definitions
bull Old Major renovation means a structural change to the foundation roof floor or exterior or load-bearing walls of a facility or extension of an existing facility to increase its floor area Major renovation also means extensive alteration of an existing facility such as to significantly change its function and purpose even if such renovation does not include any structural change to the facility Major renovation also includes a renovation of any kind which has a cost exceeding the lesser of $200000 adjusted annually to reflect the percentage change in the Consumer Price Index for All Urban Consumers (issued by the Bureau of Labor Statistics) beginning one year after June 22003 or 25 percent of the total annual direct costs approved for the grantee by ACF for the budget period in which the application is made
bull New Major renovation means any individual or collecti[ve] renovation that has a cost equal to or exceeding $250000 It excludes minor renovations and repairs except when they are included in a purchase application
25
Early Childhood Learning and Knowledge Center (ECLKC)
OHS Early Childhood Learning and Knowledge Center
Click thestar to access ECLKC byhyperlink
Or go tohttpseclkcohsacfhhsgovhslc
26
Governmental Audit Quality Center
Auditing the Head Start
Program
29
Governmental Audit Quality Center
Event Materials Highlight Requirements
Unique to Head Start
The following basic single audit knowledge
is assumed
bull Auditing standards (GAAS and Government Auditing
Standards)
bull Uniform Administrative Requirements Cost
Principles and Audit Requirements for Federal
Awards at 2 CFR 200 (UG or Uniform Guidance)
bull OMB Compliance Supplement
bull Federal Audit Clearinghouse reporting
30
Governmental Audit Quality Center
Information Provided is not a Substitute for
Compliance Supplement or UG
Session focuses on program changes and
areas identified as common risks for Head
Start programs
bull An individual entityrsquos risk may be different
Auditor must still comply with the UG and
consider all requirements identified in the
Compliance Supplement
31
Governmental Audit Quality Center
2017 Updated Compliance Supplement
for Head Start An Overview
Program Objectives and Program Procedures
Matrix
Compliance Requirements - Updates
bull A Activities Allowed or Unallowed
bull E Eligibility for Subrecipients
bull F Equipment amp Real Property Management (Head Start
property requirements move to Special Tests and Provisions
bull J Program Income ndash Deleted
bull L3 Special Reporting (new report)
bull N Special Tests and Provisions (Property amp program
governance)
IV Other Information ndash Areas of risk
32
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
Trouble Shooting
Troubleshooting Tips
No Audio
bull Ensure that your computer speakers are turned on that the
volume is appropriately set
bull Check to ensure that audio streaming is enabled on your
computer
If the presentation slides stop advancing during the
presentation
bull Close out of the presentation and re-launch the webcast
If you are still having audio or other technical
difficultybull Check with your IT personnel at your firm or state audit organization (SAO) to ensure that
this event is not being blocked by a firewall
bull Call the AICPA Service Center at 8887777077
3
Governmental Audit Quality Center
Continuing Professional Education
You must answer at least 75 of the random
attendance checks to earn CPE credit
Please respond to the attendance checks during the
live presentation
You are not eligible to earn CPE by watching the
archive of this event
At the end of todayrsquos presentation we will provide
steps for obtaining your CPE certificate
4
Governmental Audit Quality Center
Presenters
Stephen W Blann CPA CGFM CGMA
Rehmann
Terry Ramsey CPA
Technical Advisor on Single Audit
Administration for Children and Families
Belinda Rinker JD
Senior Policy Analyst
Office of Head Start
Moderator Mary Foelster CPA
AICPA
5
Governmental Audit Quality Center
What We Will Cover
Overview of the Head Start Program
Auditing the Head Start Program
bull New program compliance requirements and auditor
guidance in 2017 Office of Management and Budget
(OMB) Compliance Supplement (Supplement)
bull Program risks
bull Auditor best practices and tips
Resources
6
EMPHASIS POINT Access the Final Draft 2017 Supplement section for CFDA No 93600 under the Handouts tab and refer to during this presentation
Governmental Audit Quality Center
2017 Compliance Supplement - Status
OMB is delayed in issuing the final Supplement
A final draft of the 2017 Supplement has been
released to the GAQC for auditors to use for
planning purposes only
bull CFDA 93600 is available at the link above (look under HHS tab)
bull No major changes expected in final Supplement for Head Start
Final issuance of Supplement not expected until
GAQC will announce issuance of final Supplement
7
EMPHASIS POINT This presentation based on the final draft of the CFDA 93600 program section that was entered into OMB clearance Upon its issuance auditors should review the final 2017 Supplement to ensure no significant changes made during the clearance process
Governmental Audit Quality Center
Overview of the Head
Start Program
8
Head Start Basics
9
Purpose Of Head Start
bull To promote the school readiness of low income children by enhancing their cognitive social and emotional development ndash
ndash in a learning environment that supports childrens growth in language literacy mathematics science social and emotional functioning creative arts physical skills and approaches to learning and
ndash through the provision of health educational nutritional social and other services that are determined based on family needs assessments to be necessary
10
50+ Years of Head Start
11
1965 - 2015
Click the star to seea Head Start timeline
Head Start Program Offerings
Head Start (HS)ndash Serves children ages 3-5 years old and their families
Early Head Start (EHS)ndash Serves pregnant mothers and children ages birth to 3 years
old and their families
Early Head Start ndash Child Care Partnerships (EHS ndash CCP) ndash Early Head Start delivered in partnership with providers
receiving child care subsidies
HS and EHS may be delivered in either center-based or home-based models EHS ndash CCP is center-based only but includes family child care homes
12
Head Start Enrollment
13
In 2015 Head Start served nearly one millionchildren ages 0 ndash 5 and pregnant women
Location of Grantees
14
Grantees and Grant Awards
bull Number of Granteesndash 1600 Head Start and Early Head Start grantees
nationwide including territories
bull Number of Grants ndash 2000 Head Start and Early Head Start grant awards
bull Award Amounts ndash Head Start awards range from
$150000 - $130000000
ndash Early Head Start awards range from $80000 -$18000000
15
Organization Types
16
Regional Offices
17
bull The Head Start Act 42 USC 9801 et seqespecially Sec 642
bull 45 CFR Part 75 Uniform Administrative Requirements Cost Principles and Audit Requirements for HHS awards (the Uniform Guidance)
bull Head Start Program Performance Standards (HSPPS) 45 CFR Part 1303
ndash Subpart B Financial Requirementsndash Subpart E Facilitiesndash Definitions 45 CFR 13052ndash Effective November 7 2016
Financial Laws and Regulations
ACF Administration for Children and
Families
US DEPARTMENT
OF HEALTH AND HUMAN SERVICES
1 Log No ACF-IM-HS-14-07 2 Issuance Date 12172014
3 Originating Office Office of Head Start
4 Key Words Grants Management Grants Administration
Administrative Requirements Cost Principles Audit
Requirements
INFORMATION MEMORANDUM
TO All Head Start and Early Head Start Grantees and Delegate Agencies
SUBJECT New Uniform Administrative Requirements Cost Principles and Audit Requirements for
Federal Awards INFORMATION The Office of Management and Budget (OMB) has issued new uniform administrative
requirements cost principles and audit requirements effective Dec 26 2014 which are
applicable to all Head Start and Early Head Start agencies and sub-recipients including
delegate agencies The Office of Head Start (OHS) is providing general guidance to assist
grantees in planning for implementation of the new requirements
Non-Federal Entities
The new uniform administrative requirements cost principles and audit requirements
(collectively the new fiscal regulations) replace use of the terms grantee grant funded
organization delegate agency and sub-recipient with uniform use of the inclusive term
non-federal entity (NFE) This Memorandum will use the terms non-federal entity receiving
Head Start funds or NFE to refer to all covered entities
Effective Date The new fiscal regulations are effective for awards (or award increments) made on or after
Dec 26 2014 Adoption of the regulations prior to Dec 26 2014 is not allowed After Dec 26
2014 NFEs may establish a single program-level effective date for application of the
regulations to existing Head Start awards for ease of implementation and administration The
program-level effective date must be reflected in the granteersquos fiscal policies and within
effective dates for application of the new regulations to affected awards
Audit Threshold The regulation has increased the single audit threshold from $500000 to $750000 NFEs
receiving at least $750000 in federal funding from all sources (including Head Start Early
Head Start and Early Head Start-Child Care Partnership awards) are subject to the single
audit requirement for fiscal years beginning on or after Dec 26 2014
Supersession and Impact on the Head Start Act and Performance Standards
The new regulations when effective supersede all current audit circulars and cost principle
guidance currently codified under Title 2 Code of Federal Regulations (2 CFR 215 2 CFR 220
2 CFR 225 and 2 CFR 230) Grants management regulations at 45 CFR Part 74 and 45 CFR
Part 92 are also superseded NFEs should implement the new regulations as written but
anticipate codifying regulations from the Department of Health and Human Services (HHS) to
be found at a new 45 CFR Part 75 An issuance date is not known at this time Fiscal
18
Audits in Head Start
bull Sec 647 of the Head Start Act (HSA) requires that all entities receiving Head Start fundsndash keep records necessary to facilitate an effective audit
ndash submit a copy of the audit within 30 days of completion
bull Sec 641 of the HSA includes annual audits (going concern) within the criteria for competition under the Designation Renewal System implemented at 45 CFR Part 1303 ndashSubpart B
19
Audits in Head Start
bull Sec 642 of the HSA addresses responsibilities of the grantee governing body (board) and policy council includingndash Governing body has legal and fiscal responsibility
for the agency and shallbull be responsible for selection of the auditor who shall
report to the governing body
bull review and approve policies relating to the financial audit
bull monitor the agencyrsquos action to correct any audit findings
20
Audits in Head Start
bull Both the governing body and the policy council must be provided with a copy of the annual financial audit
bull Each agency must make available to the public a report published at least once in each fiscal year that discloses the results of the annual financial audit
21
Streamlined requirements Reduced the number of regulations Made them easier to understand Grouped related requirements Eliminated redundancy Reduced administrative burden Provided greater flexibility to
determine how best to achieve goals
22
Performance Standard Outcomes
Importance of Definitional Changes
bull An important difference in the new HSPPS is that all definitions are collected at 45 CFR sect13052
ndash Some definitions are the same some are brand new and some longstanding terms have new definitions
23
Example - New Definitions
bull Federal interest is a property right which secures the right of the federal awarding agency to recover the current fair market value of its percentage of participation in the cost of the facility in the event the facility is no longer used for Head Start purposes by the grantee or upon the disposition of the property When a grantee uses Head Start funds to purchase construct or renovate a facility or make mortgage payments it creates a federal interest The federal interest includes any portion of the cost of purchase construction or renovation contributed by or for the entity or a related donor organization to satisfy a matching requirement
bull Repair means maintenance that is necessary to keep a Head Start facility in working condition Repairs do not add significant value to the property or extend its useful life
24
Example - Changed Definitions
bull Old Major renovation means a structural change to the foundation roof floor or exterior or load-bearing walls of a facility or extension of an existing facility to increase its floor area Major renovation also means extensive alteration of an existing facility such as to significantly change its function and purpose even if such renovation does not include any structural change to the facility Major renovation also includes a renovation of any kind which has a cost exceeding the lesser of $200000 adjusted annually to reflect the percentage change in the Consumer Price Index for All Urban Consumers (issued by the Bureau of Labor Statistics) beginning one year after June 22003 or 25 percent of the total annual direct costs approved for the grantee by ACF for the budget period in which the application is made
bull New Major renovation means any individual or collecti[ve] renovation that has a cost equal to or exceeding $250000 It excludes minor renovations and repairs except when they are included in a purchase application
25
Early Childhood Learning and Knowledge Center (ECLKC)
OHS Early Childhood Learning and Knowledge Center
Click thestar to access ECLKC byhyperlink
Or go tohttpseclkcohsacfhhsgovhslc
26
Governmental Audit Quality Center
Auditing the Head Start
Program
29
Governmental Audit Quality Center
Event Materials Highlight Requirements
Unique to Head Start
The following basic single audit knowledge
is assumed
bull Auditing standards (GAAS and Government Auditing
Standards)
bull Uniform Administrative Requirements Cost
Principles and Audit Requirements for Federal
Awards at 2 CFR 200 (UG or Uniform Guidance)
bull OMB Compliance Supplement
bull Federal Audit Clearinghouse reporting
30
Governmental Audit Quality Center
Information Provided is not a Substitute for
Compliance Supplement or UG
Session focuses on program changes and
areas identified as common risks for Head
Start programs
bull An individual entityrsquos risk may be different
Auditor must still comply with the UG and
consider all requirements identified in the
Compliance Supplement
31
Governmental Audit Quality Center
2017 Updated Compliance Supplement
for Head Start An Overview
Program Objectives and Program Procedures
Matrix
Compliance Requirements - Updates
bull A Activities Allowed or Unallowed
bull E Eligibility for Subrecipients
bull F Equipment amp Real Property Management (Head Start
property requirements move to Special Tests and Provisions
bull J Program Income ndash Deleted
bull L3 Special Reporting (new report)
bull N Special Tests and Provisions (Property amp program
governance)
IV Other Information ndash Areas of risk
32
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
Continuing Professional Education
You must answer at least 75 of the random
attendance checks to earn CPE credit
Please respond to the attendance checks during the
live presentation
You are not eligible to earn CPE by watching the
archive of this event
At the end of todayrsquos presentation we will provide
steps for obtaining your CPE certificate
4
Governmental Audit Quality Center
Presenters
Stephen W Blann CPA CGFM CGMA
Rehmann
Terry Ramsey CPA
Technical Advisor on Single Audit
Administration for Children and Families
Belinda Rinker JD
Senior Policy Analyst
Office of Head Start
Moderator Mary Foelster CPA
AICPA
5
Governmental Audit Quality Center
What We Will Cover
Overview of the Head Start Program
Auditing the Head Start Program
bull New program compliance requirements and auditor
guidance in 2017 Office of Management and Budget
(OMB) Compliance Supplement (Supplement)
bull Program risks
bull Auditor best practices and tips
Resources
6
EMPHASIS POINT Access the Final Draft 2017 Supplement section for CFDA No 93600 under the Handouts tab and refer to during this presentation
Governmental Audit Quality Center
2017 Compliance Supplement - Status
OMB is delayed in issuing the final Supplement
A final draft of the 2017 Supplement has been
released to the GAQC for auditors to use for
planning purposes only
bull CFDA 93600 is available at the link above (look under HHS tab)
bull No major changes expected in final Supplement for Head Start
Final issuance of Supplement not expected until
GAQC will announce issuance of final Supplement
7
EMPHASIS POINT This presentation based on the final draft of the CFDA 93600 program section that was entered into OMB clearance Upon its issuance auditors should review the final 2017 Supplement to ensure no significant changes made during the clearance process
Governmental Audit Quality Center
Overview of the Head
Start Program
8
Head Start Basics
9
Purpose Of Head Start
bull To promote the school readiness of low income children by enhancing their cognitive social and emotional development ndash
ndash in a learning environment that supports childrens growth in language literacy mathematics science social and emotional functioning creative arts physical skills and approaches to learning and
ndash through the provision of health educational nutritional social and other services that are determined based on family needs assessments to be necessary
10
50+ Years of Head Start
11
1965 - 2015
Click the star to seea Head Start timeline
Head Start Program Offerings
Head Start (HS)ndash Serves children ages 3-5 years old and their families
Early Head Start (EHS)ndash Serves pregnant mothers and children ages birth to 3 years
old and their families
Early Head Start ndash Child Care Partnerships (EHS ndash CCP) ndash Early Head Start delivered in partnership with providers
receiving child care subsidies
HS and EHS may be delivered in either center-based or home-based models EHS ndash CCP is center-based only but includes family child care homes
12
Head Start Enrollment
13
In 2015 Head Start served nearly one millionchildren ages 0 ndash 5 and pregnant women
Location of Grantees
14
Grantees and Grant Awards
bull Number of Granteesndash 1600 Head Start and Early Head Start grantees
nationwide including territories
bull Number of Grants ndash 2000 Head Start and Early Head Start grant awards
bull Award Amounts ndash Head Start awards range from
$150000 - $130000000
ndash Early Head Start awards range from $80000 -$18000000
15
Organization Types
16
Regional Offices
17
bull The Head Start Act 42 USC 9801 et seqespecially Sec 642
bull 45 CFR Part 75 Uniform Administrative Requirements Cost Principles and Audit Requirements for HHS awards (the Uniform Guidance)
bull Head Start Program Performance Standards (HSPPS) 45 CFR Part 1303
ndash Subpart B Financial Requirementsndash Subpart E Facilitiesndash Definitions 45 CFR 13052ndash Effective November 7 2016
Financial Laws and Regulations
ACF Administration for Children and
Families
US DEPARTMENT
OF HEALTH AND HUMAN SERVICES
1 Log No ACF-IM-HS-14-07 2 Issuance Date 12172014
3 Originating Office Office of Head Start
4 Key Words Grants Management Grants Administration
Administrative Requirements Cost Principles Audit
Requirements
INFORMATION MEMORANDUM
TO All Head Start and Early Head Start Grantees and Delegate Agencies
SUBJECT New Uniform Administrative Requirements Cost Principles and Audit Requirements for
Federal Awards INFORMATION The Office of Management and Budget (OMB) has issued new uniform administrative
requirements cost principles and audit requirements effective Dec 26 2014 which are
applicable to all Head Start and Early Head Start agencies and sub-recipients including
delegate agencies The Office of Head Start (OHS) is providing general guidance to assist
grantees in planning for implementation of the new requirements
Non-Federal Entities
The new uniform administrative requirements cost principles and audit requirements
(collectively the new fiscal regulations) replace use of the terms grantee grant funded
organization delegate agency and sub-recipient with uniform use of the inclusive term
non-federal entity (NFE) This Memorandum will use the terms non-federal entity receiving
Head Start funds or NFE to refer to all covered entities
Effective Date The new fiscal regulations are effective for awards (or award increments) made on or after
Dec 26 2014 Adoption of the regulations prior to Dec 26 2014 is not allowed After Dec 26
2014 NFEs may establish a single program-level effective date for application of the
regulations to existing Head Start awards for ease of implementation and administration The
program-level effective date must be reflected in the granteersquos fiscal policies and within
effective dates for application of the new regulations to affected awards
Audit Threshold The regulation has increased the single audit threshold from $500000 to $750000 NFEs
receiving at least $750000 in federal funding from all sources (including Head Start Early
Head Start and Early Head Start-Child Care Partnership awards) are subject to the single
audit requirement for fiscal years beginning on or after Dec 26 2014
Supersession and Impact on the Head Start Act and Performance Standards
The new regulations when effective supersede all current audit circulars and cost principle
guidance currently codified under Title 2 Code of Federal Regulations (2 CFR 215 2 CFR 220
2 CFR 225 and 2 CFR 230) Grants management regulations at 45 CFR Part 74 and 45 CFR
Part 92 are also superseded NFEs should implement the new regulations as written but
anticipate codifying regulations from the Department of Health and Human Services (HHS) to
be found at a new 45 CFR Part 75 An issuance date is not known at this time Fiscal
18
Audits in Head Start
bull Sec 647 of the Head Start Act (HSA) requires that all entities receiving Head Start fundsndash keep records necessary to facilitate an effective audit
ndash submit a copy of the audit within 30 days of completion
bull Sec 641 of the HSA includes annual audits (going concern) within the criteria for competition under the Designation Renewal System implemented at 45 CFR Part 1303 ndashSubpart B
19
Audits in Head Start
bull Sec 642 of the HSA addresses responsibilities of the grantee governing body (board) and policy council includingndash Governing body has legal and fiscal responsibility
for the agency and shallbull be responsible for selection of the auditor who shall
report to the governing body
bull review and approve policies relating to the financial audit
bull monitor the agencyrsquos action to correct any audit findings
20
Audits in Head Start
bull Both the governing body and the policy council must be provided with a copy of the annual financial audit
bull Each agency must make available to the public a report published at least once in each fiscal year that discloses the results of the annual financial audit
21
Streamlined requirements Reduced the number of regulations Made them easier to understand Grouped related requirements Eliminated redundancy Reduced administrative burden Provided greater flexibility to
determine how best to achieve goals
22
Performance Standard Outcomes
Importance of Definitional Changes
bull An important difference in the new HSPPS is that all definitions are collected at 45 CFR sect13052
ndash Some definitions are the same some are brand new and some longstanding terms have new definitions
23
Example - New Definitions
bull Federal interest is a property right which secures the right of the federal awarding agency to recover the current fair market value of its percentage of participation in the cost of the facility in the event the facility is no longer used for Head Start purposes by the grantee or upon the disposition of the property When a grantee uses Head Start funds to purchase construct or renovate a facility or make mortgage payments it creates a federal interest The federal interest includes any portion of the cost of purchase construction or renovation contributed by or for the entity or a related donor organization to satisfy a matching requirement
bull Repair means maintenance that is necessary to keep a Head Start facility in working condition Repairs do not add significant value to the property or extend its useful life
24
Example - Changed Definitions
bull Old Major renovation means a structural change to the foundation roof floor or exterior or load-bearing walls of a facility or extension of an existing facility to increase its floor area Major renovation also means extensive alteration of an existing facility such as to significantly change its function and purpose even if such renovation does not include any structural change to the facility Major renovation also includes a renovation of any kind which has a cost exceeding the lesser of $200000 adjusted annually to reflect the percentage change in the Consumer Price Index for All Urban Consumers (issued by the Bureau of Labor Statistics) beginning one year after June 22003 or 25 percent of the total annual direct costs approved for the grantee by ACF for the budget period in which the application is made
bull New Major renovation means any individual or collecti[ve] renovation that has a cost equal to or exceeding $250000 It excludes minor renovations and repairs except when they are included in a purchase application
25
Early Childhood Learning and Knowledge Center (ECLKC)
OHS Early Childhood Learning and Knowledge Center
Click thestar to access ECLKC byhyperlink
Or go tohttpseclkcohsacfhhsgovhslc
26
Governmental Audit Quality Center
Auditing the Head Start
Program
29
Governmental Audit Quality Center
Event Materials Highlight Requirements
Unique to Head Start
The following basic single audit knowledge
is assumed
bull Auditing standards (GAAS and Government Auditing
Standards)
bull Uniform Administrative Requirements Cost
Principles and Audit Requirements for Federal
Awards at 2 CFR 200 (UG or Uniform Guidance)
bull OMB Compliance Supplement
bull Federal Audit Clearinghouse reporting
30
Governmental Audit Quality Center
Information Provided is not a Substitute for
Compliance Supplement or UG
Session focuses on program changes and
areas identified as common risks for Head
Start programs
bull An individual entityrsquos risk may be different
Auditor must still comply with the UG and
consider all requirements identified in the
Compliance Supplement
31
Governmental Audit Quality Center
2017 Updated Compliance Supplement
for Head Start An Overview
Program Objectives and Program Procedures
Matrix
Compliance Requirements - Updates
bull A Activities Allowed or Unallowed
bull E Eligibility for Subrecipients
bull F Equipment amp Real Property Management (Head Start
property requirements move to Special Tests and Provisions
bull J Program Income ndash Deleted
bull L3 Special Reporting (new report)
bull N Special Tests and Provisions (Property amp program
governance)
IV Other Information ndash Areas of risk
32
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
Presenters
Stephen W Blann CPA CGFM CGMA
Rehmann
Terry Ramsey CPA
Technical Advisor on Single Audit
Administration for Children and Families
Belinda Rinker JD
Senior Policy Analyst
Office of Head Start
Moderator Mary Foelster CPA
AICPA
5
Governmental Audit Quality Center
What We Will Cover
Overview of the Head Start Program
Auditing the Head Start Program
bull New program compliance requirements and auditor
guidance in 2017 Office of Management and Budget
(OMB) Compliance Supplement (Supplement)
bull Program risks
bull Auditor best practices and tips
Resources
6
EMPHASIS POINT Access the Final Draft 2017 Supplement section for CFDA No 93600 under the Handouts tab and refer to during this presentation
Governmental Audit Quality Center
2017 Compliance Supplement - Status
OMB is delayed in issuing the final Supplement
A final draft of the 2017 Supplement has been
released to the GAQC for auditors to use for
planning purposes only
bull CFDA 93600 is available at the link above (look under HHS tab)
bull No major changes expected in final Supplement for Head Start
Final issuance of Supplement not expected until
GAQC will announce issuance of final Supplement
7
EMPHASIS POINT This presentation based on the final draft of the CFDA 93600 program section that was entered into OMB clearance Upon its issuance auditors should review the final 2017 Supplement to ensure no significant changes made during the clearance process
Governmental Audit Quality Center
Overview of the Head
Start Program
8
Head Start Basics
9
Purpose Of Head Start
bull To promote the school readiness of low income children by enhancing their cognitive social and emotional development ndash
ndash in a learning environment that supports childrens growth in language literacy mathematics science social and emotional functioning creative arts physical skills and approaches to learning and
ndash through the provision of health educational nutritional social and other services that are determined based on family needs assessments to be necessary
10
50+ Years of Head Start
11
1965 - 2015
Click the star to seea Head Start timeline
Head Start Program Offerings
Head Start (HS)ndash Serves children ages 3-5 years old and their families
Early Head Start (EHS)ndash Serves pregnant mothers and children ages birth to 3 years
old and their families
Early Head Start ndash Child Care Partnerships (EHS ndash CCP) ndash Early Head Start delivered in partnership with providers
receiving child care subsidies
HS and EHS may be delivered in either center-based or home-based models EHS ndash CCP is center-based only but includes family child care homes
12
Head Start Enrollment
13
In 2015 Head Start served nearly one millionchildren ages 0 ndash 5 and pregnant women
Location of Grantees
14
Grantees and Grant Awards
bull Number of Granteesndash 1600 Head Start and Early Head Start grantees
nationwide including territories
bull Number of Grants ndash 2000 Head Start and Early Head Start grant awards
bull Award Amounts ndash Head Start awards range from
$150000 - $130000000
ndash Early Head Start awards range from $80000 -$18000000
15
Organization Types
16
Regional Offices
17
bull The Head Start Act 42 USC 9801 et seqespecially Sec 642
bull 45 CFR Part 75 Uniform Administrative Requirements Cost Principles and Audit Requirements for HHS awards (the Uniform Guidance)
bull Head Start Program Performance Standards (HSPPS) 45 CFR Part 1303
ndash Subpart B Financial Requirementsndash Subpart E Facilitiesndash Definitions 45 CFR 13052ndash Effective November 7 2016
Financial Laws and Regulations
ACF Administration for Children and
Families
US DEPARTMENT
OF HEALTH AND HUMAN SERVICES
1 Log No ACF-IM-HS-14-07 2 Issuance Date 12172014
3 Originating Office Office of Head Start
4 Key Words Grants Management Grants Administration
Administrative Requirements Cost Principles Audit
Requirements
INFORMATION MEMORANDUM
TO All Head Start and Early Head Start Grantees and Delegate Agencies
SUBJECT New Uniform Administrative Requirements Cost Principles and Audit Requirements for
Federal Awards INFORMATION The Office of Management and Budget (OMB) has issued new uniform administrative
requirements cost principles and audit requirements effective Dec 26 2014 which are
applicable to all Head Start and Early Head Start agencies and sub-recipients including
delegate agencies The Office of Head Start (OHS) is providing general guidance to assist
grantees in planning for implementation of the new requirements
Non-Federal Entities
The new uniform administrative requirements cost principles and audit requirements
(collectively the new fiscal regulations) replace use of the terms grantee grant funded
organization delegate agency and sub-recipient with uniform use of the inclusive term
non-federal entity (NFE) This Memorandum will use the terms non-federal entity receiving
Head Start funds or NFE to refer to all covered entities
Effective Date The new fiscal regulations are effective for awards (or award increments) made on or after
Dec 26 2014 Adoption of the regulations prior to Dec 26 2014 is not allowed After Dec 26
2014 NFEs may establish a single program-level effective date for application of the
regulations to existing Head Start awards for ease of implementation and administration The
program-level effective date must be reflected in the granteersquos fiscal policies and within
effective dates for application of the new regulations to affected awards
Audit Threshold The regulation has increased the single audit threshold from $500000 to $750000 NFEs
receiving at least $750000 in federal funding from all sources (including Head Start Early
Head Start and Early Head Start-Child Care Partnership awards) are subject to the single
audit requirement for fiscal years beginning on or after Dec 26 2014
Supersession and Impact on the Head Start Act and Performance Standards
The new regulations when effective supersede all current audit circulars and cost principle
guidance currently codified under Title 2 Code of Federal Regulations (2 CFR 215 2 CFR 220
2 CFR 225 and 2 CFR 230) Grants management regulations at 45 CFR Part 74 and 45 CFR
Part 92 are also superseded NFEs should implement the new regulations as written but
anticipate codifying regulations from the Department of Health and Human Services (HHS) to
be found at a new 45 CFR Part 75 An issuance date is not known at this time Fiscal
18
Audits in Head Start
bull Sec 647 of the Head Start Act (HSA) requires that all entities receiving Head Start fundsndash keep records necessary to facilitate an effective audit
ndash submit a copy of the audit within 30 days of completion
bull Sec 641 of the HSA includes annual audits (going concern) within the criteria for competition under the Designation Renewal System implemented at 45 CFR Part 1303 ndashSubpart B
19
Audits in Head Start
bull Sec 642 of the HSA addresses responsibilities of the grantee governing body (board) and policy council includingndash Governing body has legal and fiscal responsibility
for the agency and shallbull be responsible for selection of the auditor who shall
report to the governing body
bull review and approve policies relating to the financial audit
bull monitor the agencyrsquos action to correct any audit findings
20
Audits in Head Start
bull Both the governing body and the policy council must be provided with a copy of the annual financial audit
bull Each agency must make available to the public a report published at least once in each fiscal year that discloses the results of the annual financial audit
21
Streamlined requirements Reduced the number of regulations Made them easier to understand Grouped related requirements Eliminated redundancy Reduced administrative burden Provided greater flexibility to
determine how best to achieve goals
22
Performance Standard Outcomes
Importance of Definitional Changes
bull An important difference in the new HSPPS is that all definitions are collected at 45 CFR sect13052
ndash Some definitions are the same some are brand new and some longstanding terms have new definitions
23
Example - New Definitions
bull Federal interest is a property right which secures the right of the federal awarding agency to recover the current fair market value of its percentage of participation in the cost of the facility in the event the facility is no longer used for Head Start purposes by the grantee or upon the disposition of the property When a grantee uses Head Start funds to purchase construct or renovate a facility or make mortgage payments it creates a federal interest The federal interest includes any portion of the cost of purchase construction or renovation contributed by or for the entity or a related donor organization to satisfy a matching requirement
bull Repair means maintenance that is necessary to keep a Head Start facility in working condition Repairs do not add significant value to the property or extend its useful life
24
Example - Changed Definitions
bull Old Major renovation means a structural change to the foundation roof floor or exterior or load-bearing walls of a facility or extension of an existing facility to increase its floor area Major renovation also means extensive alteration of an existing facility such as to significantly change its function and purpose even if such renovation does not include any structural change to the facility Major renovation also includes a renovation of any kind which has a cost exceeding the lesser of $200000 adjusted annually to reflect the percentage change in the Consumer Price Index for All Urban Consumers (issued by the Bureau of Labor Statistics) beginning one year after June 22003 or 25 percent of the total annual direct costs approved for the grantee by ACF for the budget period in which the application is made
bull New Major renovation means any individual or collecti[ve] renovation that has a cost equal to or exceeding $250000 It excludes minor renovations and repairs except when they are included in a purchase application
25
Early Childhood Learning and Knowledge Center (ECLKC)
OHS Early Childhood Learning and Knowledge Center
Click thestar to access ECLKC byhyperlink
Or go tohttpseclkcohsacfhhsgovhslc
26
Governmental Audit Quality Center
Auditing the Head Start
Program
29
Governmental Audit Quality Center
Event Materials Highlight Requirements
Unique to Head Start
The following basic single audit knowledge
is assumed
bull Auditing standards (GAAS and Government Auditing
Standards)
bull Uniform Administrative Requirements Cost
Principles and Audit Requirements for Federal
Awards at 2 CFR 200 (UG or Uniform Guidance)
bull OMB Compliance Supplement
bull Federal Audit Clearinghouse reporting
30
Governmental Audit Quality Center
Information Provided is not a Substitute for
Compliance Supplement or UG
Session focuses on program changes and
areas identified as common risks for Head
Start programs
bull An individual entityrsquos risk may be different
Auditor must still comply with the UG and
consider all requirements identified in the
Compliance Supplement
31
Governmental Audit Quality Center
2017 Updated Compliance Supplement
for Head Start An Overview
Program Objectives and Program Procedures
Matrix
Compliance Requirements - Updates
bull A Activities Allowed or Unallowed
bull E Eligibility for Subrecipients
bull F Equipment amp Real Property Management (Head Start
property requirements move to Special Tests and Provisions
bull J Program Income ndash Deleted
bull L3 Special Reporting (new report)
bull N Special Tests and Provisions (Property amp program
governance)
IV Other Information ndash Areas of risk
32
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
What We Will Cover
Overview of the Head Start Program
Auditing the Head Start Program
bull New program compliance requirements and auditor
guidance in 2017 Office of Management and Budget
(OMB) Compliance Supplement (Supplement)
bull Program risks
bull Auditor best practices and tips
Resources
6
EMPHASIS POINT Access the Final Draft 2017 Supplement section for CFDA No 93600 under the Handouts tab and refer to during this presentation
Governmental Audit Quality Center
2017 Compliance Supplement - Status
OMB is delayed in issuing the final Supplement
A final draft of the 2017 Supplement has been
released to the GAQC for auditors to use for
planning purposes only
bull CFDA 93600 is available at the link above (look under HHS tab)
bull No major changes expected in final Supplement for Head Start
Final issuance of Supplement not expected until
GAQC will announce issuance of final Supplement
7
EMPHASIS POINT This presentation based on the final draft of the CFDA 93600 program section that was entered into OMB clearance Upon its issuance auditors should review the final 2017 Supplement to ensure no significant changes made during the clearance process
Governmental Audit Quality Center
Overview of the Head
Start Program
8
Head Start Basics
9
Purpose Of Head Start
bull To promote the school readiness of low income children by enhancing their cognitive social and emotional development ndash
ndash in a learning environment that supports childrens growth in language literacy mathematics science social and emotional functioning creative arts physical skills and approaches to learning and
ndash through the provision of health educational nutritional social and other services that are determined based on family needs assessments to be necessary
10
50+ Years of Head Start
11
1965 - 2015
Click the star to seea Head Start timeline
Head Start Program Offerings
Head Start (HS)ndash Serves children ages 3-5 years old and their families
Early Head Start (EHS)ndash Serves pregnant mothers and children ages birth to 3 years
old and their families
Early Head Start ndash Child Care Partnerships (EHS ndash CCP) ndash Early Head Start delivered in partnership with providers
receiving child care subsidies
HS and EHS may be delivered in either center-based or home-based models EHS ndash CCP is center-based only but includes family child care homes
12
Head Start Enrollment
13
In 2015 Head Start served nearly one millionchildren ages 0 ndash 5 and pregnant women
Location of Grantees
14
Grantees and Grant Awards
bull Number of Granteesndash 1600 Head Start and Early Head Start grantees
nationwide including territories
bull Number of Grants ndash 2000 Head Start and Early Head Start grant awards
bull Award Amounts ndash Head Start awards range from
$150000 - $130000000
ndash Early Head Start awards range from $80000 -$18000000
15
Organization Types
16
Regional Offices
17
bull The Head Start Act 42 USC 9801 et seqespecially Sec 642
bull 45 CFR Part 75 Uniform Administrative Requirements Cost Principles and Audit Requirements for HHS awards (the Uniform Guidance)
bull Head Start Program Performance Standards (HSPPS) 45 CFR Part 1303
ndash Subpart B Financial Requirementsndash Subpart E Facilitiesndash Definitions 45 CFR 13052ndash Effective November 7 2016
Financial Laws and Regulations
ACF Administration for Children and
Families
US DEPARTMENT
OF HEALTH AND HUMAN SERVICES
1 Log No ACF-IM-HS-14-07 2 Issuance Date 12172014
3 Originating Office Office of Head Start
4 Key Words Grants Management Grants Administration
Administrative Requirements Cost Principles Audit
Requirements
INFORMATION MEMORANDUM
TO All Head Start and Early Head Start Grantees and Delegate Agencies
SUBJECT New Uniform Administrative Requirements Cost Principles and Audit Requirements for
Federal Awards INFORMATION The Office of Management and Budget (OMB) has issued new uniform administrative
requirements cost principles and audit requirements effective Dec 26 2014 which are
applicable to all Head Start and Early Head Start agencies and sub-recipients including
delegate agencies The Office of Head Start (OHS) is providing general guidance to assist
grantees in planning for implementation of the new requirements
Non-Federal Entities
The new uniform administrative requirements cost principles and audit requirements
(collectively the new fiscal regulations) replace use of the terms grantee grant funded
organization delegate agency and sub-recipient with uniform use of the inclusive term
non-federal entity (NFE) This Memorandum will use the terms non-federal entity receiving
Head Start funds or NFE to refer to all covered entities
Effective Date The new fiscal regulations are effective for awards (or award increments) made on or after
Dec 26 2014 Adoption of the regulations prior to Dec 26 2014 is not allowed After Dec 26
2014 NFEs may establish a single program-level effective date for application of the
regulations to existing Head Start awards for ease of implementation and administration The
program-level effective date must be reflected in the granteersquos fiscal policies and within
effective dates for application of the new regulations to affected awards
Audit Threshold The regulation has increased the single audit threshold from $500000 to $750000 NFEs
receiving at least $750000 in federal funding from all sources (including Head Start Early
Head Start and Early Head Start-Child Care Partnership awards) are subject to the single
audit requirement for fiscal years beginning on or after Dec 26 2014
Supersession and Impact on the Head Start Act and Performance Standards
The new regulations when effective supersede all current audit circulars and cost principle
guidance currently codified under Title 2 Code of Federal Regulations (2 CFR 215 2 CFR 220
2 CFR 225 and 2 CFR 230) Grants management regulations at 45 CFR Part 74 and 45 CFR
Part 92 are also superseded NFEs should implement the new regulations as written but
anticipate codifying regulations from the Department of Health and Human Services (HHS) to
be found at a new 45 CFR Part 75 An issuance date is not known at this time Fiscal
18
Audits in Head Start
bull Sec 647 of the Head Start Act (HSA) requires that all entities receiving Head Start fundsndash keep records necessary to facilitate an effective audit
ndash submit a copy of the audit within 30 days of completion
bull Sec 641 of the HSA includes annual audits (going concern) within the criteria for competition under the Designation Renewal System implemented at 45 CFR Part 1303 ndashSubpart B
19
Audits in Head Start
bull Sec 642 of the HSA addresses responsibilities of the grantee governing body (board) and policy council includingndash Governing body has legal and fiscal responsibility
for the agency and shallbull be responsible for selection of the auditor who shall
report to the governing body
bull review and approve policies relating to the financial audit
bull monitor the agencyrsquos action to correct any audit findings
20
Audits in Head Start
bull Both the governing body and the policy council must be provided with a copy of the annual financial audit
bull Each agency must make available to the public a report published at least once in each fiscal year that discloses the results of the annual financial audit
21
Streamlined requirements Reduced the number of regulations Made them easier to understand Grouped related requirements Eliminated redundancy Reduced administrative burden Provided greater flexibility to
determine how best to achieve goals
22
Performance Standard Outcomes
Importance of Definitional Changes
bull An important difference in the new HSPPS is that all definitions are collected at 45 CFR sect13052
ndash Some definitions are the same some are brand new and some longstanding terms have new definitions
23
Example - New Definitions
bull Federal interest is a property right which secures the right of the federal awarding agency to recover the current fair market value of its percentage of participation in the cost of the facility in the event the facility is no longer used for Head Start purposes by the grantee or upon the disposition of the property When a grantee uses Head Start funds to purchase construct or renovate a facility or make mortgage payments it creates a federal interest The federal interest includes any portion of the cost of purchase construction or renovation contributed by or for the entity or a related donor organization to satisfy a matching requirement
bull Repair means maintenance that is necessary to keep a Head Start facility in working condition Repairs do not add significant value to the property or extend its useful life
24
Example - Changed Definitions
bull Old Major renovation means a structural change to the foundation roof floor or exterior or load-bearing walls of a facility or extension of an existing facility to increase its floor area Major renovation also means extensive alteration of an existing facility such as to significantly change its function and purpose even if such renovation does not include any structural change to the facility Major renovation also includes a renovation of any kind which has a cost exceeding the lesser of $200000 adjusted annually to reflect the percentage change in the Consumer Price Index for All Urban Consumers (issued by the Bureau of Labor Statistics) beginning one year after June 22003 or 25 percent of the total annual direct costs approved for the grantee by ACF for the budget period in which the application is made
bull New Major renovation means any individual or collecti[ve] renovation that has a cost equal to or exceeding $250000 It excludes minor renovations and repairs except when they are included in a purchase application
25
Early Childhood Learning and Knowledge Center (ECLKC)
OHS Early Childhood Learning and Knowledge Center
Click thestar to access ECLKC byhyperlink
Or go tohttpseclkcohsacfhhsgovhslc
26
Governmental Audit Quality Center
Auditing the Head Start
Program
29
Governmental Audit Quality Center
Event Materials Highlight Requirements
Unique to Head Start
The following basic single audit knowledge
is assumed
bull Auditing standards (GAAS and Government Auditing
Standards)
bull Uniform Administrative Requirements Cost
Principles and Audit Requirements for Federal
Awards at 2 CFR 200 (UG or Uniform Guidance)
bull OMB Compliance Supplement
bull Federal Audit Clearinghouse reporting
30
Governmental Audit Quality Center
Information Provided is not a Substitute for
Compliance Supplement or UG
Session focuses on program changes and
areas identified as common risks for Head
Start programs
bull An individual entityrsquos risk may be different
Auditor must still comply with the UG and
consider all requirements identified in the
Compliance Supplement
31
Governmental Audit Quality Center
2017 Updated Compliance Supplement
for Head Start An Overview
Program Objectives and Program Procedures
Matrix
Compliance Requirements - Updates
bull A Activities Allowed or Unallowed
bull E Eligibility for Subrecipients
bull F Equipment amp Real Property Management (Head Start
property requirements move to Special Tests and Provisions
bull J Program Income ndash Deleted
bull L3 Special Reporting (new report)
bull N Special Tests and Provisions (Property amp program
governance)
IV Other Information ndash Areas of risk
32
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
2017 Compliance Supplement - Status
OMB is delayed in issuing the final Supplement
A final draft of the 2017 Supplement has been
released to the GAQC for auditors to use for
planning purposes only
bull CFDA 93600 is available at the link above (look under HHS tab)
bull No major changes expected in final Supplement for Head Start
Final issuance of Supplement not expected until
GAQC will announce issuance of final Supplement
7
EMPHASIS POINT This presentation based on the final draft of the CFDA 93600 program section that was entered into OMB clearance Upon its issuance auditors should review the final 2017 Supplement to ensure no significant changes made during the clearance process
Governmental Audit Quality Center
Overview of the Head
Start Program
8
Head Start Basics
9
Purpose Of Head Start
bull To promote the school readiness of low income children by enhancing their cognitive social and emotional development ndash
ndash in a learning environment that supports childrens growth in language literacy mathematics science social and emotional functioning creative arts physical skills and approaches to learning and
ndash through the provision of health educational nutritional social and other services that are determined based on family needs assessments to be necessary
10
50+ Years of Head Start
11
1965 - 2015
Click the star to seea Head Start timeline
Head Start Program Offerings
Head Start (HS)ndash Serves children ages 3-5 years old and their families
Early Head Start (EHS)ndash Serves pregnant mothers and children ages birth to 3 years
old and their families
Early Head Start ndash Child Care Partnerships (EHS ndash CCP) ndash Early Head Start delivered in partnership with providers
receiving child care subsidies
HS and EHS may be delivered in either center-based or home-based models EHS ndash CCP is center-based only but includes family child care homes
12
Head Start Enrollment
13
In 2015 Head Start served nearly one millionchildren ages 0 ndash 5 and pregnant women
Location of Grantees
14
Grantees and Grant Awards
bull Number of Granteesndash 1600 Head Start and Early Head Start grantees
nationwide including territories
bull Number of Grants ndash 2000 Head Start and Early Head Start grant awards
bull Award Amounts ndash Head Start awards range from
$150000 - $130000000
ndash Early Head Start awards range from $80000 -$18000000
15
Organization Types
16
Regional Offices
17
bull The Head Start Act 42 USC 9801 et seqespecially Sec 642
bull 45 CFR Part 75 Uniform Administrative Requirements Cost Principles and Audit Requirements for HHS awards (the Uniform Guidance)
bull Head Start Program Performance Standards (HSPPS) 45 CFR Part 1303
ndash Subpart B Financial Requirementsndash Subpart E Facilitiesndash Definitions 45 CFR 13052ndash Effective November 7 2016
Financial Laws and Regulations
ACF Administration for Children and
Families
US DEPARTMENT
OF HEALTH AND HUMAN SERVICES
1 Log No ACF-IM-HS-14-07 2 Issuance Date 12172014
3 Originating Office Office of Head Start
4 Key Words Grants Management Grants Administration
Administrative Requirements Cost Principles Audit
Requirements
INFORMATION MEMORANDUM
TO All Head Start and Early Head Start Grantees and Delegate Agencies
SUBJECT New Uniform Administrative Requirements Cost Principles and Audit Requirements for
Federal Awards INFORMATION The Office of Management and Budget (OMB) has issued new uniform administrative
requirements cost principles and audit requirements effective Dec 26 2014 which are
applicable to all Head Start and Early Head Start agencies and sub-recipients including
delegate agencies The Office of Head Start (OHS) is providing general guidance to assist
grantees in planning for implementation of the new requirements
Non-Federal Entities
The new uniform administrative requirements cost principles and audit requirements
(collectively the new fiscal regulations) replace use of the terms grantee grant funded
organization delegate agency and sub-recipient with uniform use of the inclusive term
non-federal entity (NFE) This Memorandum will use the terms non-federal entity receiving
Head Start funds or NFE to refer to all covered entities
Effective Date The new fiscal regulations are effective for awards (or award increments) made on or after
Dec 26 2014 Adoption of the regulations prior to Dec 26 2014 is not allowed After Dec 26
2014 NFEs may establish a single program-level effective date for application of the
regulations to existing Head Start awards for ease of implementation and administration The
program-level effective date must be reflected in the granteersquos fiscal policies and within
effective dates for application of the new regulations to affected awards
Audit Threshold The regulation has increased the single audit threshold from $500000 to $750000 NFEs
receiving at least $750000 in federal funding from all sources (including Head Start Early
Head Start and Early Head Start-Child Care Partnership awards) are subject to the single
audit requirement for fiscal years beginning on or after Dec 26 2014
Supersession and Impact on the Head Start Act and Performance Standards
The new regulations when effective supersede all current audit circulars and cost principle
guidance currently codified under Title 2 Code of Federal Regulations (2 CFR 215 2 CFR 220
2 CFR 225 and 2 CFR 230) Grants management regulations at 45 CFR Part 74 and 45 CFR
Part 92 are also superseded NFEs should implement the new regulations as written but
anticipate codifying regulations from the Department of Health and Human Services (HHS) to
be found at a new 45 CFR Part 75 An issuance date is not known at this time Fiscal
18
Audits in Head Start
bull Sec 647 of the Head Start Act (HSA) requires that all entities receiving Head Start fundsndash keep records necessary to facilitate an effective audit
ndash submit a copy of the audit within 30 days of completion
bull Sec 641 of the HSA includes annual audits (going concern) within the criteria for competition under the Designation Renewal System implemented at 45 CFR Part 1303 ndashSubpart B
19
Audits in Head Start
bull Sec 642 of the HSA addresses responsibilities of the grantee governing body (board) and policy council includingndash Governing body has legal and fiscal responsibility
for the agency and shallbull be responsible for selection of the auditor who shall
report to the governing body
bull review and approve policies relating to the financial audit
bull monitor the agencyrsquos action to correct any audit findings
20
Audits in Head Start
bull Both the governing body and the policy council must be provided with a copy of the annual financial audit
bull Each agency must make available to the public a report published at least once in each fiscal year that discloses the results of the annual financial audit
21
Streamlined requirements Reduced the number of regulations Made them easier to understand Grouped related requirements Eliminated redundancy Reduced administrative burden Provided greater flexibility to
determine how best to achieve goals
22
Performance Standard Outcomes
Importance of Definitional Changes
bull An important difference in the new HSPPS is that all definitions are collected at 45 CFR sect13052
ndash Some definitions are the same some are brand new and some longstanding terms have new definitions
23
Example - New Definitions
bull Federal interest is a property right which secures the right of the federal awarding agency to recover the current fair market value of its percentage of participation in the cost of the facility in the event the facility is no longer used for Head Start purposes by the grantee or upon the disposition of the property When a grantee uses Head Start funds to purchase construct or renovate a facility or make mortgage payments it creates a federal interest The federal interest includes any portion of the cost of purchase construction or renovation contributed by or for the entity or a related donor organization to satisfy a matching requirement
bull Repair means maintenance that is necessary to keep a Head Start facility in working condition Repairs do not add significant value to the property or extend its useful life
24
Example - Changed Definitions
bull Old Major renovation means a structural change to the foundation roof floor or exterior or load-bearing walls of a facility or extension of an existing facility to increase its floor area Major renovation also means extensive alteration of an existing facility such as to significantly change its function and purpose even if such renovation does not include any structural change to the facility Major renovation also includes a renovation of any kind which has a cost exceeding the lesser of $200000 adjusted annually to reflect the percentage change in the Consumer Price Index for All Urban Consumers (issued by the Bureau of Labor Statistics) beginning one year after June 22003 or 25 percent of the total annual direct costs approved for the grantee by ACF for the budget period in which the application is made
bull New Major renovation means any individual or collecti[ve] renovation that has a cost equal to or exceeding $250000 It excludes minor renovations and repairs except when they are included in a purchase application
25
Early Childhood Learning and Knowledge Center (ECLKC)
OHS Early Childhood Learning and Knowledge Center
Click thestar to access ECLKC byhyperlink
Or go tohttpseclkcohsacfhhsgovhslc
26
Governmental Audit Quality Center
Auditing the Head Start
Program
29
Governmental Audit Quality Center
Event Materials Highlight Requirements
Unique to Head Start
The following basic single audit knowledge
is assumed
bull Auditing standards (GAAS and Government Auditing
Standards)
bull Uniform Administrative Requirements Cost
Principles and Audit Requirements for Federal
Awards at 2 CFR 200 (UG or Uniform Guidance)
bull OMB Compliance Supplement
bull Federal Audit Clearinghouse reporting
30
Governmental Audit Quality Center
Information Provided is not a Substitute for
Compliance Supplement or UG
Session focuses on program changes and
areas identified as common risks for Head
Start programs
bull An individual entityrsquos risk may be different
Auditor must still comply with the UG and
consider all requirements identified in the
Compliance Supplement
31
Governmental Audit Quality Center
2017 Updated Compliance Supplement
for Head Start An Overview
Program Objectives and Program Procedures
Matrix
Compliance Requirements - Updates
bull A Activities Allowed or Unallowed
bull E Eligibility for Subrecipients
bull F Equipment amp Real Property Management (Head Start
property requirements move to Special Tests and Provisions
bull J Program Income ndash Deleted
bull L3 Special Reporting (new report)
bull N Special Tests and Provisions (Property amp program
governance)
IV Other Information ndash Areas of risk
32
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
Overview of the Head
Start Program
8
Head Start Basics
9
Purpose Of Head Start
bull To promote the school readiness of low income children by enhancing their cognitive social and emotional development ndash
ndash in a learning environment that supports childrens growth in language literacy mathematics science social and emotional functioning creative arts physical skills and approaches to learning and
ndash through the provision of health educational nutritional social and other services that are determined based on family needs assessments to be necessary
10
50+ Years of Head Start
11
1965 - 2015
Click the star to seea Head Start timeline
Head Start Program Offerings
Head Start (HS)ndash Serves children ages 3-5 years old and their families
Early Head Start (EHS)ndash Serves pregnant mothers and children ages birth to 3 years
old and their families
Early Head Start ndash Child Care Partnerships (EHS ndash CCP) ndash Early Head Start delivered in partnership with providers
receiving child care subsidies
HS and EHS may be delivered in either center-based or home-based models EHS ndash CCP is center-based only but includes family child care homes
12
Head Start Enrollment
13
In 2015 Head Start served nearly one millionchildren ages 0 ndash 5 and pregnant women
Location of Grantees
14
Grantees and Grant Awards
bull Number of Granteesndash 1600 Head Start and Early Head Start grantees
nationwide including territories
bull Number of Grants ndash 2000 Head Start and Early Head Start grant awards
bull Award Amounts ndash Head Start awards range from
$150000 - $130000000
ndash Early Head Start awards range from $80000 -$18000000
15
Organization Types
16
Regional Offices
17
bull The Head Start Act 42 USC 9801 et seqespecially Sec 642
bull 45 CFR Part 75 Uniform Administrative Requirements Cost Principles and Audit Requirements for HHS awards (the Uniform Guidance)
bull Head Start Program Performance Standards (HSPPS) 45 CFR Part 1303
ndash Subpart B Financial Requirementsndash Subpart E Facilitiesndash Definitions 45 CFR 13052ndash Effective November 7 2016
Financial Laws and Regulations
ACF Administration for Children and
Families
US DEPARTMENT
OF HEALTH AND HUMAN SERVICES
1 Log No ACF-IM-HS-14-07 2 Issuance Date 12172014
3 Originating Office Office of Head Start
4 Key Words Grants Management Grants Administration
Administrative Requirements Cost Principles Audit
Requirements
INFORMATION MEMORANDUM
TO All Head Start and Early Head Start Grantees and Delegate Agencies
SUBJECT New Uniform Administrative Requirements Cost Principles and Audit Requirements for
Federal Awards INFORMATION The Office of Management and Budget (OMB) has issued new uniform administrative
requirements cost principles and audit requirements effective Dec 26 2014 which are
applicable to all Head Start and Early Head Start agencies and sub-recipients including
delegate agencies The Office of Head Start (OHS) is providing general guidance to assist
grantees in planning for implementation of the new requirements
Non-Federal Entities
The new uniform administrative requirements cost principles and audit requirements
(collectively the new fiscal regulations) replace use of the terms grantee grant funded
organization delegate agency and sub-recipient with uniform use of the inclusive term
non-federal entity (NFE) This Memorandum will use the terms non-federal entity receiving
Head Start funds or NFE to refer to all covered entities
Effective Date The new fiscal regulations are effective for awards (or award increments) made on or after
Dec 26 2014 Adoption of the regulations prior to Dec 26 2014 is not allowed After Dec 26
2014 NFEs may establish a single program-level effective date for application of the
regulations to existing Head Start awards for ease of implementation and administration The
program-level effective date must be reflected in the granteersquos fiscal policies and within
effective dates for application of the new regulations to affected awards
Audit Threshold The regulation has increased the single audit threshold from $500000 to $750000 NFEs
receiving at least $750000 in federal funding from all sources (including Head Start Early
Head Start and Early Head Start-Child Care Partnership awards) are subject to the single
audit requirement for fiscal years beginning on or after Dec 26 2014
Supersession and Impact on the Head Start Act and Performance Standards
The new regulations when effective supersede all current audit circulars and cost principle
guidance currently codified under Title 2 Code of Federal Regulations (2 CFR 215 2 CFR 220
2 CFR 225 and 2 CFR 230) Grants management regulations at 45 CFR Part 74 and 45 CFR
Part 92 are also superseded NFEs should implement the new regulations as written but
anticipate codifying regulations from the Department of Health and Human Services (HHS) to
be found at a new 45 CFR Part 75 An issuance date is not known at this time Fiscal
18
Audits in Head Start
bull Sec 647 of the Head Start Act (HSA) requires that all entities receiving Head Start fundsndash keep records necessary to facilitate an effective audit
ndash submit a copy of the audit within 30 days of completion
bull Sec 641 of the HSA includes annual audits (going concern) within the criteria for competition under the Designation Renewal System implemented at 45 CFR Part 1303 ndashSubpart B
19
Audits in Head Start
bull Sec 642 of the HSA addresses responsibilities of the grantee governing body (board) and policy council includingndash Governing body has legal and fiscal responsibility
for the agency and shallbull be responsible for selection of the auditor who shall
report to the governing body
bull review and approve policies relating to the financial audit
bull monitor the agencyrsquos action to correct any audit findings
20
Audits in Head Start
bull Both the governing body and the policy council must be provided with a copy of the annual financial audit
bull Each agency must make available to the public a report published at least once in each fiscal year that discloses the results of the annual financial audit
21
Streamlined requirements Reduced the number of regulations Made them easier to understand Grouped related requirements Eliminated redundancy Reduced administrative burden Provided greater flexibility to
determine how best to achieve goals
22
Performance Standard Outcomes
Importance of Definitional Changes
bull An important difference in the new HSPPS is that all definitions are collected at 45 CFR sect13052
ndash Some definitions are the same some are brand new and some longstanding terms have new definitions
23
Example - New Definitions
bull Federal interest is a property right which secures the right of the federal awarding agency to recover the current fair market value of its percentage of participation in the cost of the facility in the event the facility is no longer used for Head Start purposes by the grantee or upon the disposition of the property When a grantee uses Head Start funds to purchase construct or renovate a facility or make mortgage payments it creates a federal interest The federal interest includes any portion of the cost of purchase construction or renovation contributed by or for the entity or a related donor organization to satisfy a matching requirement
bull Repair means maintenance that is necessary to keep a Head Start facility in working condition Repairs do not add significant value to the property or extend its useful life
24
Example - Changed Definitions
bull Old Major renovation means a structural change to the foundation roof floor or exterior or load-bearing walls of a facility or extension of an existing facility to increase its floor area Major renovation also means extensive alteration of an existing facility such as to significantly change its function and purpose even if such renovation does not include any structural change to the facility Major renovation also includes a renovation of any kind which has a cost exceeding the lesser of $200000 adjusted annually to reflect the percentage change in the Consumer Price Index for All Urban Consumers (issued by the Bureau of Labor Statistics) beginning one year after June 22003 or 25 percent of the total annual direct costs approved for the grantee by ACF for the budget period in which the application is made
bull New Major renovation means any individual or collecti[ve] renovation that has a cost equal to or exceeding $250000 It excludes minor renovations and repairs except when they are included in a purchase application
25
Early Childhood Learning and Knowledge Center (ECLKC)
OHS Early Childhood Learning and Knowledge Center
Click thestar to access ECLKC byhyperlink
Or go tohttpseclkcohsacfhhsgovhslc
26
Governmental Audit Quality Center
Auditing the Head Start
Program
29
Governmental Audit Quality Center
Event Materials Highlight Requirements
Unique to Head Start
The following basic single audit knowledge
is assumed
bull Auditing standards (GAAS and Government Auditing
Standards)
bull Uniform Administrative Requirements Cost
Principles and Audit Requirements for Federal
Awards at 2 CFR 200 (UG or Uniform Guidance)
bull OMB Compliance Supplement
bull Federal Audit Clearinghouse reporting
30
Governmental Audit Quality Center
Information Provided is not a Substitute for
Compliance Supplement or UG
Session focuses on program changes and
areas identified as common risks for Head
Start programs
bull An individual entityrsquos risk may be different
Auditor must still comply with the UG and
consider all requirements identified in the
Compliance Supplement
31
Governmental Audit Quality Center
2017 Updated Compliance Supplement
for Head Start An Overview
Program Objectives and Program Procedures
Matrix
Compliance Requirements - Updates
bull A Activities Allowed or Unallowed
bull E Eligibility for Subrecipients
bull F Equipment amp Real Property Management (Head Start
property requirements move to Special Tests and Provisions
bull J Program Income ndash Deleted
bull L3 Special Reporting (new report)
bull N Special Tests and Provisions (Property amp program
governance)
IV Other Information ndash Areas of risk
32
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Head Start Basics
9
Purpose Of Head Start
bull To promote the school readiness of low income children by enhancing their cognitive social and emotional development ndash
ndash in a learning environment that supports childrens growth in language literacy mathematics science social and emotional functioning creative arts physical skills and approaches to learning and
ndash through the provision of health educational nutritional social and other services that are determined based on family needs assessments to be necessary
10
50+ Years of Head Start
11
1965 - 2015
Click the star to seea Head Start timeline
Head Start Program Offerings
Head Start (HS)ndash Serves children ages 3-5 years old and their families
Early Head Start (EHS)ndash Serves pregnant mothers and children ages birth to 3 years
old and their families
Early Head Start ndash Child Care Partnerships (EHS ndash CCP) ndash Early Head Start delivered in partnership with providers
receiving child care subsidies
HS and EHS may be delivered in either center-based or home-based models EHS ndash CCP is center-based only but includes family child care homes
12
Head Start Enrollment
13
In 2015 Head Start served nearly one millionchildren ages 0 ndash 5 and pregnant women
Location of Grantees
14
Grantees and Grant Awards
bull Number of Granteesndash 1600 Head Start and Early Head Start grantees
nationwide including territories
bull Number of Grants ndash 2000 Head Start and Early Head Start grant awards
bull Award Amounts ndash Head Start awards range from
$150000 - $130000000
ndash Early Head Start awards range from $80000 -$18000000
15
Organization Types
16
Regional Offices
17
bull The Head Start Act 42 USC 9801 et seqespecially Sec 642
bull 45 CFR Part 75 Uniform Administrative Requirements Cost Principles and Audit Requirements for HHS awards (the Uniform Guidance)
bull Head Start Program Performance Standards (HSPPS) 45 CFR Part 1303
ndash Subpart B Financial Requirementsndash Subpart E Facilitiesndash Definitions 45 CFR 13052ndash Effective November 7 2016
Financial Laws and Regulations
ACF Administration for Children and
Families
US DEPARTMENT
OF HEALTH AND HUMAN SERVICES
1 Log No ACF-IM-HS-14-07 2 Issuance Date 12172014
3 Originating Office Office of Head Start
4 Key Words Grants Management Grants Administration
Administrative Requirements Cost Principles Audit
Requirements
INFORMATION MEMORANDUM
TO All Head Start and Early Head Start Grantees and Delegate Agencies
SUBJECT New Uniform Administrative Requirements Cost Principles and Audit Requirements for
Federal Awards INFORMATION The Office of Management and Budget (OMB) has issued new uniform administrative
requirements cost principles and audit requirements effective Dec 26 2014 which are
applicable to all Head Start and Early Head Start agencies and sub-recipients including
delegate agencies The Office of Head Start (OHS) is providing general guidance to assist
grantees in planning for implementation of the new requirements
Non-Federal Entities
The new uniform administrative requirements cost principles and audit requirements
(collectively the new fiscal regulations) replace use of the terms grantee grant funded
organization delegate agency and sub-recipient with uniform use of the inclusive term
non-federal entity (NFE) This Memorandum will use the terms non-federal entity receiving
Head Start funds or NFE to refer to all covered entities
Effective Date The new fiscal regulations are effective for awards (or award increments) made on or after
Dec 26 2014 Adoption of the regulations prior to Dec 26 2014 is not allowed After Dec 26
2014 NFEs may establish a single program-level effective date for application of the
regulations to existing Head Start awards for ease of implementation and administration The
program-level effective date must be reflected in the granteersquos fiscal policies and within
effective dates for application of the new regulations to affected awards
Audit Threshold The regulation has increased the single audit threshold from $500000 to $750000 NFEs
receiving at least $750000 in federal funding from all sources (including Head Start Early
Head Start and Early Head Start-Child Care Partnership awards) are subject to the single
audit requirement for fiscal years beginning on or after Dec 26 2014
Supersession and Impact on the Head Start Act and Performance Standards
The new regulations when effective supersede all current audit circulars and cost principle
guidance currently codified under Title 2 Code of Federal Regulations (2 CFR 215 2 CFR 220
2 CFR 225 and 2 CFR 230) Grants management regulations at 45 CFR Part 74 and 45 CFR
Part 92 are also superseded NFEs should implement the new regulations as written but
anticipate codifying regulations from the Department of Health and Human Services (HHS) to
be found at a new 45 CFR Part 75 An issuance date is not known at this time Fiscal
18
Audits in Head Start
bull Sec 647 of the Head Start Act (HSA) requires that all entities receiving Head Start fundsndash keep records necessary to facilitate an effective audit
ndash submit a copy of the audit within 30 days of completion
bull Sec 641 of the HSA includes annual audits (going concern) within the criteria for competition under the Designation Renewal System implemented at 45 CFR Part 1303 ndashSubpart B
19
Audits in Head Start
bull Sec 642 of the HSA addresses responsibilities of the grantee governing body (board) and policy council includingndash Governing body has legal and fiscal responsibility
for the agency and shallbull be responsible for selection of the auditor who shall
report to the governing body
bull review and approve policies relating to the financial audit
bull monitor the agencyrsquos action to correct any audit findings
20
Audits in Head Start
bull Both the governing body and the policy council must be provided with a copy of the annual financial audit
bull Each agency must make available to the public a report published at least once in each fiscal year that discloses the results of the annual financial audit
21
Streamlined requirements Reduced the number of regulations Made them easier to understand Grouped related requirements Eliminated redundancy Reduced administrative burden Provided greater flexibility to
determine how best to achieve goals
22
Performance Standard Outcomes
Importance of Definitional Changes
bull An important difference in the new HSPPS is that all definitions are collected at 45 CFR sect13052
ndash Some definitions are the same some are brand new and some longstanding terms have new definitions
23
Example - New Definitions
bull Federal interest is a property right which secures the right of the federal awarding agency to recover the current fair market value of its percentage of participation in the cost of the facility in the event the facility is no longer used for Head Start purposes by the grantee or upon the disposition of the property When a grantee uses Head Start funds to purchase construct or renovate a facility or make mortgage payments it creates a federal interest The federal interest includes any portion of the cost of purchase construction or renovation contributed by or for the entity or a related donor organization to satisfy a matching requirement
bull Repair means maintenance that is necessary to keep a Head Start facility in working condition Repairs do not add significant value to the property or extend its useful life
24
Example - Changed Definitions
bull Old Major renovation means a structural change to the foundation roof floor or exterior or load-bearing walls of a facility or extension of an existing facility to increase its floor area Major renovation also means extensive alteration of an existing facility such as to significantly change its function and purpose even if such renovation does not include any structural change to the facility Major renovation also includes a renovation of any kind which has a cost exceeding the lesser of $200000 adjusted annually to reflect the percentage change in the Consumer Price Index for All Urban Consumers (issued by the Bureau of Labor Statistics) beginning one year after June 22003 or 25 percent of the total annual direct costs approved for the grantee by ACF for the budget period in which the application is made
bull New Major renovation means any individual or collecti[ve] renovation that has a cost equal to or exceeding $250000 It excludes minor renovations and repairs except when they are included in a purchase application
25
Early Childhood Learning and Knowledge Center (ECLKC)
OHS Early Childhood Learning and Knowledge Center
Click thestar to access ECLKC byhyperlink
Or go tohttpseclkcohsacfhhsgovhslc
26
Governmental Audit Quality Center
Auditing the Head Start
Program
29
Governmental Audit Quality Center
Event Materials Highlight Requirements
Unique to Head Start
The following basic single audit knowledge
is assumed
bull Auditing standards (GAAS and Government Auditing
Standards)
bull Uniform Administrative Requirements Cost
Principles and Audit Requirements for Federal
Awards at 2 CFR 200 (UG or Uniform Guidance)
bull OMB Compliance Supplement
bull Federal Audit Clearinghouse reporting
30
Governmental Audit Quality Center
Information Provided is not a Substitute for
Compliance Supplement or UG
Session focuses on program changes and
areas identified as common risks for Head
Start programs
bull An individual entityrsquos risk may be different
Auditor must still comply with the UG and
consider all requirements identified in the
Compliance Supplement
31
Governmental Audit Quality Center
2017 Updated Compliance Supplement
for Head Start An Overview
Program Objectives and Program Procedures
Matrix
Compliance Requirements - Updates
bull A Activities Allowed or Unallowed
bull E Eligibility for Subrecipients
bull F Equipment amp Real Property Management (Head Start
property requirements move to Special Tests and Provisions
bull J Program Income ndash Deleted
bull L3 Special Reporting (new report)
bull N Special Tests and Provisions (Property amp program
governance)
IV Other Information ndash Areas of risk
32
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Purpose Of Head Start
bull To promote the school readiness of low income children by enhancing their cognitive social and emotional development ndash
ndash in a learning environment that supports childrens growth in language literacy mathematics science social and emotional functioning creative arts physical skills and approaches to learning and
ndash through the provision of health educational nutritional social and other services that are determined based on family needs assessments to be necessary
10
50+ Years of Head Start
11
1965 - 2015
Click the star to seea Head Start timeline
Head Start Program Offerings
Head Start (HS)ndash Serves children ages 3-5 years old and their families
Early Head Start (EHS)ndash Serves pregnant mothers and children ages birth to 3 years
old and their families
Early Head Start ndash Child Care Partnerships (EHS ndash CCP) ndash Early Head Start delivered in partnership with providers
receiving child care subsidies
HS and EHS may be delivered in either center-based or home-based models EHS ndash CCP is center-based only but includes family child care homes
12
Head Start Enrollment
13
In 2015 Head Start served nearly one millionchildren ages 0 ndash 5 and pregnant women
Location of Grantees
14
Grantees and Grant Awards
bull Number of Granteesndash 1600 Head Start and Early Head Start grantees
nationwide including territories
bull Number of Grants ndash 2000 Head Start and Early Head Start grant awards
bull Award Amounts ndash Head Start awards range from
$150000 - $130000000
ndash Early Head Start awards range from $80000 -$18000000
15
Organization Types
16
Regional Offices
17
bull The Head Start Act 42 USC 9801 et seqespecially Sec 642
bull 45 CFR Part 75 Uniform Administrative Requirements Cost Principles and Audit Requirements for HHS awards (the Uniform Guidance)
bull Head Start Program Performance Standards (HSPPS) 45 CFR Part 1303
ndash Subpart B Financial Requirementsndash Subpart E Facilitiesndash Definitions 45 CFR 13052ndash Effective November 7 2016
Financial Laws and Regulations
ACF Administration for Children and
Families
US DEPARTMENT
OF HEALTH AND HUMAN SERVICES
1 Log No ACF-IM-HS-14-07 2 Issuance Date 12172014
3 Originating Office Office of Head Start
4 Key Words Grants Management Grants Administration
Administrative Requirements Cost Principles Audit
Requirements
INFORMATION MEMORANDUM
TO All Head Start and Early Head Start Grantees and Delegate Agencies
SUBJECT New Uniform Administrative Requirements Cost Principles and Audit Requirements for
Federal Awards INFORMATION The Office of Management and Budget (OMB) has issued new uniform administrative
requirements cost principles and audit requirements effective Dec 26 2014 which are
applicable to all Head Start and Early Head Start agencies and sub-recipients including
delegate agencies The Office of Head Start (OHS) is providing general guidance to assist
grantees in planning for implementation of the new requirements
Non-Federal Entities
The new uniform administrative requirements cost principles and audit requirements
(collectively the new fiscal regulations) replace use of the terms grantee grant funded
organization delegate agency and sub-recipient with uniform use of the inclusive term
non-federal entity (NFE) This Memorandum will use the terms non-federal entity receiving
Head Start funds or NFE to refer to all covered entities
Effective Date The new fiscal regulations are effective for awards (or award increments) made on or after
Dec 26 2014 Adoption of the regulations prior to Dec 26 2014 is not allowed After Dec 26
2014 NFEs may establish a single program-level effective date for application of the
regulations to existing Head Start awards for ease of implementation and administration The
program-level effective date must be reflected in the granteersquos fiscal policies and within
effective dates for application of the new regulations to affected awards
Audit Threshold The regulation has increased the single audit threshold from $500000 to $750000 NFEs
receiving at least $750000 in federal funding from all sources (including Head Start Early
Head Start and Early Head Start-Child Care Partnership awards) are subject to the single
audit requirement for fiscal years beginning on or after Dec 26 2014
Supersession and Impact on the Head Start Act and Performance Standards
The new regulations when effective supersede all current audit circulars and cost principle
guidance currently codified under Title 2 Code of Federal Regulations (2 CFR 215 2 CFR 220
2 CFR 225 and 2 CFR 230) Grants management regulations at 45 CFR Part 74 and 45 CFR
Part 92 are also superseded NFEs should implement the new regulations as written but
anticipate codifying regulations from the Department of Health and Human Services (HHS) to
be found at a new 45 CFR Part 75 An issuance date is not known at this time Fiscal
18
Audits in Head Start
bull Sec 647 of the Head Start Act (HSA) requires that all entities receiving Head Start fundsndash keep records necessary to facilitate an effective audit
ndash submit a copy of the audit within 30 days of completion
bull Sec 641 of the HSA includes annual audits (going concern) within the criteria for competition under the Designation Renewal System implemented at 45 CFR Part 1303 ndashSubpart B
19
Audits in Head Start
bull Sec 642 of the HSA addresses responsibilities of the grantee governing body (board) and policy council includingndash Governing body has legal and fiscal responsibility
for the agency and shallbull be responsible for selection of the auditor who shall
report to the governing body
bull review and approve policies relating to the financial audit
bull monitor the agencyrsquos action to correct any audit findings
20
Audits in Head Start
bull Both the governing body and the policy council must be provided with a copy of the annual financial audit
bull Each agency must make available to the public a report published at least once in each fiscal year that discloses the results of the annual financial audit
21
Streamlined requirements Reduced the number of regulations Made them easier to understand Grouped related requirements Eliminated redundancy Reduced administrative burden Provided greater flexibility to
determine how best to achieve goals
22
Performance Standard Outcomes
Importance of Definitional Changes
bull An important difference in the new HSPPS is that all definitions are collected at 45 CFR sect13052
ndash Some definitions are the same some are brand new and some longstanding terms have new definitions
23
Example - New Definitions
bull Federal interest is a property right which secures the right of the federal awarding agency to recover the current fair market value of its percentage of participation in the cost of the facility in the event the facility is no longer used for Head Start purposes by the grantee or upon the disposition of the property When a grantee uses Head Start funds to purchase construct or renovate a facility or make mortgage payments it creates a federal interest The federal interest includes any portion of the cost of purchase construction or renovation contributed by or for the entity or a related donor organization to satisfy a matching requirement
bull Repair means maintenance that is necessary to keep a Head Start facility in working condition Repairs do not add significant value to the property or extend its useful life
24
Example - Changed Definitions
bull Old Major renovation means a structural change to the foundation roof floor or exterior or load-bearing walls of a facility or extension of an existing facility to increase its floor area Major renovation also means extensive alteration of an existing facility such as to significantly change its function and purpose even if such renovation does not include any structural change to the facility Major renovation also includes a renovation of any kind which has a cost exceeding the lesser of $200000 adjusted annually to reflect the percentage change in the Consumer Price Index for All Urban Consumers (issued by the Bureau of Labor Statistics) beginning one year after June 22003 or 25 percent of the total annual direct costs approved for the grantee by ACF for the budget period in which the application is made
bull New Major renovation means any individual or collecti[ve] renovation that has a cost equal to or exceeding $250000 It excludes minor renovations and repairs except when they are included in a purchase application
25
Early Childhood Learning and Knowledge Center (ECLKC)
OHS Early Childhood Learning and Knowledge Center
Click thestar to access ECLKC byhyperlink
Or go tohttpseclkcohsacfhhsgovhslc
26
Governmental Audit Quality Center
Auditing the Head Start
Program
29
Governmental Audit Quality Center
Event Materials Highlight Requirements
Unique to Head Start
The following basic single audit knowledge
is assumed
bull Auditing standards (GAAS and Government Auditing
Standards)
bull Uniform Administrative Requirements Cost
Principles and Audit Requirements for Federal
Awards at 2 CFR 200 (UG or Uniform Guidance)
bull OMB Compliance Supplement
bull Federal Audit Clearinghouse reporting
30
Governmental Audit Quality Center
Information Provided is not a Substitute for
Compliance Supplement or UG
Session focuses on program changes and
areas identified as common risks for Head
Start programs
bull An individual entityrsquos risk may be different
Auditor must still comply with the UG and
consider all requirements identified in the
Compliance Supplement
31
Governmental Audit Quality Center
2017 Updated Compliance Supplement
for Head Start An Overview
Program Objectives and Program Procedures
Matrix
Compliance Requirements - Updates
bull A Activities Allowed or Unallowed
bull E Eligibility for Subrecipients
bull F Equipment amp Real Property Management (Head Start
property requirements move to Special Tests and Provisions
bull J Program Income ndash Deleted
bull L3 Special Reporting (new report)
bull N Special Tests and Provisions (Property amp program
governance)
IV Other Information ndash Areas of risk
32
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
50+ Years of Head Start
11
1965 - 2015
Click the star to seea Head Start timeline
Head Start Program Offerings
Head Start (HS)ndash Serves children ages 3-5 years old and their families
Early Head Start (EHS)ndash Serves pregnant mothers and children ages birth to 3 years
old and their families
Early Head Start ndash Child Care Partnerships (EHS ndash CCP) ndash Early Head Start delivered in partnership with providers
receiving child care subsidies
HS and EHS may be delivered in either center-based or home-based models EHS ndash CCP is center-based only but includes family child care homes
12
Head Start Enrollment
13
In 2015 Head Start served nearly one millionchildren ages 0 ndash 5 and pregnant women
Location of Grantees
14
Grantees and Grant Awards
bull Number of Granteesndash 1600 Head Start and Early Head Start grantees
nationwide including territories
bull Number of Grants ndash 2000 Head Start and Early Head Start grant awards
bull Award Amounts ndash Head Start awards range from
$150000 - $130000000
ndash Early Head Start awards range from $80000 -$18000000
15
Organization Types
16
Regional Offices
17
bull The Head Start Act 42 USC 9801 et seqespecially Sec 642
bull 45 CFR Part 75 Uniform Administrative Requirements Cost Principles and Audit Requirements for HHS awards (the Uniform Guidance)
bull Head Start Program Performance Standards (HSPPS) 45 CFR Part 1303
ndash Subpart B Financial Requirementsndash Subpart E Facilitiesndash Definitions 45 CFR 13052ndash Effective November 7 2016
Financial Laws and Regulations
ACF Administration for Children and
Families
US DEPARTMENT
OF HEALTH AND HUMAN SERVICES
1 Log No ACF-IM-HS-14-07 2 Issuance Date 12172014
3 Originating Office Office of Head Start
4 Key Words Grants Management Grants Administration
Administrative Requirements Cost Principles Audit
Requirements
INFORMATION MEMORANDUM
TO All Head Start and Early Head Start Grantees and Delegate Agencies
SUBJECT New Uniform Administrative Requirements Cost Principles and Audit Requirements for
Federal Awards INFORMATION The Office of Management and Budget (OMB) has issued new uniform administrative
requirements cost principles and audit requirements effective Dec 26 2014 which are
applicable to all Head Start and Early Head Start agencies and sub-recipients including
delegate agencies The Office of Head Start (OHS) is providing general guidance to assist
grantees in planning for implementation of the new requirements
Non-Federal Entities
The new uniform administrative requirements cost principles and audit requirements
(collectively the new fiscal regulations) replace use of the terms grantee grant funded
organization delegate agency and sub-recipient with uniform use of the inclusive term
non-federal entity (NFE) This Memorandum will use the terms non-federal entity receiving
Head Start funds or NFE to refer to all covered entities
Effective Date The new fiscal regulations are effective for awards (or award increments) made on or after
Dec 26 2014 Adoption of the regulations prior to Dec 26 2014 is not allowed After Dec 26
2014 NFEs may establish a single program-level effective date for application of the
regulations to existing Head Start awards for ease of implementation and administration The
program-level effective date must be reflected in the granteersquos fiscal policies and within
effective dates for application of the new regulations to affected awards
Audit Threshold The regulation has increased the single audit threshold from $500000 to $750000 NFEs
receiving at least $750000 in federal funding from all sources (including Head Start Early
Head Start and Early Head Start-Child Care Partnership awards) are subject to the single
audit requirement for fiscal years beginning on or after Dec 26 2014
Supersession and Impact on the Head Start Act and Performance Standards
The new regulations when effective supersede all current audit circulars and cost principle
guidance currently codified under Title 2 Code of Federal Regulations (2 CFR 215 2 CFR 220
2 CFR 225 and 2 CFR 230) Grants management regulations at 45 CFR Part 74 and 45 CFR
Part 92 are also superseded NFEs should implement the new regulations as written but
anticipate codifying regulations from the Department of Health and Human Services (HHS) to
be found at a new 45 CFR Part 75 An issuance date is not known at this time Fiscal
18
Audits in Head Start
bull Sec 647 of the Head Start Act (HSA) requires that all entities receiving Head Start fundsndash keep records necessary to facilitate an effective audit
ndash submit a copy of the audit within 30 days of completion
bull Sec 641 of the HSA includes annual audits (going concern) within the criteria for competition under the Designation Renewal System implemented at 45 CFR Part 1303 ndashSubpart B
19
Audits in Head Start
bull Sec 642 of the HSA addresses responsibilities of the grantee governing body (board) and policy council includingndash Governing body has legal and fiscal responsibility
for the agency and shallbull be responsible for selection of the auditor who shall
report to the governing body
bull review and approve policies relating to the financial audit
bull monitor the agencyrsquos action to correct any audit findings
20
Audits in Head Start
bull Both the governing body and the policy council must be provided with a copy of the annual financial audit
bull Each agency must make available to the public a report published at least once in each fiscal year that discloses the results of the annual financial audit
21
Streamlined requirements Reduced the number of regulations Made them easier to understand Grouped related requirements Eliminated redundancy Reduced administrative burden Provided greater flexibility to
determine how best to achieve goals
22
Performance Standard Outcomes
Importance of Definitional Changes
bull An important difference in the new HSPPS is that all definitions are collected at 45 CFR sect13052
ndash Some definitions are the same some are brand new and some longstanding terms have new definitions
23
Example - New Definitions
bull Federal interest is a property right which secures the right of the federal awarding agency to recover the current fair market value of its percentage of participation in the cost of the facility in the event the facility is no longer used for Head Start purposes by the grantee or upon the disposition of the property When a grantee uses Head Start funds to purchase construct or renovate a facility or make mortgage payments it creates a federal interest The federal interest includes any portion of the cost of purchase construction or renovation contributed by or for the entity or a related donor organization to satisfy a matching requirement
bull Repair means maintenance that is necessary to keep a Head Start facility in working condition Repairs do not add significant value to the property or extend its useful life
24
Example - Changed Definitions
bull Old Major renovation means a structural change to the foundation roof floor or exterior or load-bearing walls of a facility or extension of an existing facility to increase its floor area Major renovation also means extensive alteration of an existing facility such as to significantly change its function and purpose even if such renovation does not include any structural change to the facility Major renovation also includes a renovation of any kind which has a cost exceeding the lesser of $200000 adjusted annually to reflect the percentage change in the Consumer Price Index for All Urban Consumers (issued by the Bureau of Labor Statistics) beginning one year after June 22003 or 25 percent of the total annual direct costs approved for the grantee by ACF for the budget period in which the application is made
bull New Major renovation means any individual or collecti[ve] renovation that has a cost equal to or exceeding $250000 It excludes minor renovations and repairs except when they are included in a purchase application
25
Early Childhood Learning and Knowledge Center (ECLKC)
OHS Early Childhood Learning and Knowledge Center
Click thestar to access ECLKC byhyperlink
Or go tohttpseclkcohsacfhhsgovhslc
26
Governmental Audit Quality Center
Auditing the Head Start
Program
29
Governmental Audit Quality Center
Event Materials Highlight Requirements
Unique to Head Start
The following basic single audit knowledge
is assumed
bull Auditing standards (GAAS and Government Auditing
Standards)
bull Uniform Administrative Requirements Cost
Principles and Audit Requirements for Federal
Awards at 2 CFR 200 (UG or Uniform Guidance)
bull OMB Compliance Supplement
bull Federal Audit Clearinghouse reporting
30
Governmental Audit Quality Center
Information Provided is not a Substitute for
Compliance Supplement or UG
Session focuses on program changes and
areas identified as common risks for Head
Start programs
bull An individual entityrsquos risk may be different
Auditor must still comply with the UG and
consider all requirements identified in the
Compliance Supplement
31
Governmental Audit Quality Center
2017 Updated Compliance Supplement
for Head Start An Overview
Program Objectives and Program Procedures
Matrix
Compliance Requirements - Updates
bull A Activities Allowed or Unallowed
bull E Eligibility for Subrecipients
bull F Equipment amp Real Property Management (Head Start
property requirements move to Special Tests and Provisions
bull J Program Income ndash Deleted
bull L3 Special Reporting (new report)
bull N Special Tests and Provisions (Property amp program
governance)
IV Other Information ndash Areas of risk
32
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Head Start Program Offerings
Head Start (HS)ndash Serves children ages 3-5 years old and their families
Early Head Start (EHS)ndash Serves pregnant mothers and children ages birth to 3 years
old and their families
Early Head Start ndash Child Care Partnerships (EHS ndash CCP) ndash Early Head Start delivered in partnership with providers
receiving child care subsidies
HS and EHS may be delivered in either center-based or home-based models EHS ndash CCP is center-based only but includes family child care homes
12
Head Start Enrollment
13
In 2015 Head Start served nearly one millionchildren ages 0 ndash 5 and pregnant women
Location of Grantees
14
Grantees and Grant Awards
bull Number of Granteesndash 1600 Head Start and Early Head Start grantees
nationwide including territories
bull Number of Grants ndash 2000 Head Start and Early Head Start grant awards
bull Award Amounts ndash Head Start awards range from
$150000 - $130000000
ndash Early Head Start awards range from $80000 -$18000000
15
Organization Types
16
Regional Offices
17
bull The Head Start Act 42 USC 9801 et seqespecially Sec 642
bull 45 CFR Part 75 Uniform Administrative Requirements Cost Principles and Audit Requirements for HHS awards (the Uniform Guidance)
bull Head Start Program Performance Standards (HSPPS) 45 CFR Part 1303
ndash Subpart B Financial Requirementsndash Subpart E Facilitiesndash Definitions 45 CFR 13052ndash Effective November 7 2016
Financial Laws and Regulations
ACF Administration for Children and
Families
US DEPARTMENT
OF HEALTH AND HUMAN SERVICES
1 Log No ACF-IM-HS-14-07 2 Issuance Date 12172014
3 Originating Office Office of Head Start
4 Key Words Grants Management Grants Administration
Administrative Requirements Cost Principles Audit
Requirements
INFORMATION MEMORANDUM
TO All Head Start and Early Head Start Grantees and Delegate Agencies
SUBJECT New Uniform Administrative Requirements Cost Principles and Audit Requirements for
Federal Awards INFORMATION The Office of Management and Budget (OMB) has issued new uniform administrative
requirements cost principles and audit requirements effective Dec 26 2014 which are
applicable to all Head Start and Early Head Start agencies and sub-recipients including
delegate agencies The Office of Head Start (OHS) is providing general guidance to assist
grantees in planning for implementation of the new requirements
Non-Federal Entities
The new uniform administrative requirements cost principles and audit requirements
(collectively the new fiscal regulations) replace use of the terms grantee grant funded
organization delegate agency and sub-recipient with uniform use of the inclusive term
non-federal entity (NFE) This Memorandum will use the terms non-federal entity receiving
Head Start funds or NFE to refer to all covered entities
Effective Date The new fiscal regulations are effective for awards (or award increments) made on or after
Dec 26 2014 Adoption of the regulations prior to Dec 26 2014 is not allowed After Dec 26
2014 NFEs may establish a single program-level effective date for application of the
regulations to existing Head Start awards for ease of implementation and administration The
program-level effective date must be reflected in the granteersquos fiscal policies and within
effective dates for application of the new regulations to affected awards
Audit Threshold The regulation has increased the single audit threshold from $500000 to $750000 NFEs
receiving at least $750000 in federal funding from all sources (including Head Start Early
Head Start and Early Head Start-Child Care Partnership awards) are subject to the single
audit requirement for fiscal years beginning on or after Dec 26 2014
Supersession and Impact on the Head Start Act and Performance Standards
The new regulations when effective supersede all current audit circulars and cost principle
guidance currently codified under Title 2 Code of Federal Regulations (2 CFR 215 2 CFR 220
2 CFR 225 and 2 CFR 230) Grants management regulations at 45 CFR Part 74 and 45 CFR
Part 92 are also superseded NFEs should implement the new regulations as written but
anticipate codifying regulations from the Department of Health and Human Services (HHS) to
be found at a new 45 CFR Part 75 An issuance date is not known at this time Fiscal
18
Audits in Head Start
bull Sec 647 of the Head Start Act (HSA) requires that all entities receiving Head Start fundsndash keep records necessary to facilitate an effective audit
ndash submit a copy of the audit within 30 days of completion
bull Sec 641 of the HSA includes annual audits (going concern) within the criteria for competition under the Designation Renewal System implemented at 45 CFR Part 1303 ndashSubpart B
19
Audits in Head Start
bull Sec 642 of the HSA addresses responsibilities of the grantee governing body (board) and policy council includingndash Governing body has legal and fiscal responsibility
for the agency and shallbull be responsible for selection of the auditor who shall
report to the governing body
bull review and approve policies relating to the financial audit
bull monitor the agencyrsquos action to correct any audit findings
20
Audits in Head Start
bull Both the governing body and the policy council must be provided with a copy of the annual financial audit
bull Each agency must make available to the public a report published at least once in each fiscal year that discloses the results of the annual financial audit
21
Streamlined requirements Reduced the number of regulations Made them easier to understand Grouped related requirements Eliminated redundancy Reduced administrative burden Provided greater flexibility to
determine how best to achieve goals
22
Performance Standard Outcomes
Importance of Definitional Changes
bull An important difference in the new HSPPS is that all definitions are collected at 45 CFR sect13052
ndash Some definitions are the same some are brand new and some longstanding terms have new definitions
23
Example - New Definitions
bull Federal interest is a property right which secures the right of the federal awarding agency to recover the current fair market value of its percentage of participation in the cost of the facility in the event the facility is no longer used for Head Start purposes by the grantee or upon the disposition of the property When a grantee uses Head Start funds to purchase construct or renovate a facility or make mortgage payments it creates a federal interest The federal interest includes any portion of the cost of purchase construction or renovation contributed by or for the entity or a related donor organization to satisfy a matching requirement
bull Repair means maintenance that is necessary to keep a Head Start facility in working condition Repairs do not add significant value to the property or extend its useful life
24
Example - Changed Definitions
bull Old Major renovation means a structural change to the foundation roof floor or exterior or load-bearing walls of a facility or extension of an existing facility to increase its floor area Major renovation also means extensive alteration of an existing facility such as to significantly change its function and purpose even if such renovation does not include any structural change to the facility Major renovation also includes a renovation of any kind which has a cost exceeding the lesser of $200000 adjusted annually to reflect the percentage change in the Consumer Price Index for All Urban Consumers (issued by the Bureau of Labor Statistics) beginning one year after June 22003 or 25 percent of the total annual direct costs approved for the grantee by ACF for the budget period in which the application is made
bull New Major renovation means any individual or collecti[ve] renovation that has a cost equal to or exceeding $250000 It excludes minor renovations and repairs except when they are included in a purchase application
25
Early Childhood Learning and Knowledge Center (ECLKC)
OHS Early Childhood Learning and Knowledge Center
Click thestar to access ECLKC byhyperlink
Or go tohttpseclkcohsacfhhsgovhslc
26
Governmental Audit Quality Center
Auditing the Head Start
Program
29
Governmental Audit Quality Center
Event Materials Highlight Requirements
Unique to Head Start
The following basic single audit knowledge
is assumed
bull Auditing standards (GAAS and Government Auditing
Standards)
bull Uniform Administrative Requirements Cost
Principles and Audit Requirements for Federal
Awards at 2 CFR 200 (UG or Uniform Guidance)
bull OMB Compliance Supplement
bull Federal Audit Clearinghouse reporting
30
Governmental Audit Quality Center
Information Provided is not a Substitute for
Compliance Supplement or UG
Session focuses on program changes and
areas identified as common risks for Head
Start programs
bull An individual entityrsquos risk may be different
Auditor must still comply with the UG and
consider all requirements identified in the
Compliance Supplement
31
Governmental Audit Quality Center
2017 Updated Compliance Supplement
for Head Start An Overview
Program Objectives and Program Procedures
Matrix
Compliance Requirements - Updates
bull A Activities Allowed or Unallowed
bull E Eligibility for Subrecipients
bull F Equipment amp Real Property Management (Head Start
property requirements move to Special Tests and Provisions
bull J Program Income ndash Deleted
bull L3 Special Reporting (new report)
bull N Special Tests and Provisions (Property amp program
governance)
IV Other Information ndash Areas of risk
32
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Head Start Enrollment
13
In 2015 Head Start served nearly one millionchildren ages 0 ndash 5 and pregnant women
Location of Grantees
14
Grantees and Grant Awards
bull Number of Granteesndash 1600 Head Start and Early Head Start grantees
nationwide including territories
bull Number of Grants ndash 2000 Head Start and Early Head Start grant awards
bull Award Amounts ndash Head Start awards range from
$150000 - $130000000
ndash Early Head Start awards range from $80000 -$18000000
15
Organization Types
16
Regional Offices
17
bull The Head Start Act 42 USC 9801 et seqespecially Sec 642
bull 45 CFR Part 75 Uniform Administrative Requirements Cost Principles and Audit Requirements for HHS awards (the Uniform Guidance)
bull Head Start Program Performance Standards (HSPPS) 45 CFR Part 1303
ndash Subpart B Financial Requirementsndash Subpart E Facilitiesndash Definitions 45 CFR 13052ndash Effective November 7 2016
Financial Laws and Regulations
ACF Administration for Children and
Families
US DEPARTMENT
OF HEALTH AND HUMAN SERVICES
1 Log No ACF-IM-HS-14-07 2 Issuance Date 12172014
3 Originating Office Office of Head Start
4 Key Words Grants Management Grants Administration
Administrative Requirements Cost Principles Audit
Requirements
INFORMATION MEMORANDUM
TO All Head Start and Early Head Start Grantees and Delegate Agencies
SUBJECT New Uniform Administrative Requirements Cost Principles and Audit Requirements for
Federal Awards INFORMATION The Office of Management and Budget (OMB) has issued new uniform administrative
requirements cost principles and audit requirements effective Dec 26 2014 which are
applicable to all Head Start and Early Head Start agencies and sub-recipients including
delegate agencies The Office of Head Start (OHS) is providing general guidance to assist
grantees in planning for implementation of the new requirements
Non-Federal Entities
The new uniform administrative requirements cost principles and audit requirements
(collectively the new fiscal regulations) replace use of the terms grantee grant funded
organization delegate agency and sub-recipient with uniform use of the inclusive term
non-federal entity (NFE) This Memorandum will use the terms non-federal entity receiving
Head Start funds or NFE to refer to all covered entities
Effective Date The new fiscal regulations are effective for awards (or award increments) made on or after
Dec 26 2014 Adoption of the regulations prior to Dec 26 2014 is not allowed After Dec 26
2014 NFEs may establish a single program-level effective date for application of the
regulations to existing Head Start awards for ease of implementation and administration The
program-level effective date must be reflected in the granteersquos fiscal policies and within
effective dates for application of the new regulations to affected awards
Audit Threshold The regulation has increased the single audit threshold from $500000 to $750000 NFEs
receiving at least $750000 in federal funding from all sources (including Head Start Early
Head Start and Early Head Start-Child Care Partnership awards) are subject to the single
audit requirement for fiscal years beginning on or after Dec 26 2014
Supersession and Impact on the Head Start Act and Performance Standards
The new regulations when effective supersede all current audit circulars and cost principle
guidance currently codified under Title 2 Code of Federal Regulations (2 CFR 215 2 CFR 220
2 CFR 225 and 2 CFR 230) Grants management regulations at 45 CFR Part 74 and 45 CFR
Part 92 are also superseded NFEs should implement the new regulations as written but
anticipate codifying regulations from the Department of Health and Human Services (HHS) to
be found at a new 45 CFR Part 75 An issuance date is not known at this time Fiscal
18
Audits in Head Start
bull Sec 647 of the Head Start Act (HSA) requires that all entities receiving Head Start fundsndash keep records necessary to facilitate an effective audit
ndash submit a copy of the audit within 30 days of completion
bull Sec 641 of the HSA includes annual audits (going concern) within the criteria for competition under the Designation Renewal System implemented at 45 CFR Part 1303 ndashSubpart B
19
Audits in Head Start
bull Sec 642 of the HSA addresses responsibilities of the grantee governing body (board) and policy council includingndash Governing body has legal and fiscal responsibility
for the agency and shallbull be responsible for selection of the auditor who shall
report to the governing body
bull review and approve policies relating to the financial audit
bull monitor the agencyrsquos action to correct any audit findings
20
Audits in Head Start
bull Both the governing body and the policy council must be provided with a copy of the annual financial audit
bull Each agency must make available to the public a report published at least once in each fiscal year that discloses the results of the annual financial audit
21
Streamlined requirements Reduced the number of regulations Made them easier to understand Grouped related requirements Eliminated redundancy Reduced administrative burden Provided greater flexibility to
determine how best to achieve goals
22
Performance Standard Outcomes
Importance of Definitional Changes
bull An important difference in the new HSPPS is that all definitions are collected at 45 CFR sect13052
ndash Some definitions are the same some are brand new and some longstanding terms have new definitions
23
Example - New Definitions
bull Federal interest is a property right which secures the right of the federal awarding agency to recover the current fair market value of its percentage of participation in the cost of the facility in the event the facility is no longer used for Head Start purposes by the grantee or upon the disposition of the property When a grantee uses Head Start funds to purchase construct or renovate a facility or make mortgage payments it creates a federal interest The federal interest includes any portion of the cost of purchase construction or renovation contributed by or for the entity or a related donor organization to satisfy a matching requirement
bull Repair means maintenance that is necessary to keep a Head Start facility in working condition Repairs do not add significant value to the property or extend its useful life
24
Example - Changed Definitions
bull Old Major renovation means a structural change to the foundation roof floor or exterior or load-bearing walls of a facility or extension of an existing facility to increase its floor area Major renovation also means extensive alteration of an existing facility such as to significantly change its function and purpose even if such renovation does not include any structural change to the facility Major renovation also includes a renovation of any kind which has a cost exceeding the lesser of $200000 adjusted annually to reflect the percentage change in the Consumer Price Index for All Urban Consumers (issued by the Bureau of Labor Statistics) beginning one year after June 22003 or 25 percent of the total annual direct costs approved for the grantee by ACF for the budget period in which the application is made
bull New Major renovation means any individual or collecti[ve] renovation that has a cost equal to or exceeding $250000 It excludes minor renovations and repairs except when they are included in a purchase application
25
Early Childhood Learning and Knowledge Center (ECLKC)
OHS Early Childhood Learning and Knowledge Center
Click thestar to access ECLKC byhyperlink
Or go tohttpseclkcohsacfhhsgovhslc
26
Governmental Audit Quality Center
Auditing the Head Start
Program
29
Governmental Audit Quality Center
Event Materials Highlight Requirements
Unique to Head Start
The following basic single audit knowledge
is assumed
bull Auditing standards (GAAS and Government Auditing
Standards)
bull Uniform Administrative Requirements Cost
Principles and Audit Requirements for Federal
Awards at 2 CFR 200 (UG or Uniform Guidance)
bull OMB Compliance Supplement
bull Federal Audit Clearinghouse reporting
30
Governmental Audit Quality Center
Information Provided is not a Substitute for
Compliance Supplement or UG
Session focuses on program changes and
areas identified as common risks for Head
Start programs
bull An individual entityrsquos risk may be different
Auditor must still comply with the UG and
consider all requirements identified in the
Compliance Supplement
31
Governmental Audit Quality Center
2017 Updated Compliance Supplement
for Head Start An Overview
Program Objectives and Program Procedures
Matrix
Compliance Requirements - Updates
bull A Activities Allowed or Unallowed
bull E Eligibility for Subrecipients
bull F Equipment amp Real Property Management (Head Start
property requirements move to Special Tests and Provisions
bull J Program Income ndash Deleted
bull L3 Special Reporting (new report)
bull N Special Tests and Provisions (Property amp program
governance)
IV Other Information ndash Areas of risk
32
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Location of Grantees
14
Grantees and Grant Awards
bull Number of Granteesndash 1600 Head Start and Early Head Start grantees
nationwide including territories
bull Number of Grants ndash 2000 Head Start and Early Head Start grant awards
bull Award Amounts ndash Head Start awards range from
$150000 - $130000000
ndash Early Head Start awards range from $80000 -$18000000
15
Organization Types
16
Regional Offices
17
bull The Head Start Act 42 USC 9801 et seqespecially Sec 642
bull 45 CFR Part 75 Uniform Administrative Requirements Cost Principles and Audit Requirements for HHS awards (the Uniform Guidance)
bull Head Start Program Performance Standards (HSPPS) 45 CFR Part 1303
ndash Subpart B Financial Requirementsndash Subpart E Facilitiesndash Definitions 45 CFR 13052ndash Effective November 7 2016
Financial Laws and Regulations
ACF Administration for Children and
Families
US DEPARTMENT
OF HEALTH AND HUMAN SERVICES
1 Log No ACF-IM-HS-14-07 2 Issuance Date 12172014
3 Originating Office Office of Head Start
4 Key Words Grants Management Grants Administration
Administrative Requirements Cost Principles Audit
Requirements
INFORMATION MEMORANDUM
TO All Head Start and Early Head Start Grantees and Delegate Agencies
SUBJECT New Uniform Administrative Requirements Cost Principles and Audit Requirements for
Federal Awards INFORMATION The Office of Management and Budget (OMB) has issued new uniform administrative
requirements cost principles and audit requirements effective Dec 26 2014 which are
applicable to all Head Start and Early Head Start agencies and sub-recipients including
delegate agencies The Office of Head Start (OHS) is providing general guidance to assist
grantees in planning for implementation of the new requirements
Non-Federal Entities
The new uniform administrative requirements cost principles and audit requirements
(collectively the new fiscal regulations) replace use of the terms grantee grant funded
organization delegate agency and sub-recipient with uniform use of the inclusive term
non-federal entity (NFE) This Memorandum will use the terms non-federal entity receiving
Head Start funds or NFE to refer to all covered entities
Effective Date The new fiscal regulations are effective for awards (or award increments) made on or after
Dec 26 2014 Adoption of the regulations prior to Dec 26 2014 is not allowed After Dec 26
2014 NFEs may establish a single program-level effective date for application of the
regulations to existing Head Start awards for ease of implementation and administration The
program-level effective date must be reflected in the granteersquos fiscal policies and within
effective dates for application of the new regulations to affected awards
Audit Threshold The regulation has increased the single audit threshold from $500000 to $750000 NFEs
receiving at least $750000 in federal funding from all sources (including Head Start Early
Head Start and Early Head Start-Child Care Partnership awards) are subject to the single
audit requirement for fiscal years beginning on or after Dec 26 2014
Supersession and Impact on the Head Start Act and Performance Standards
The new regulations when effective supersede all current audit circulars and cost principle
guidance currently codified under Title 2 Code of Federal Regulations (2 CFR 215 2 CFR 220
2 CFR 225 and 2 CFR 230) Grants management regulations at 45 CFR Part 74 and 45 CFR
Part 92 are also superseded NFEs should implement the new regulations as written but
anticipate codifying regulations from the Department of Health and Human Services (HHS) to
be found at a new 45 CFR Part 75 An issuance date is not known at this time Fiscal
18
Audits in Head Start
bull Sec 647 of the Head Start Act (HSA) requires that all entities receiving Head Start fundsndash keep records necessary to facilitate an effective audit
ndash submit a copy of the audit within 30 days of completion
bull Sec 641 of the HSA includes annual audits (going concern) within the criteria for competition under the Designation Renewal System implemented at 45 CFR Part 1303 ndashSubpart B
19
Audits in Head Start
bull Sec 642 of the HSA addresses responsibilities of the grantee governing body (board) and policy council includingndash Governing body has legal and fiscal responsibility
for the agency and shallbull be responsible for selection of the auditor who shall
report to the governing body
bull review and approve policies relating to the financial audit
bull monitor the agencyrsquos action to correct any audit findings
20
Audits in Head Start
bull Both the governing body and the policy council must be provided with a copy of the annual financial audit
bull Each agency must make available to the public a report published at least once in each fiscal year that discloses the results of the annual financial audit
21
Streamlined requirements Reduced the number of regulations Made them easier to understand Grouped related requirements Eliminated redundancy Reduced administrative burden Provided greater flexibility to
determine how best to achieve goals
22
Performance Standard Outcomes
Importance of Definitional Changes
bull An important difference in the new HSPPS is that all definitions are collected at 45 CFR sect13052
ndash Some definitions are the same some are brand new and some longstanding terms have new definitions
23
Example - New Definitions
bull Federal interest is a property right which secures the right of the federal awarding agency to recover the current fair market value of its percentage of participation in the cost of the facility in the event the facility is no longer used for Head Start purposes by the grantee or upon the disposition of the property When a grantee uses Head Start funds to purchase construct or renovate a facility or make mortgage payments it creates a federal interest The federal interest includes any portion of the cost of purchase construction or renovation contributed by or for the entity or a related donor organization to satisfy a matching requirement
bull Repair means maintenance that is necessary to keep a Head Start facility in working condition Repairs do not add significant value to the property or extend its useful life
24
Example - Changed Definitions
bull Old Major renovation means a structural change to the foundation roof floor or exterior or load-bearing walls of a facility or extension of an existing facility to increase its floor area Major renovation also means extensive alteration of an existing facility such as to significantly change its function and purpose even if such renovation does not include any structural change to the facility Major renovation also includes a renovation of any kind which has a cost exceeding the lesser of $200000 adjusted annually to reflect the percentage change in the Consumer Price Index for All Urban Consumers (issued by the Bureau of Labor Statistics) beginning one year after June 22003 or 25 percent of the total annual direct costs approved for the grantee by ACF for the budget period in which the application is made
bull New Major renovation means any individual or collecti[ve] renovation that has a cost equal to or exceeding $250000 It excludes minor renovations and repairs except when they are included in a purchase application
25
Early Childhood Learning and Knowledge Center (ECLKC)
OHS Early Childhood Learning and Knowledge Center
Click thestar to access ECLKC byhyperlink
Or go tohttpseclkcohsacfhhsgovhslc
26
Governmental Audit Quality Center
Auditing the Head Start
Program
29
Governmental Audit Quality Center
Event Materials Highlight Requirements
Unique to Head Start
The following basic single audit knowledge
is assumed
bull Auditing standards (GAAS and Government Auditing
Standards)
bull Uniform Administrative Requirements Cost
Principles and Audit Requirements for Federal
Awards at 2 CFR 200 (UG or Uniform Guidance)
bull OMB Compliance Supplement
bull Federal Audit Clearinghouse reporting
30
Governmental Audit Quality Center
Information Provided is not a Substitute for
Compliance Supplement or UG
Session focuses on program changes and
areas identified as common risks for Head
Start programs
bull An individual entityrsquos risk may be different
Auditor must still comply with the UG and
consider all requirements identified in the
Compliance Supplement
31
Governmental Audit Quality Center
2017 Updated Compliance Supplement
for Head Start An Overview
Program Objectives and Program Procedures
Matrix
Compliance Requirements - Updates
bull A Activities Allowed or Unallowed
bull E Eligibility for Subrecipients
bull F Equipment amp Real Property Management (Head Start
property requirements move to Special Tests and Provisions
bull J Program Income ndash Deleted
bull L3 Special Reporting (new report)
bull N Special Tests and Provisions (Property amp program
governance)
IV Other Information ndash Areas of risk
32
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Grantees and Grant Awards
bull Number of Granteesndash 1600 Head Start and Early Head Start grantees
nationwide including territories
bull Number of Grants ndash 2000 Head Start and Early Head Start grant awards
bull Award Amounts ndash Head Start awards range from
$150000 - $130000000
ndash Early Head Start awards range from $80000 -$18000000
15
Organization Types
16
Regional Offices
17
bull The Head Start Act 42 USC 9801 et seqespecially Sec 642
bull 45 CFR Part 75 Uniform Administrative Requirements Cost Principles and Audit Requirements for HHS awards (the Uniform Guidance)
bull Head Start Program Performance Standards (HSPPS) 45 CFR Part 1303
ndash Subpart B Financial Requirementsndash Subpart E Facilitiesndash Definitions 45 CFR 13052ndash Effective November 7 2016
Financial Laws and Regulations
ACF Administration for Children and
Families
US DEPARTMENT
OF HEALTH AND HUMAN SERVICES
1 Log No ACF-IM-HS-14-07 2 Issuance Date 12172014
3 Originating Office Office of Head Start
4 Key Words Grants Management Grants Administration
Administrative Requirements Cost Principles Audit
Requirements
INFORMATION MEMORANDUM
TO All Head Start and Early Head Start Grantees and Delegate Agencies
SUBJECT New Uniform Administrative Requirements Cost Principles and Audit Requirements for
Federal Awards INFORMATION The Office of Management and Budget (OMB) has issued new uniform administrative
requirements cost principles and audit requirements effective Dec 26 2014 which are
applicable to all Head Start and Early Head Start agencies and sub-recipients including
delegate agencies The Office of Head Start (OHS) is providing general guidance to assist
grantees in planning for implementation of the new requirements
Non-Federal Entities
The new uniform administrative requirements cost principles and audit requirements
(collectively the new fiscal regulations) replace use of the terms grantee grant funded
organization delegate agency and sub-recipient with uniform use of the inclusive term
non-federal entity (NFE) This Memorandum will use the terms non-federal entity receiving
Head Start funds or NFE to refer to all covered entities
Effective Date The new fiscal regulations are effective for awards (or award increments) made on or after
Dec 26 2014 Adoption of the regulations prior to Dec 26 2014 is not allowed After Dec 26
2014 NFEs may establish a single program-level effective date for application of the
regulations to existing Head Start awards for ease of implementation and administration The
program-level effective date must be reflected in the granteersquos fiscal policies and within
effective dates for application of the new regulations to affected awards
Audit Threshold The regulation has increased the single audit threshold from $500000 to $750000 NFEs
receiving at least $750000 in federal funding from all sources (including Head Start Early
Head Start and Early Head Start-Child Care Partnership awards) are subject to the single
audit requirement for fiscal years beginning on or after Dec 26 2014
Supersession and Impact on the Head Start Act and Performance Standards
The new regulations when effective supersede all current audit circulars and cost principle
guidance currently codified under Title 2 Code of Federal Regulations (2 CFR 215 2 CFR 220
2 CFR 225 and 2 CFR 230) Grants management regulations at 45 CFR Part 74 and 45 CFR
Part 92 are also superseded NFEs should implement the new regulations as written but
anticipate codifying regulations from the Department of Health and Human Services (HHS) to
be found at a new 45 CFR Part 75 An issuance date is not known at this time Fiscal
18
Audits in Head Start
bull Sec 647 of the Head Start Act (HSA) requires that all entities receiving Head Start fundsndash keep records necessary to facilitate an effective audit
ndash submit a copy of the audit within 30 days of completion
bull Sec 641 of the HSA includes annual audits (going concern) within the criteria for competition under the Designation Renewal System implemented at 45 CFR Part 1303 ndashSubpart B
19
Audits in Head Start
bull Sec 642 of the HSA addresses responsibilities of the grantee governing body (board) and policy council includingndash Governing body has legal and fiscal responsibility
for the agency and shallbull be responsible for selection of the auditor who shall
report to the governing body
bull review and approve policies relating to the financial audit
bull monitor the agencyrsquos action to correct any audit findings
20
Audits in Head Start
bull Both the governing body and the policy council must be provided with a copy of the annual financial audit
bull Each agency must make available to the public a report published at least once in each fiscal year that discloses the results of the annual financial audit
21
Streamlined requirements Reduced the number of regulations Made them easier to understand Grouped related requirements Eliminated redundancy Reduced administrative burden Provided greater flexibility to
determine how best to achieve goals
22
Performance Standard Outcomes
Importance of Definitional Changes
bull An important difference in the new HSPPS is that all definitions are collected at 45 CFR sect13052
ndash Some definitions are the same some are brand new and some longstanding terms have new definitions
23
Example - New Definitions
bull Federal interest is a property right which secures the right of the federal awarding agency to recover the current fair market value of its percentage of participation in the cost of the facility in the event the facility is no longer used for Head Start purposes by the grantee or upon the disposition of the property When a grantee uses Head Start funds to purchase construct or renovate a facility or make mortgage payments it creates a federal interest The federal interest includes any portion of the cost of purchase construction or renovation contributed by or for the entity or a related donor organization to satisfy a matching requirement
bull Repair means maintenance that is necessary to keep a Head Start facility in working condition Repairs do not add significant value to the property or extend its useful life
24
Example - Changed Definitions
bull Old Major renovation means a structural change to the foundation roof floor or exterior or load-bearing walls of a facility or extension of an existing facility to increase its floor area Major renovation also means extensive alteration of an existing facility such as to significantly change its function and purpose even if such renovation does not include any structural change to the facility Major renovation also includes a renovation of any kind which has a cost exceeding the lesser of $200000 adjusted annually to reflect the percentage change in the Consumer Price Index for All Urban Consumers (issued by the Bureau of Labor Statistics) beginning one year after June 22003 or 25 percent of the total annual direct costs approved for the grantee by ACF for the budget period in which the application is made
bull New Major renovation means any individual or collecti[ve] renovation that has a cost equal to or exceeding $250000 It excludes minor renovations and repairs except when they are included in a purchase application
25
Early Childhood Learning and Knowledge Center (ECLKC)
OHS Early Childhood Learning and Knowledge Center
Click thestar to access ECLKC byhyperlink
Or go tohttpseclkcohsacfhhsgovhslc
26
Governmental Audit Quality Center
Auditing the Head Start
Program
29
Governmental Audit Quality Center
Event Materials Highlight Requirements
Unique to Head Start
The following basic single audit knowledge
is assumed
bull Auditing standards (GAAS and Government Auditing
Standards)
bull Uniform Administrative Requirements Cost
Principles and Audit Requirements for Federal
Awards at 2 CFR 200 (UG or Uniform Guidance)
bull OMB Compliance Supplement
bull Federal Audit Clearinghouse reporting
30
Governmental Audit Quality Center
Information Provided is not a Substitute for
Compliance Supplement or UG
Session focuses on program changes and
areas identified as common risks for Head
Start programs
bull An individual entityrsquos risk may be different
Auditor must still comply with the UG and
consider all requirements identified in the
Compliance Supplement
31
Governmental Audit Quality Center
2017 Updated Compliance Supplement
for Head Start An Overview
Program Objectives and Program Procedures
Matrix
Compliance Requirements - Updates
bull A Activities Allowed or Unallowed
bull E Eligibility for Subrecipients
bull F Equipment amp Real Property Management (Head Start
property requirements move to Special Tests and Provisions
bull J Program Income ndash Deleted
bull L3 Special Reporting (new report)
bull N Special Tests and Provisions (Property amp program
governance)
IV Other Information ndash Areas of risk
32
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Organization Types
16
Regional Offices
17
bull The Head Start Act 42 USC 9801 et seqespecially Sec 642
bull 45 CFR Part 75 Uniform Administrative Requirements Cost Principles and Audit Requirements for HHS awards (the Uniform Guidance)
bull Head Start Program Performance Standards (HSPPS) 45 CFR Part 1303
ndash Subpart B Financial Requirementsndash Subpart E Facilitiesndash Definitions 45 CFR 13052ndash Effective November 7 2016
Financial Laws and Regulations
ACF Administration for Children and
Families
US DEPARTMENT
OF HEALTH AND HUMAN SERVICES
1 Log No ACF-IM-HS-14-07 2 Issuance Date 12172014
3 Originating Office Office of Head Start
4 Key Words Grants Management Grants Administration
Administrative Requirements Cost Principles Audit
Requirements
INFORMATION MEMORANDUM
TO All Head Start and Early Head Start Grantees and Delegate Agencies
SUBJECT New Uniform Administrative Requirements Cost Principles and Audit Requirements for
Federal Awards INFORMATION The Office of Management and Budget (OMB) has issued new uniform administrative
requirements cost principles and audit requirements effective Dec 26 2014 which are
applicable to all Head Start and Early Head Start agencies and sub-recipients including
delegate agencies The Office of Head Start (OHS) is providing general guidance to assist
grantees in planning for implementation of the new requirements
Non-Federal Entities
The new uniform administrative requirements cost principles and audit requirements
(collectively the new fiscal regulations) replace use of the terms grantee grant funded
organization delegate agency and sub-recipient with uniform use of the inclusive term
non-federal entity (NFE) This Memorandum will use the terms non-federal entity receiving
Head Start funds or NFE to refer to all covered entities
Effective Date The new fiscal regulations are effective for awards (or award increments) made on or after
Dec 26 2014 Adoption of the regulations prior to Dec 26 2014 is not allowed After Dec 26
2014 NFEs may establish a single program-level effective date for application of the
regulations to existing Head Start awards for ease of implementation and administration The
program-level effective date must be reflected in the granteersquos fiscal policies and within
effective dates for application of the new regulations to affected awards
Audit Threshold The regulation has increased the single audit threshold from $500000 to $750000 NFEs
receiving at least $750000 in federal funding from all sources (including Head Start Early
Head Start and Early Head Start-Child Care Partnership awards) are subject to the single
audit requirement for fiscal years beginning on or after Dec 26 2014
Supersession and Impact on the Head Start Act and Performance Standards
The new regulations when effective supersede all current audit circulars and cost principle
guidance currently codified under Title 2 Code of Federal Regulations (2 CFR 215 2 CFR 220
2 CFR 225 and 2 CFR 230) Grants management regulations at 45 CFR Part 74 and 45 CFR
Part 92 are also superseded NFEs should implement the new regulations as written but
anticipate codifying regulations from the Department of Health and Human Services (HHS) to
be found at a new 45 CFR Part 75 An issuance date is not known at this time Fiscal
18
Audits in Head Start
bull Sec 647 of the Head Start Act (HSA) requires that all entities receiving Head Start fundsndash keep records necessary to facilitate an effective audit
ndash submit a copy of the audit within 30 days of completion
bull Sec 641 of the HSA includes annual audits (going concern) within the criteria for competition under the Designation Renewal System implemented at 45 CFR Part 1303 ndashSubpart B
19
Audits in Head Start
bull Sec 642 of the HSA addresses responsibilities of the grantee governing body (board) and policy council includingndash Governing body has legal and fiscal responsibility
for the agency and shallbull be responsible for selection of the auditor who shall
report to the governing body
bull review and approve policies relating to the financial audit
bull monitor the agencyrsquos action to correct any audit findings
20
Audits in Head Start
bull Both the governing body and the policy council must be provided with a copy of the annual financial audit
bull Each agency must make available to the public a report published at least once in each fiscal year that discloses the results of the annual financial audit
21
Streamlined requirements Reduced the number of regulations Made them easier to understand Grouped related requirements Eliminated redundancy Reduced administrative burden Provided greater flexibility to
determine how best to achieve goals
22
Performance Standard Outcomes
Importance of Definitional Changes
bull An important difference in the new HSPPS is that all definitions are collected at 45 CFR sect13052
ndash Some definitions are the same some are brand new and some longstanding terms have new definitions
23
Example - New Definitions
bull Federal interest is a property right which secures the right of the federal awarding agency to recover the current fair market value of its percentage of participation in the cost of the facility in the event the facility is no longer used for Head Start purposes by the grantee or upon the disposition of the property When a grantee uses Head Start funds to purchase construct or renovate a facility or make mortgage payments it creates a federal interest The federal interest includes any portion of the cost of purchase construction or renovation contributed by or for the entity or a related donor organization to satisfy a matching requirement
bull Repair means maintenance that is necessary to keep a Head Start facility in working condition Repairs do not add significant value to the property or extend its useful life
24
Example - Changed Definitions
bull Old Major renovation means a structural change to the foundation roof floor or exterior or load-bearing walls of a facility or extension of an existing facility to increase its floor area Major renovation also means extensive alteration of an existing facility such as to significantly change its function and purpose even if such renovation does not include any structural change to the facility Major renovation also includes a renovation of any kind which has a cost exceeding the lesser of $200000 adjusted annually to reflect the percentage change in the Consumer Price Index for All Urban Consumers (issued by the Bureau of Labor Statistics) beginning one year after June 22003 or 25 percent of the total annual direct costs approved for the grantee by ACF for the budget period in which the application is made
bull New Major renovation means any individual or collecti[ve] renovation that has a cost equal to or exceeding $250000 It excludes minor renovations and repairs except when they are included in a purchase application
25
Early Childhood Learning and Knowledge Center (ECLKC)
OHS Early Childhood Learning and Knowledge Center
Click thestar to access ECLKC byhyperlink
Or go tohttpseclkcohsacfhhsgovhslc
26
Governmental Audit Quality Center
Auditing the Head Start
Program
29
Governmental Audit Quality Center
Event Materials Highlight Requirements
Unique to Head Start
The following basic single audit knowledge
is assumed
bull Auditing standards (GAAS and Government Auditing
Standards)
bull Uniform Administrative Requirements Cost
Principles and Audit Requirements for Federal
Awards at 2 CFR 200 (UG or Uniform Guidance)
bull OMB Compliance Supplement
bull Federal Audit Clearinghouse reporting
30
Governmental Audit Quality Center
Information Provided is not a Substitute for
Compliance Supplement or UG
Session focuses on program changes and
areas identified as common risks for Head
Start programs
bull An individual entityrsquos risk may be different
Auditor must still comply with the UG and
consider all requirements identified in the
Compliance Supplement
31
Governmental Audit Quality Center
2017 Updated Compliance Supplement
for Head Start An Overview
Program Objectives and Program Procedures
Matrix
Compliance Requirements - Updates
bull A Activities Allowed or Unallowed
bull E Eligibility for Subrecipients
bull F Equipment amp Real Property Management (Head Start
property requirements move to Special Tests and Provisions
bull J Program Income ndash Deleted
bull L3 Special Reporting (new report)
bull N Special Tests and Provisions (Property amp program
governance)
IV Other Information ndash Areas of risk
32
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Regional Offices
17
bull The Head Start Act 42 USC 9801 et seqespecially Sec 642
bull 45 CFR Part 75 Uniform Administrative Requirements Cost Principles and Audit Requirements for HHS awards (the Uniform Guidance)
bull Head Start Program Performance Standards (HSPPS) 45 CFR Part 1303
ndash Subpart B Financial Requirementsndash Subpart E Facilitiesndash Definitions 45 CFR 13052ndash Effective November 7 2016
Financial Laws and Regulations
ACF Administration for Children and
Families
US DEPARTMENT
OF HEALTH AND HUMAN SERVICES
1 Log No ACF-IM-HS-14-07 2 Issuance Date 12172014
3 Originating Office Office of Head Start
4 Key Words Grants Management Grants Administration
Administrative Requirements Cost Principles Audit
Requirements
INFORMATION MEMORANDUM
TO All Head Start and Early Head Start Grantees and Delegate Agencies
SUBJECT New Uniform Administrative Requirements Cost Principles and Audit Requirements for
Federal Awards INFORMATION The Office of Management and Budget (OMB) has issued new uniform administrative
requirements cost principles and audit requirements effective Dec 26 2014 which are
applicable to all Head Start and Early Head Start agencies and sub-recipients including
delegate agencies The Office of Head Start (OHS) is providing general guidance to assist
grantees in planning for implementation of the new requirements
Non-Federal Entities
The new uniform administrative requirements cost principles and audit requirements
(collectively the new fiscal regulations) replace use of the terms grantee grant funded
organization delegate agency and sub-recipient with uniform use of the inclusive term
non-federal entity (NFE) This Memorandum will use the terms non-federal entity receiving
Head Start funds or NFE to refer to all covered entities
Effective Date The new fiscal regulations are effective for awards (or award increments) made on or after
Dec 26 2014 Adoption of the regulations prior to Dec 26 2014 is not allowed After Dec 26
2014 NFEs may establish a single program-level effective date for application of the
regulations to existing Head Start awards for ease of implementation and administration The
program-level effective date must be reflected in the granteersquos fiscal policies and within
effective dates for application of the new regulations to affected awards
Audit Threshold The regulation has increased the single audit threshold from $500000 to $750000 NFEs
receiving at least $750000 in federal funding from all sources (including Head Start Early
Head Start and Early Head Start-Child Care Partnership awards) are subject to the single
audit requirement for fiscal years beginning on or after Dec 26 2014
Supersession and Impact on the Head Start Act and Performance Standards
The new regulations when effective supersede all current audit circulars and cost principle
guidance currently codified under Title 2 Code of Federal Regulations (2 CFR 215 2 CFR 220
2 CFR 225 and 2 CFR 230) Grants management regulations at 45 CFR Part 74 and 45 CFR
Part 92 are also superseded NFEs should implement the new regulations as written but
anticipate codifying regulations from the Department of Health and Human Services (HHS) to
be found at a new 45 CFR Part 75 An issuance date is not known at this time Fiscal
18
Audits in Head Start
bull Sec 647 of the Head Start Act (HSA) requires that all entities receiving Head Start fundsndash keep records necessary to facilitate an effective audit
ndash submit a copy of the audit within 30 days of completion
bull Sec 641 of the HSA includes annual audits (going concern) within the criteria for competition under the Designation Renewal System implemented at 45 CFR Part 1303 ndashSubpart B
19
Audits in Head Start
bull Sec 642 of the HSA addresses responsibilities of the grantee governing body (board) and policy council includingndash Governing body has legal and fiscal responsibility
for the agency and shallbull be responsible for selection of the auditor who shall
report to the governing body
bull review and approve policies relating to the financial audit
bull monitor the agencyrsquos action to correct any audit findings
20
Audits in Head Start
bull Both the governing body and the policy council must be provided with a copy of the annual financial audit
bull Each agency must make available to the public a report published at least once in each fiscal year that discloses the results of the annual financial audit
21
Streamlined requirements Reduced the number of regulations Made them easier to understand Grouped related requirements Eliminated redundancy Reduced administrative burden Provided greater flexibility to
determine how best to achieve goals
22
Performance Standard Outcomes
Importance of Definitional Changes
bull An important difference in the new HSPPS is that all definitions are collected at 45 CFR sect13052
ndash Some definitions are the same some are brand new and some longstanding terms have new definitions
23
Example - New Definitions
bull Federal interest is a property right which secures the right of the federal awarding agency to recover the current fair market value of its percentage of participation in the cost of the facility in the event the facility is no longer used for Head Start purposes by the grantee or upon the disposition of the property When a grantee uses Head Start funds to purchase construct or renovate a facility or make mortgage payments it creates a federal interest The federal interest includes any portion of the cost of purchase construction or renovation contributed by or for the entity or a related donor organization to satisfy a matching requirement
bull Repair means maintenance that is necessary to keep a Head Start facility in working condition Repairs do not add significant value to the property or extend its useful life
24
Example - Changed Definitions
bull Old Major renovation means a structural change to the foundation roof floor or exterior or load-bearing walls of a facility or extension of an existing facility to increase its floor area Major renovation also means extensive alteration of an existing facility such as to significantly change its function and purpose even if such renovation does not include any structural change to the facility Major renovation also includes a renovation of any kind which has a cost exceeding the lesser of $200000 adjusted annually to reflect the percentage change in the Consumer Price Index for All Urban Consumers (issued by the Bureau of Labor Statistics) beginning one year after June 22003 or 25 percent of the total annual direct costs approved for the grantee by ACF for the budget period in which the application is made
bull New Major renovation means any individual or collecti[ve] renovation that has a cost equal to or exceeding $250000 It excludes minor renovations and repairs except when they are included in a purchase application
25
Early Childhood Learning and Knowledge Center (ECLKC)
OHS Early Childhood Learning and Knowledge Center
Click thestar to access ECLKC byhyperlink
Or go tohttpseclkcohsacfhhsgovhslc
26
Governmental Audit Quality Center
Auditing the Head Start
Program
29
Governmental Audit Quality Center
Event Materials Highlight Requirements
Unique to Head Start
The following basic single audit knowledge
is assumed
bull Auditing standards (GAAS and Government Auditing
Standards)
bull Uniform Administrative Requirements Cost
Principles and Audit Requirements for Federal
Awards at 2 CFR 200 (UG or Uniform Guidance)
bull OMB Compliance Supplement
bull Federal Audit Clearinghouse reporting
30
Governmental Audit Quality Center
Information Provided is not a Substitute for
Compliance Supplement or UG
Session focuses on program changes and
areas identified as common risks for Head
Start programs
bull An individual entityrsquos risk may be different
Auditor must still comply with the UG and
consider all requirements identified in the
Compliance Supplement
31
Governmental Audit Quality Center
2017 Updated Compliance Supplement
for Head Start An Overview
Program Objectives and Program Procedures
Matrix
Compliance Requirements - Updates
bull A Activities Allowed or Unallowed
bull E Eligibility for Subrecipients
bull F Equipment amp Real Property Management (Head Start
property requirements move to Special Tests and Provisions
bull J Program Income ndash Deleted
bull L3 Special Reporting (new report)
bull N Special Tests and Provisions (Property amp program
governance)
IV Other Information ndash Areas of risk
32
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
bull The Head Start Act 42 USC 9801 et seqespecially Sec 642
bull 45 CFR Part 75 Uniform Administrative Requirements Cost Principles and Audit Requirements for HHS awards (the Uniform Guidance)
bull Head Start Program Performance Standards (HSPPS) 45 CFR Part 1303
ndash Subpart B Financial Requirementsndash Subpart E Facilitiesndash Definitions 45 CFR 13052ndash Effective November 7 2016
Financial Laws and Regulations
ACF Administration for Children and
Families
US DEPARTMENT
OF HEALTH AND HUMAN SERVICES
1 Log No ACF-IM-HS-14-07 2 Issuance Date 12172014
3 Originating Office Office of Head Start
4 Key Words Grants Management Grants Administration
Administrative Requirements Cost Principles Audit
Requirements
INFORMATION MEMORANDUM
TO All Head Start and Early Head Start Grantees and Delegate Agencies
SUBJECT New Uniform Administrative Requirements Cost Principles and Audit Requirements for
Federal Awards INFORMATION The Office of Management and Budget (OMB) has issued new uniform administrative
requirements cost principles and audit requirements effective Dec 26 2014 which are
applicable to all Head Start and Early Head Start agencies and sub-recipients including
delegate agencies The Office of Head Start (OHS) is providing general guidance to assist
grantees in planning for implementation of the new requirements
Non-Federal Entities
The new uniform administrative requirements cost principles and audit requirements
(collectively the new fiscal regulations) replace use of the terms grantee grant funded
organization delegate agency and sub-recipient with uniform use of the inclusive term
non-federal entity (NFE) This Memorandum will use the terms non-federal entity receiving
Head Start funds or NFE to refer to all covered entities
Effective Date The new fiscal regulations are effective for awards (or award increments) made on or after
Dec 26 2014 Adoption of the regulations prior to Dec 26 2014 is not allowed After Dec 26
2014 NFEs may establish a single program-level effective date for application of the
regulations to existing Head Start awards for ease of implementation and administration The
program-level effective date must be reflected in the granteersquos fiscal policies and within
effective dates for application of the new regulations to affected awards
Audit Threshold The regulation has increased the single audit threshold from $500000 to $750000 NFEs
receiving at least $750000 in federal funding from all sources (including Head Start Early
Head Start and Early Head Start-Child Care Partnership awards) are subject to the single
audit requirement for fiscal years beginning on or after Dec 26 2014
Supersession and Impact on the Head Start Act and Performance Standards
The new regulations when effective supersede all current audit circulars and cost principle
guidance currently codified under Title 2 Code of Federal Regulations (2 CFR 215 2 CFR 220
2 CFR 225 and 2 CFR 230) Grants management regulations at 45 CFR Part 74 and 45 CFR
Part 92 are also superseded NFEs should implement the new regulations as written but
anticipate codifying regulations from the Department of Health and Human Services (HHS) to
be found at a new 45 CFR Part 75 An issuance date is not known at this time Fiscal
18
Audits in Head Start
bull Sec 647 of the Head Start Act (HSA) requires that all entities receiving Head Start fundsndash keep records necessary to facilitate an effective audit
ndash submit a copy of the audit within 30 days of completion
bull Sec 641 of the HSA includes annual audits (going concern) within the criteria for competition under the Designation Renewal System implemented at 45 CFR Part 1303 ndashSubpart B
19
Audits in Head Start
bull Sec 642 of the HSA addresses responsibilities of the grantee governing body (board) and policy council includingndash Governing body has legal and fiscal responsibility
for the agency and shallbull be responsible for selection of the auditor who shall
report to the governing body
bull review and approve policies relating to the financial audit
bull monitor the agencyrsquos action to correct any audit findings
20
Audits in Head Start
bull Both the governing body and the policy council must be provided with a copy of the annual financial audit
bull Each agency must make available to the public a report published at least once in each fiscal year that discloses the results of the annual financial audit
21
Streamlined requirements Reduced the number of regulations Made them easier to understand Grouped related requirements Eliminated redundancy Reduced administrative burden Provided greater flexibility to
determine how best to achieve goals
22
Performance Standard Outcomes
Importance of Definitional Changes
bull An important difference in the new HSPPS is that all definitions are collected at 45 CFR sect13052
ndash Some definitions are the same some are brand new and some longstanding terms have new definitions
23
Example - New Definitions
bull Federal interest is a property right which secures the right of the federal awarding agency to recover the current fair market value of its percentage of participation in the cost of the facility in the event the facility is no longer used for Head Start purposes by the grantee or upon the disposition of the property When a grantee uses Head Start funds to purchase construct or renovate a facility or make mortgage payments it creates a federal interest The federal interest includes any portion of the cost of purchase construction or renovation contributed by or for the entity or a related donor organization to satisfy a matching requirement
bull Repair means maintenance that is necessary to keep a Head Start facility in working condition Repairs do not add significant value to the property or extend its useful life
24
Example - Changed Definitions
bull Old Major renovation means a structural change to the foundation roof floor or exterior or load-bearing walls of a facility or extension of an existing facility to increase its floor area Major renovation also means extensive alteration of an existing facility such as to significantly change its function and purpose even if such renovation does not include any structural change to the facility Major renovation also includes a renovation of any kind which has a cost exceeding the lesser of $200000 adjusted annually to reflect the percentage change in the Consumer Price Index for All Urban Consumers (issued by the Bureau of Labor Statistics) beginning one year after June 22003 or 25 percent of the total annual direct costs approved for the grantee by ACF for the budget period in which the application is made
bull New Major renovation means any individual or collecti[ve] renovation that has a cost equal to or exceeding $250000 It excludes minor renovations and repairs except when they are included in a purchase application
25
Early Childhood Learning and Knowledge Center (ECLKC)
OHS Early Childhood Learning and Knowledge Center
Click thestar to access ECLKC byhyperlink
Or go tohttpseclkcohsacfhhsgovhslc
26
Governmental Audit Quality Center
Auditing the Head Start
Program
29
Governmental Audit Quality Center
Event Materials Highlight Requirements
Unique to Head Start
The following basic single audit knowledge
is assumed
bull Auditing standards (GAAS and Government Auditing
Standards)
bull Uniform Administrative Requirements Cost
Principles and Audit Requirements for Federal
Awards at 2 CFR 200 (UG or Uniform Guidance)
bull OMB Compliance Supplement
bull Federal Audit Clearinghouse reporting
30
Governmental Audit Quality Center
Information Provided is not a Substitute for
Compliance Supplement or UG
Session focuses on program changes and
areas identified as common risks for Head
Start programs
bull An individual entityrsquos risk may be different
Auditor must still comply with the UG and
consider all requirements identified in the
Compliance Supplement
31
Governmental Audit Quality Center
2017 Updated Compliance Supplement
for Head Start An Overview
Program Objectives and Program Procedures
Matrix
Compliance Requirements - Updates
bull A Activities Allowed or Unallowed
bull E Eligibility for Subrecipients
bull F Equipment amp Real Property Management (Head Start
property requirements move to Special Tests and Provisions
bull J Program Income ndash Deleted
bull L3 Special Reporting (new report)
bull N Special Tests and Provisions (Property amp program
governance)
IV Other Information ndash Areas of risk
32
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Audits in Head Start
bull Sec 647 of the Head Start Act (HSA) requires that all entities receiving Head Start fundsndash keep records necessary to facilitate an effective audit
ndash submit a copy of the audit within 30 days of completion
bull Sec 641 of the HSA includes annual audits (going concern) within the criteria for competition under the Designation Renewal System implemented at 45 CFR Part 1303 ndashSubpart B
19
Audits in Head Start
bull Sec 642 of the HSA addresses responsibilities of the grantee governing body (board) and policy council includingndash Governing body has legal and fiscal responsibility
for the agency and shallbull be responsible for selection of the auditor who shall
report to the governing body
bull review and approve policies relating to the financial audit
bull monitor the agencyrsquos action to correct any audit findings
20
Audits in Head Start
bull Both the governing body and the policy council must be provided with a copy of the annual financial audit
bull Each agency must make available to the public a report published at least once in each fiscal year that discloses the results of the annual financial audit
21
Streamlined requirements Reduced the number of regulations Made them easier to understand Grouped related requirements Eliminated redundancy Reduced administrative burden Provided greater flexibility to
determine how best to achieve goals
22
Performance Standard Outcomes
Importance of Definitional Changes
bull An important difference in the new HSPPS is that all definitions are collected at 45 CFR sect13052
ndash Some definitions are the same some are brand new and some longstanding terms have new definitions
23
Example - New Definitions
bull Federal interest is a property right which secures the right of the federal awarding agency to recover the current fair market value of its percentage of participation in the cost of the facility in the event the facility is no longer used for Head Start purposes by the grantee or upon the disposition of the property When a grantee uses Head Start funds to purchase construct or renovate a facility or make mortgage payments it creates a federal interest The federal interest includes any portion of the cost of purchase construction or renovation contributed by or for the entity or a related donor organization to satisfy a matching requirement
bull Repair means maintenance that is necessary to keep a Head Start facility in working condition Repairs do not add significant value to the property or extend its useful life
24
Example - Changed Definitions
bull Old Major renovation means a structural change to the foundation roof floor or exterior or load-bearing walls of a facility or extension of an existing facility to increase its floor area Major renovation also means extensive alteration of an existing facility such as to significantly change its function and purpose even if such renovation does not include any structural change to the facility Major renovation also includes a renovation of any kind which has a cost exceeding the lesser of $200000 adjusted annually to reflect the percentage change in the Consumer Price Index for All Urban Consumers (issued by the Bureau of Labor Statistics) beginning one year after June 22003 or 25 percent of the total annual direct costs approved for the grantee by ACF for the budget period in which the application is made
bull New Major renovation means any individual or collecti[ve] renovation that has a cost equal to or exceeding $250000 It excludes minor renovations and repairs except when they are included in a purchase application
25
Early Childhood Learning and Knowledge Center (ECLKC)
OHS Early Childhood Learning and Knowledge Center
Click thestar to access ECLKC byhyperlink
Or go tohttpseclkcohsacfhhsgovhslc
26
Governmental Audit Quality Center
Auditing the Head Start
Program
29
Governmental Audit Quality Center
Event Materials Highlight Requirements
Unique to Head Start
The following basic single audit knowledge
is assumed
bull Auditing standards (GAAS and Government Auditing
Standards)
bull Uniform Administrative Requirements Cost
Principles and Audit Requirements for Federal
Awards at 2 CFR 200 (UG or Uniform Guidance)
bull OMB Compliance Supplement
bull Federal Audit Clearinghouse reporting
30
Governmental Audit Quality Center
Information Provided is not a Substitute for
Compliance Supplement or UG
Session focuses on program changes and
areas identified as common risks for Head
Start programs
bull An individual entityrsquos risk may be different
Auditor must still comply with the UG and
consider all requirements identified in the
Compliance Supplement
31
Governmental Audit Quality Center
2017 Updated Compliance Supplement
for Head Start An Overview
Program Objectives and Program Procedures
Matrix
Compliance Requirements - Updates
bull A Activities Allowed or Unallowed
bull E Eligibility for Subrecipients
bull F Equipment amp Real Property Management (Head Start
property requirements move to Special Tests and Provisions
bull J Program Income ndash Deleted
bull L3 Special Reporting (new report)
bull N Special Tests and Provisions (Property amp program
governance)
IV Other Information ndash Areas of risk
32
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Audits in Head Start
bull Sec 642 of the HSA addresses responsibilities of the grantee governing body (board) and policy council includingndash Governing body has legal and fiscal responsibility
for the agency and shallbull be responsible for selection of the auditor who shall
report to the governing body
bull review and approve policies relating to the financial audit
bull monitor the agencyrsquos action to correct any audit findings
20
Audits in Head Start
bull Both the governing body and the policy council must be provided with a copy of the annual financial audit
bull Each agency must make available to the public a report published at least once in each fiscal year that discloses the results of the annual financial audit
21
Streamlined requirements Reduced the number of regulations Made them easier to understand Grouped related requirements Eliminated redundancy Reduced administrative burden Provided greater flexibility to
determine how best to achieve goals
22
Performance Standard Outcomes
Importance of Definitional Changes
bull An important difference in the new HSPPS is that all definitions are collected at 45 CFR sect13052
ndash Some definitions are the same some are brand new and some longstanding terms have new definitions
23
Example - New Definitions
bull Federal interest is a property right which secures the right of the federal awarding agency to recover the current fair market value of its percentage of participation in the cost of the facility in the event the facility is no longer used for Head Start purposes by the grantee or upon the disposition of the property When a grantee uses Head Start funds to purchase construct or renovate a facility or make mortgage payments it creates a federal interest The federal interest includes any portion of the cost of purchase construction or renovation contributed by or for the entity or a related donor organization to satisfy a matching requirement
bull Repair means maintenance that is necessary to keep a Head Start facility in working condition Repairs do not add significant value to the property or extend its useful life
24
Example - Changed Definitions
bull Old Major renovation means a structural change to the foundation roof floor or exterior or load-bearing walls of a facility or extension of an existing facility to increase its floor area Major renovation also means extensive alteration of an existing facility such as to significantly change its function and purpose even if such renovation does not include any structural change to the facility Major renovation also includes a renovation of any kind which has a cost exceeding the lesser of $200000 adjusted annually to reflect the percentage change in the Consumer Price Index for All Urban Consumers (issued by the Bureau of Labor Statistics) beginning one year after June 22003 or 25 percent of the total annual direct costs approved for the grantee by ACF for the budget period in which the application is made
bull New Major renovation means any individual or collecti[ve] renovation that has a cost equal to or exceeding $250000 It excludes minor renovations and repairs except when they are included in a purchase application
25
Early Childhood Learning and Knowledge Center (ECLKC)
OHS Early Childhood Learning and Knowledge Center
Click thestar to access ECLKC byhyperlink
Or go tohttpseclkcohsacfhhsgovhslc
26
Governmental Audit Quality Center
Auditing the Head Start
Program
29
Governmental Audit Quality Center
Event Materials Highlight Requirements
Unique to Head Start
The following basic single audit knowledge
is assumed
bull Auditing standards (GAAS and Government Auditing
Standards)
bull Uniform Administrative Requirements Cost
Principles and Audit Requirements for Federal
Awards at 2 CFR 200 (UG or Uniform Guidance)
bull OMB Compliance Supplement
bull Federal Audit Clearinghouse reporting
30
Governmental Audit Quality Center
Information Provided is not a Substitute for
Compliance Supplement or UG
Session focuses on program changes and
areas identified as common risks for Head
Start programs
bull An individual entityrsquos risk may be different
Auditor must still comply with the UG and
consider all requirements identified in the
Compliance Supplement
31
Governmental Audit Quality Center
2017 Updated Compliance Supplement
for Head Start An Overview
Program Objectives and Program Procedures
Matrix
Compliance Requirements - Updates
bull A Activities Allowed or Unallowed
bull E Eligibility for Subrecipients
bull F Equipment amp Real Property Management (Head Start
property requirements move to Special Tests and Provisions
bull J Program Income ndash Deleted
bull L3 Special Reporting (new report)
bull N Special Tests and Provisions (Property amp program
governance)
IV Other Information ndash Areas of risk
32
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Audits in Head Start
bull Both the governing body and the policy council must be provided with a copy of the annual financial audit
bull Each agency must make available to the public a report published at least once in each fiscal year that discloses the results of the annual financial audit
21
Streamlined requirements Reduced the number of regulations Made them easier to understand Grouped related requirements Eliminated redundancy Reduced administrative burden Provided greater flexibility to
determine how best to achieve goals
22
Performance Standard Outcomes
Importance of Definitional Changes
bull An important difference in the new HSPPS is that all definitions are collected at 45 CFR sect13052
ndash Some definitions are the same some are brand new and some longstanding terms have new definitions
23
Example - New Definitions
bull Federal interest is a property right which secures the right of the federal awarding agency to recover the current fair market value of its percentage of participation in the cost of the facility in the event the facility is no longer used for Head Start purposes by the grantee or upon the disposition of the property When a grantee uses Head Start funds to purchase construct or renovate a facility or make mortgage payments it creates a federal interest The federal interest includes any portion of the cost of purchase construction or renovation contributed by or for the entity or a related donor organization to satisfy a matching requirement
bull Repair means maintenance that is necessary to keep a Head Start facility in working condition Repairs do not add significant value to the property or extend its useful life
24
Example - Changed Definitions
bull Old Major renovation means a structural change to the foundation roof floor or exterior or load-bearing walls of a facility or extension of an existing facility to increase its floor area Major renovation also means extensive alteration of an existing facility such as to significantly change its function and purpose even if such renovation does not include any structural change to the facility Major renovation also includes a renovation of any kind which has a cost exceeding the lesser of $200000 adjusted annually to reflect the percentage change in the Consumer Price Index for All Urban Consumers (issued by the Bureau of Labor Statistics) beginning one year after June 22003 or 25 percent of the total annual direct costs approved for the grantee by ACF for the budget period in which the application is made
bull New Major renovation means any individual or collecti[ve] renovation that has a cost equal to or exceeding $250000 It excludes minor renovations and repairs except when they are included in a purchase application
25
Early Childhood Learning and Knowledge Center (ECLKC)
OHS Early Childhood Learning and Knowledge Center
Click thestar to access ECLKC byhyperlink
Or go tohttpseclkcohsacfhhsgovhslc
26
Governmental Audit Quality Center
Auditing the Head Start
Program
29
Governmental Audit Quality Center
Event Materials Highlight Requirements
Unique to Head Start
The following basic single audit knowledge
is assumed
bull Auditing standards (GAAS and Government Auditing
Standards)
bull Uniform Administrative Requirements Cost
Principles and Audit Requirements for Federal
Awards at 2 CFR 200 (UG or Uniform Guidance)
bull OMB Compliance Supplement
bull Federal Audit Clearinghouse reporting
30
Governmental Audit Quality Center
Information Provided is not a Substitute for
Compliance Supplement or UG
Session focuses on program changes and
areas identified as common risks for Head
Start programs
bull An individual entityrsquos risk may be different
Auditor must still comply with the UG and
consider all requirements identified in the
Compliance Supplement
31
Governmental Audit Quality Center
2017 Updated Compliance Supplement
for Head Start An Overview
Program Objectives and Program Procedures
Matrix
Compliance Requirements - Updates
bull A Activities Allowed or Unallowed
bull E Eligibility for Subrecipients
bull F Equipment amp Real Property Management (Head Start
property requirements move to Special Tests and Provisions
bull J Program Income ndash Deleted
bull L3 Special Reporting (new report)
bull N Special Tests and Provisions (Property amp program
governance)
IV Other Information ndash Areas of risk
32
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Streamlined requirements Reduced the number of regulations Made them easier to understand Grouped related requirements Eliminated redundancy Reduced administrative burden Provided greater flexibility to
determine how best to achieve goals
22
Performance Standard Outcomes
Importance of Definitional Changes
bull An important difference in the new HSPPS is that all definitions are collected at 45 CFR sect13052
ndash Some definitions are the same some are brand new and some longstanding terms have new definitions
23
Example - New Definitions
bull Federal interest is a property right which secures the right of the federal awarding agency to recover the current fair market value of its percentage of participation in the cost of the facility in the event the facility is no longer used for Head Start purposes by the grantee or upon the disposition of the property When a grantee uses Head Start funds to purchase construct or renovate a facility or make mortgage payments it creates a federal interest The federal interest includes any portion of the cost of purchase construction or renovation contributed by or for the entity or a related donor organization to satisfy a matching requirement
bull Repair means maintenance that is necessary to keep a Head Start facility in working condition Repairs do not add significant value to the property or extend its useful life
24
Example - Changed Definitions
bull Old Major renovation means a structural change to the foundation roof floor or exterior or load-bearing walls of a facility or extension of an existing facility to increase its floor area Major renovation also means extensive alteration of an existing facility such as to significantly change its function and purpose even if such renovation does not include any structural change to the facility Major renovation also includes a renovation of any kind which has a cost exceeding the lesser of $200000 adjusted annually to reflect the percentage change in the Consumer Price Index for All Urban Consumers (issued by the Bureau of Labor Statistics) beginning one year after June 22003 or 25 percent of the total annual direct costs approved for the grantee by ACF for the budget period in which the application is made
bull New Major renovation means any individual or collecti[ve] renovation that has a cost equal to or exceeding $250000 It excludes minor renovations and repairs except when they are included in a purchase application
25
Early Childhood Learning and Knowledge Center (ECLKC)
OHS Early Childhood Learning and Knowledge Center
Click thestar to access ECLKC byhyperlink
Or go tohttpseclkcohsacfhhsgovhslc
26
Governmental Audit Quality Center
Auditing the Head Start
Program
29
Governmental Audit Quality Center
Event Materials Highlight Requirements
Unique to Head Start
The following basic single audit knowledge
is assumed
bull Auditing standards (GAAS and Government Auditing
Standards)
bull Uniform Administrative Requirements Cost
Principles and Audit Requirements for Federal
Awards at 2 CFR 200 (UG or Uniform Guidance)
bull OMB Compliance Supplement
bull Federal Audit Clearinghouse reporting
30
Governmental Audit Quality Center
Information Provided is not a Substitute for
Compliance Supplement or UG
Session focuses on program changes and
areas identified as common risks for Head
Start programs
bull An individual entityrsquos risk may be different
Auditor must still comply with the UG and
consider all requirements identified in the
Compliance Supplement
31
Governmental Audit Quality Center
2017 Updated Compliance Supplement
for Head Start An Overview
Program Objectives and Program Procedures
Matrix
Compliance Requirements - Updates
bull A Activities Allowed or Unallowed
bull E Eligibility for Subrecipients
bull F Equipment amp Real Property Management (Head Start
property requirements move to Special Tests and Provisions
bull J Program Income ndash Deleted
bull L3 Special Reporting (new report)
bull N Special Tests and Provisions (Property amp program
governance)
IV Other Information ndash Areas of risk
32
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Importance of Definitional Changes
bull An important difference in the new HSPPS is that all definitions are collected at 45 CFR sect13052
ndash Some definitions are the same some are brand new and some longstanding terms have new definitions
23
Example - New Definitions
bull Federal interest is a property right which secures the right of the federal awarding agency to recover the current fair market value of its percentage of participation in the cost of the facility in the event the facility is no longer used for Head Start purposes by the grantee or upon the disposition of the property When a grantee uses Head Start funds to purchase construct or renovate a facility or make mortgage payments it creates a federal interest The federal interest includes any portion of the cost of purchase construction or renovation contributed by or for the entity or a related donor organization to satisfy a matching requirement
bull Repair means maintenance that is necessary to keep a Head Start facility in working condition Repairs do not add significant value to the property or extend its useful life
24
Example - Changed Definitions
bull Old Major renovation means a structural change to the foundation roof floor or exterior or load-bearing walls of a facility or extension of an existing facility to increase its floor area Major renovation also means extensive alteration of an existing facility such as to significantly change its function and purpose even if such renovation does not include any structural change to the facility Major renovation also includes a renovation of any kind which has a cost exceeding the lesser of $200000 adjusted annually to reflect the percentage change in the Consumer Price Index for All Urban Consumers (issued by the Bureau of Labor Statistics) beginning one year after June 22003 or 25 percent of the total annual direct costs approved for the grantee by ACF for the budget period in which the application is made
bull New Major renovation means any individual or collecti[ve] renovation that has a cost equal to or exceeding $250000 It excludes minor renovations and repairs except when they are included in a purchase application
25
Early Childhood Learning and Knowledge Center (ECLKC)
OHS Early Childhood Learning and Knowledge Center
Click thestar to access ECLKC byhyperlink
Or go tohttpseclkcohsacfhhsgovhslc
26
Governmental Audit Quality Center
Auditing the Head Start
Program
29
Governmental Audit Quality Center
Event Materials Highlight Requirements
Unique to Head Start
The following basic single audit knowledge
is assumed
bull Auditing standards (GAAS and Government Auditing
Standards)
bull Uniform Administrative Requirements Cost
Principles and Audit Requirements for Federal
Awards at 2 CFR 200 (UG or Uniform Guidance)
bull OMB Compliance Supplement
bull Federal Audit Clearinghouse reporting
30
Governmental Audit Quality Center
Information Provided is not a Substitute for
Compliance Supplement or UG
Session focuses on program changes and
areas identified as common risks for Head
Start programs
bull An individual entityrsquos risk may be different
Auditor must still comply with the UG and
consider all requirements identified in the
Compliance Supplement
31
Governmental Audit Quality Center
2017 Updated Compliance Supplement
for Head Start An Overview
Program Objectives and Program Procedures
Matrix
Compliance Requirements - Updates
bull A Activities Allowed or Unallowed
bull E Eligibility for Subrecipients
bull F Equipment amp Real Property Management (Head Start
property requirements move to Special Tests and Provisions
bull J Program Income ndash Deleted
bull L3 Special Reporting (new report)
bull N Special Tests and Provisions (Property amp program
governance)
IV Other Information ndash Areas of risk
32
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Example - New Definitions
bull Federal interest is a property right which secures the right of the federal awarding agency to recover the current fair market value of its percentage of participation in the cost of the facility in the event the facility is no longer used for Head Start purposes by the grantee or upon the disposition of the property When a grantee uses Head Start funds to purchase construct or renovate a facility or make mortgage payments it creates a federal interest The federal interest includes any portion of the cost of purchase construction or renovation contributed by or for the entity or a related donor organization to satisfy a matching requirement
bull Repair means maintenance that is necessary to keep a Head Start facility in working condition Repairs do not add significant value to the property or extend its useful life
24
Example - Changed Definitions
bull Old Major renovation means a structural change to the foundation roof floor or exterior or load-bearing walls of a facility or extension of an existing facility to increase its floor area Major renovation also means extensive alteration of an existing facility such as to significantly change its function and purpose even if such renovation does not include any structural change to the facility Major renovation also includes a renovation of any kind which has a cost exceeding the lesser of $200000 adjusted annually to reflect the percentage change in the Consumer Price Index for All Urban Consumers (issued by the Bureau of Labor Statistics) beginning one year after June 22003 or 25 percent of the total annual direct costs approved for the grantee by ACF for the budget period in which the application is made
bull New Major renovation means any individual or collecti[ve] renovation that has a cost equal to or exceeding $250000 It excludes minor renovations and repairs except when they are included in a purchase application
25
Early Childhood Learning and Knowledge Center (ECLKC)
OHS Early Childhood Learning and Knowledge Center
Click thestar to access ECLKC byhyperlink
Or go tohttpseclkcohsacfhhsgovhslc
26
Governmental Audit Quality Center
Auditing the Head Start
Program
29
Governmental Audit Quality Center
Event Materials Highlight Requirements
Unique to Head Start
The following basic single audit knowledge
is assumed
bull Auditing standards (GAAS and Government Auditing
Standards)
bull Uniform Administrative Requirements Cost
Principles and Audit Requirements for Federal
Awards at 2 CFR 200 (UG or Uniform Guidance)
bull OMB Compliance Supplement
bull Federal Audit Clearinghouse reporting
30
Governmental Audit Quality Center
Information Provided is not a Substitute for
Compliance Supplement or UG
Session focuses on program changes and
areas identified as common risks for Head
Start programs
bull An individual entityrsquos risk may be different
Auditor must still comply with the UG and
consider all requirements identified in the
Compliance Supplement
31
Governmental Audit Quality Center
2017 Updated Compliance Supplement
for Head Start An Overview
Program Objectives and Program Procedures
Matrix
Compliance Requirements - Updates
bull A Activities Allowed or Unallowed
bull E Eligibility for Subrecipients
bull F Equipment amp Real Property Management (Head Start
property requirements move to Special Tests and Provisions
bull J Program Income ndash Deleted
bull L3 Special Reporting (new report)
bull N Special Tests and Provisions (Property amp program
governance)
IV Other Information ndash Areas of risk
32
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Example - Changed Definitions
bull Old Major renovation means a structural change to the foundation roof floor or exterior or load-bearing walls of a facility or extension of an existing facility to increase its floor area Major renovation also means extensive alteration of an existing facility such as to significantly change its function and purpose even if such renovation does not include any structural change to the facility Major renovation also includes a renovation of any kind which has a cost exceeding the lesser of $200000 adjusted annually to reflect the percentage change in the Consumer Price Index for All Urban Consumers (issued by the Bureau of Labor Statistics) beginning one year after June 22003 or 25 percent of the total annual direct costs approved for the grantee by ACF for the budget period in which the application is made
bull New Major renovation means any individual or collecti[ve] renovation that has a cost equal to or exceeding $250000 It excludes minor renovations and repairs except when they are included in a purchase application
25
Early Childhood Learning and Knowledge Center (ECLKC)
OHS Early Childhood Learning and Knowledge Center
Click thestar to access ECLKC byhyperlink
Or go tohttpseclkcohsacfhhsgovhslc
26
Governmental Audit Quality Center
Auditing the Head Start
Program
29
Governmental Audit Quality Center
Event Materials Highlight Requirements
Unique to Head Start
The following basic single audit knowledge
is assumed
bull Auditing standards (GAAS and Government Auditing
Standards)
bull Uniform Administrative Requirements Cost
Principles and Audit Requirements for Federal
Awards at 2 CFR 200 (UG or Uniform Guidance)
bull OMB Compliance Supplement
bull Federal Audit Clearinghouse reporting
30
Governmental Audit Quality Center
Information Provided is not a Substitute for
Compliance Supplement or UG
Session focuses on program changes and
areas identified as common risks for Head
Start programs
bull An individual entityrsquos risk may be different
Auditor must still comply with the UG and
consider all requirements identified in the
Compliance Supplement
31
Governmental Audit Quality Center
2017 Updated Compliance Supplement
for Head Start An Overview
Program Objectives and Program Procedures
Matrix
Compliance Requirements - Updates
bull A Activities Allowed or Unallowed
bull E Eligibility for Subrecipients
bull F Equipment amp Real Property Management (Head Start
property requirements move to Special Tests and Provisions
bull J Program Income ndash Deleted
bull L3 Special Reporting (new report)
bull N Special Tests and Provisions (Property amp program
governance)
IV Other Information ndash Areas of risk
32
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Early Childhood Learning and Knowledge Center (ECLKC)
OHS Early Childhood Learning and Knowledge Center
Click thestar to access ECLKC byhyperlink
Or go tohttpseclkcohsacfhhsgovhslc
26
Governmental Audit Quality Center
Auditing the Head Start
Program
29
Governmental Audit Quality Center
Event Materials Highlight Requirements
Unique to Head Start
The following basic single audit knowledge
is assumed
bull Auditing standards (GAAS and Government Auditing
Standards)
bull Uniform Administrative Requirements Cost
Principles and Audit Requirements for Federal
Awards at 2 CFR 200 (UG or Uniform Guidance)
bull OMB Compliance Supplement
bull Federal Audit Clearinghouse reporting
30
Governmental Audit Quality Center
Information Provided is not a Substitute for
Compliance Supplement or UG
Session focuses on program changes and
areas identified as common risks for Head
Start programs
bull An individual entityrsquos risk may be different
Auditor must still comply with the UG and
consider all requirements identified in the
Compliance Supplement
31
Governmental Audit Quality Center
2017 Updated Compliance Supplement
for Head Start An Overview
Program Objectives and Program Procedures
Matrix
Compliance Requirements - Updates
bull A Activities Allowed or Unallowed
bull E Eligibility for Subrecipients
bull F Equipment amp Real Property Management (Head Start
property requirements move to Special Tests and Provisions
bull J Program Income ndash Deleted
bull L3 Special Reporting (new report)
bull N Special Tests and Provisions (Property amp program
governance)
IV Other Information ndash Areas of risk
32
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
Auditing the Head Start
Program
29
Governmental Audit Quality Center
Event Materials Highlight Requirements
Unique to Head Start
The following basic single audit knowledge
is assumed
bull Auditing standards (GAAS and Government Auditing
Standards)
bull Uniform Administrative Requirements Cost
Principles and Audit Requirements for Federal
Awards at 2 CFR 200 (UG or Uniform Guidance)
bull OMB Compliance Supplement
bull Federal Audit Clearinghouse reporting
30
Governmental Audit Quality Center
Information Provided is not a Substitute for
Compliance Supplement or UG
Session focuses on program changes and
areas identified as common risks for Head
Start programs
bull An individual entityrsquos risk may be different
Auditor must still comply with the UG and
consider all requirements identified in the
Compliance Supplement
31
Governmental Audit Quality Center
2017 Updated Compliance Supplement
for Head Start An Overview
Program Objectives and Program Procedures
Matrix
Compliance Requirements - Updates
bull A Activities Allowed or Unallowed
bull E Eligibility for Subrecipients
bull F Equipment amp Real Property Management (Head Start
property requirements move to Special Tests and Provisions
bull J Program Income ndash Deleted
bull L3 Special Reporting (new report)
bull N Special Tests and Provisions (Property amp program
governance)
IV Other Information ndash Areas of risk
32
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
Event Materials Highlight Requirements
Unique to Head Start
The following basic single audit knowledge
is assumed
bull Auditing standards (GAAS and Government Auditing
Standards)
bull Uniform Administrative Requirements Cost
Principles and Audit Requirements for Federal
Awards at 2 CFR 200 (UG or Uniform Guidance)
bull OMB Compliance Supplement
bull Federal Audit Clearinghouse reporting
30
Governmental Audit Quality Center
Information Provided is not a Substitute for
Compliance Supplement or UG
Session focuses on program changes and
areas identified as common risks for Head
Start programs
bull An individual entityrsquos risk may be different
Auditor must still comply with the UG and
consider all requirements identified in the
Compliance Supplement
31
Governmental Audit Quality Center
2017 Updated Compliance Supplement
for Head Start An Overview
Program Objectives and Program Procedures
Matrix
Compliance Requirements - Updates
bull A Activities Allowed or Unallowed
bull E Eligibility for Subrecipients
bull F Equipment amp Real Property Management (Head Start
property requirements move to Special Tests and Provisions
bull J Program Income ndash Deleted
bull L3 Special Reporting (new report)
bull N Special Tests and Provisions (Property amp program
governance)
IV Other Information ndash Areas of risk
32
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
Information Provided is not a Substitute for
Compliance Supplement or UG
Session focuses on program changes and
areas identified as common risks for Head
Start programs
bull An individual entityrsquos risk may be different
Auditor must still comply with the UG and
consider all requirements identified in the
Compliance Supplement
31
Governmental Audit Quality Center
2017 Updated Compliance Supplement
for Head Start An Overview
Program Objectives and Program Procedures
Matrix
Compliance Requirements - Updates
bull A Activities Allowed or Unallowed
bull E Eligibility for Subrecipients
bull F Equipment amp Real Property Management (Head Start
property requirements move to Special Tests and Provisions
bull J Program Income ndash Deleted
bull L3 Special Reporting (new report)
bull N Special Tests and Provisions (Property amp program
governance)
IV Other Information ndash Areas of risk
32
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
2017 Updated Compliance Supplement
for Head Start An Overview
Program Objectives and Program Procedures
Matrix
Compliance Requirements - Updates
bull A Activities Allowed or Unallowed
bull E Eligibility for Subrecipients
bull F Equipment amp Real Property Management (Head Start
property requirements move to Special Tests and Provisions
bull J Program Income ndash Deleted
bull L3 Special Reporting (new report)
bull N Special Tests and Provisions (Property amp program
governance)
IV Other Information ndash Areas of risk
32
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
Program Objectives and Procedure
Shortened to focus on what auditor needs to know
Updated for Head Start Performance Standards
Clarifies Head Start terms
bull Head Start Agency ndash May also be a pass-through entity
bull Delegate agency ndash Subrecipient
- Can be public non-profit or for-profit
Highlights the following matters
bull Specific subrecipient monitoring requirements
bull Program governance
33
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
Matrix
Added Eligibility of Subrecipients
Deleted Program Income
Added Special Tests and Provisions
bull Protection of Federal Interest
bull Program Governance
Compliance Requirements
A B C E F G H I J L M N
Act
ivit
ies
Allo
wed
or
Un
allo
wed
Allo
wab
le
Co
sts
Co
st
Pri
nci
ple
s
Cas
h
Man
agem
ent
Elig
ibili
ty
Equ
ipm
ent
Rea
l Pro
per
ty
Man
agem
ent
Mat
chin
g
Leve
l of
Effo
rt
Earm
arki
ng
Per
iod
of
Per
form
ance
Pro
cure
men
tSu
spen
sio
n
and
D
ebar
men
t
Pro
gram
In
com
e
Rep
ort
ing
Sub
reci
pie
nt
Mo
nit
ori
ng
Spec
ial T
ests
an
d P
rovi
sio
ns
Y Y Y Y Y Y Y N N Y Y Y
34
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
A Activities Allowed or Unallowed
Moved ldquoProgram Governancerdquo to Special
Tests and Provisions
Clarified requirement for professional
medical and health services
bull Only allowable when no other funding source
available
bull Documentation of effort (written) to access other
funding
35
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
E Eligibility for Subrecipients
(also known as Delegate Agency)
Written agreement required
Office of Head Start must approve
agreement prior to award
36
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
Auditor Observations AllowabilityEligibility
Changes
Document activities allowed unallowed
Document managementrsquos internal control over
allowability
bull Inquire of program staff how they remain current on changing
program requirements
bull How do program staff ensure only allowable costs are charged
to the program
bull What evidence of this control is retained
bull Consider both direct and allocated costs
Test both compliance and internal control over
compliance
Be alert for payments to potential subrecipients
37
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
L3 Special Reporting
SF-429 ndash Real Property Status Reportbull Background
bull Effective date
SF-429-A General Reportingbull Background
Key Web Linksbull Changes in Federal Reporting
(httpseclkcohsacfhhsgovpolicypiacf-pi-hs-16-01)
bull Access to Form 429
(httpseclkcohsacfhhsgovsitesdefaultfilesdocspolicy-im2016-
085Dacf-im-hs-15-01pdf)
38
EMPHASIS POINT Access the latest SF-429 and SF-429A forms under the Handouts tab referred to earlier during this presentation
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
SF-429 ndash Real Property Status Report
39
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
SF-429 Key Line Items
Line 1 Federal Agency and Organizational
Element Where Submitted
Line 2 Federal Grant or Identifying Number
Line 3 Recipient Organization Name
Line 4b Employer Identification Number (40)
40
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
SF-429A ndash Real Property Status Report
Attachment A
41
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
SF-429-A General Reporting
Line 13 Period and type of Federal interest
Line 14a Description of real property
Line 14b Address of real property
Line 14f Real property cost ndash Federal and non-Federal share
Line 14g Document recorded to establish Federal interest
Line 14h Has Federally required insurance coverage been secured
Line 15 Has significant change occurred
- Auditor not expected to review for anticipated change
Line 16 Real property disposition status (eg sold transferred)
42
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
Auditor Observations Reporting Changes
Consider the timing of required reports
bull May need to test reports filed during the audit period rather than
reports filed for the audit period
Document managementrsquos internal control over
reporting
bull Inquire of program staff how they remain current on changing
program requirements
bull Who prepares reviews reporting (Program vs financial
personnel)
bull What evidence of this control is retained
Test both compliance and internal control over
compliance
43
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Terms ndash Definitions in 45 CFR 13052
bull Construction
bull Facility
bull Federal interest
bull Major renovation
bull Modular unit
Prior written approval from ACF
bull SF-429 and
- Attachment B ndash Request to Acquire Improve or Furnish
- Attachment C ndash Disposition or Encumbrance Request
44
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Notice of Federal Interest
bull Real Property
- Owned or leased
- Recorded in official real property records
bull Modular Unit
- Posted on exterior and interior
bull Required language in ldquonoticerdquo
Prohibition against encumbering without prior
written approval from ACF
45
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Audit Objectives ndash Determine whether
1 Federal interests protected by required Notice of Federal Interest
2 Correct language content in the Notice of Federal Interest
3 Required written approvals from ACF
- Purchase
- Sale or lease
- Encumber
- Different use
46
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
N Special Tests and Provisions1 Protection of Federal Interest in Real Property and
Facilities
Suggested Audit Procedures
1 Review minutes and general ledger accounts and inquire of
management for transactions occurring during the audit period
2 Review prior written approval from Administration for Children
and Families (ACF) for purchases construction or major
renovation
3 For purchase or major renovation during the audit period
- Was notice Federal interest properly recorded or posted
- Was required language used
4 For sales leases encumbrances used for different purpose
during the audit period
- Review documentation of ACF prior written approval
47
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Audit Objectives ndash Determine whether the entity
complied with the program governance
requirements for
1 Composition and qualifications of board members
2 Providing information to the governing body and the public
48
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
N Special Tests and Provisions
2 Program Governance
Suggested Audit Procedures
bull Identify attorney or alternative and ascertain license and
experience
bull Identify fiscal or accounting expertise or alternative and
ascertain expertise
bull Ascertain if monthly financial statements shared monthly with
governing body and policy council
bull Ascertain if annual financial information made available to pubic
49
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
Auditor Observations Special Tests and
Provisions Changes
Document managementrsquos internal control over
special tests and provisions
bull Inquire of program staff how they remain current on changing
program requirements
bull Consider how these requirements are communicated to key
individuals within the organization
Test both compliance and internal control over
compliance
bull Suggested audit procedures are compliance-focused
bull Donrsquot fall into the trap of using compliance as a proxy for internal
control over compliance
50
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
IV Other Information
Office of Head Start (OHS) Identified Risk
Indicators
A Activities Allowed or Unallowed
bull Meal costs eligible for USDA funding
bull Medical or oral health services when other funding available
51
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
B Allowable CostsCost Principlesbull Proper allocation of costs when multiple funding streams
bull Over allocation to Head Start (usually largest funder and cash readily available)
- For example all rent charged to Head Start when other benefitting programs
bull Documentation for allocation of shared staff time For example
- Teacher working for Head Start and Child Care
- Charging same costs as direct and indirect
- Including same costs in indirect cost rate and also charging through allocation
- Large dollar costs charged through unsupported journal entries between programs or program years
- Rent charged at market value instead of depreciation or use allowance
bull Transactions between related parties with excessive charges
52
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
IV Other Information
OHS Identified Risk Indicators
C Cash Management ndash Drawing down Head Start funds and using to pay costs of other programs awaiting reimbursement
G Matching Level of Effort Earmarkingbull Economic conditions reducing donations with less money available
for match
bull In-kind matching not complying with cost principles or not properly documented
bull Misclassifying administrative costs as program costs to circumvent the 15 administrative earmark requirement
H Period of Performancebull Improper allocation of payroll spanning fiscal years or shifting
expenses at fiscal year end between years to address budget shortages
bull Bank account reconciliations showing unissued checks as outstanding at year end or large dollar checks at year end not clearing promptly
53
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
Reminder Overall Program and Entity Risks
Head Start not designed to make money
bull Only covers costs that are reasonable allowable and allocable
(RAA) for the accomplishment of program objectives
At best entity relying on Head Start funding breaks
even
bull Grantee must insure that costs are allowable or cover
unallowable costs from other revenue sources
Entity primarily funded by Federal grants at higher
risk for unallowable costs particularly match
bull Limited options to cover unallowable costs
54
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
Auditor Observations OHS Identified Risk
Indicators
Auditors should be sure to consider these risk areas
when planning the audit
bull Remember that suggested audit procedures are the starting
point of developing an audit plan not the end
bull Consider the stated audit objectives and whether additional
procedures are needed to achieve them
55
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
A Few Final Auditor Best Practice Tips
Determining which compliance requirements may
have a direct and material effect
Testing compliance requirements
bull Identifying the population for testing (GL cash draws reports
filed)
bull Separately consider compliance and internal control over
compliance
bull Consider major control systems separately (AP PR JEs)
bull Before sampling consider identifying and testing individually
important items
bull Remember this applies to all directmaterial compliance areas
not just allowability
Document document document
56
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
Other Single Audit
Resources
57
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
Single Audit-Related Information
Uniform Guidance
bull Electronic Code of Federal Regulations (e-CFR) version
OMB Federal Financial Management Web site
bull Access Compliance Supplement
bull Find various additional UG related documents
bull Office of Federal Financial Management Web page
Access COFAR guidance at httpscfogovCOFAR
bull Access COFAR FAQ document
FAC Web site
httpsharvestercensusgovfacwebDefaultaspx
FAC ldquoInstructions and Documentsrdquo page which includes
bull DCF and related instructions
bull IDES instructions
bull Single audit worksheets (Excel)
bull Older versions of the Form and IDES instructions
58
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
AICPA Governmental Audit Quality Center
(wwwaicpaorgGAQC)
Firm-based membership center supporting the
performance of quality ldquogovernmental auditsrdquo
bull Approximately 2030 CPA firm members
ldquoGovernmental auditsrdquo includes audits performed
under Government Auditing Standards such as single
audits
Access more information about membership
requirements or to join
59
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
About the GAQC
60
Provides resources (eg
alerts web events tools
etc)
Main areas of current
emphasis
bull OMB Uniform Guidance
implementation
bull Preparation for upcoming
study on single audit quality
GAQC Web site provides
useful information for both
auditors and auditees
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
GAQC Resources ndash GAQC Web site
(wwwaicpaorgGAQC)
Key areas to check out andor bookmark
bull Access archived GAQC Alerts in chronological order
bull Access archived GAQC Web events by topic or in chronological
order
bull Illustrative auditor reports
bull Uniform Guidance auditor resources Web page
bull Yellow Book tools and resources
- GAQC Practice Aid 2011 Yellow Book Independencemdash
Nonaudit Services Documentation Practice Aid
bull Other Compliance Audit Information Web page
bull HUD Information Web page
bull GAQC Membership Listings
bull Auditee Resource Center
61
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
GAQC Auditee Resource Center
Section of GAQC Web site dedicated to auditees and
open to the public
bull Auditee Resource Center
The types of tools available include
bull Auditee Single Audit Resources Web page
bull An archived no-CPE Web event titled Preparing for a Single
Audit An Auditee Perspective
bull A practice aid titled Procuring Governmental Audit Services
62
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
Recent GAQC Single Audit Tools and Aids
Updated Schedule of Expenditures of Federal
Awards (SEFA) Practice Aids
bull Auditor SEFA Practice Aid
bull Auditee SEFA Practice Aid
GAQC Article Practice Issue Noted With Auditee
Corrective Action Plan and Summary Schedule of
Prior Audit Findings
Agency differences nonauthoritative tool
GAQC Article Tips for Auditors Implementing the
Uniform Guidance in Single Audits
11 Tips for Success with Single Audits (Journal of
Accountancy article)
63
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
Other AICPA Resources ndash Exam-Based
Single Audit Certificates
Comprehensive information on program found at
httpsacertaicpastorecom
Tests knowledge on Uniform Guidance requirements
Offered at Intermediate and Advanced levels
Passing exam results in a digital certificate
bull Learn more about these digital badges and how to access and use
them
AICPA offers learning options aligned with exam content
Participants can opt to take the exam(s) without the
learning options
Participants do not have to take intermediate exam in
order to take advanced exam
Distinguish yourself in the marketplace
64
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
Other AICPA Resources ndash AICPA Competency Framework
Governmental Auditing (competencyaipcaorg)
bull FREE resource designed to help CPAs understand the knowledge
and skills necessary to perform high-quality governmental audit
engagements
bull ldquoKnowledge checksrdquo help you identify growth areas and
recommend learning resources such as reports self-study
courses publications webcasts and more to bolster your
competency
75
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
Questions
66
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
How do I get my CPE certificateAccess your CPE certificate by
clicking this orange icon
If at the end of this presentation you are eligible for but unable to
print your CPE certificate please log back in to this webcast in
24 hours and click the orange ldquoGet CPErdquo button Your certificate
will still be available
If you need assistance with locating your certificate please
contact the AICPA Service Center at 8887777077 or
serviceaicpaorg
67
Governmental Audit Quality Center
Thank You for Attending
68
Governmental Audit Quality Center
Thank You for Attending
68