68
Auditing Head Start Under the New Program Performance Standards and Revised 2017 Compliance Supplement A Governmental Audit Quality Center Web Event June 15, 2017

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Page 1: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 2: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 3: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 4: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 5: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 6: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 7: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 8: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 9: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 10: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 11: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 12: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 13: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 14: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 15: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 16: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 17: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 18: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 19: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 20: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 21: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 22: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 23: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 24: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 25: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 26: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 27: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 28: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 29: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 30: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 31: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 32: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 33: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 34: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 35: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 36: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 37: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 38: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 39: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 40: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 41: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 42: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 43: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 44: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 45: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 46: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 47: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 48: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 49: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 50: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 51: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 52: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 53: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 54: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 55: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 56: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 57: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 58: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 59: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 60: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 61: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 62: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 63: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 64: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 65: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

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

Page 66: Auditing Head Start Under the New Program Performance ... · PDF fileProgram Performance Standards and Revised 2017 Compliance Supplement ... Auditing the Head Start Program ... art

Governmental Audit Quality Center

Thank You for Attending

68