BLS Insights

Uniform Guidance Brings Change to Data Collection Forms

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Delaware Nonprofit Auditors The Office of Management and Budget (OMB) released a Federal Register notice on April 22, 2016, that provides the public a final 30-day window to comment on changes made to the data collection form (SF-SAC). OMB’s primary reason for updating the form is to make changes that are needed due to the implementation of Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards; Final Rule (Uniform Guidance). The new form will be applicable for fiscal periods beginning on or after December 26, 2014. As stated within OMB’s SF-SAC’s proposed instructions the estimated time required to complete the new form is an average of 65 hours for large auditees and 20 hours for all other auditees. These amounts reflect estimates of reporting burden on both the auditees and their auditors.

A few of the specific proposed changes are as follows:

  • Collection of three-digit CFDA extensions listed in the Catalog of Federal Domestic Assistance (CFDA).
  • Identification as to whether the program is part of a cluster of programs and if so, the type of cluster.
  • Collection of loan and/or loan guarantee balances outstanding at the end of the audit period for certain loan programs.
  • For awards that are passed through from another organization, the SF-SAC will collect the name of the pass-through organization along with the identifying number of the award assigned to that organization.
  • Identification as to whether any funds were passed through to a subreceipient and if so, what amount.
  • Disclosure as to whether the financial statements were prepared in accordance with a special purpose framework.
  • Significant expansion of certification statements

The SF-SAC and reporting package is to be electronically transmitted within the earlier of 30 days after receipt of the auditor’s reports, or nine months after the end of the audit period. If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. The Federal Audit Clearinghouse (FAC) anticipates collection of data for single audits performed under Uniform Guidance to begin in late spring 2016 (after the new Form SF-SAC has been issued). For organizations whose audits were performed under the Uniform Guidance and whose SF-SAC would have been due prior to July 31, 2016, the OMB has extended the deadline until July 31, 2016. This extension only applies to the actual submission of the SF-FAC. The audit and reports themselves must be completed and issued within the timeframe specified in the Uniform Guidance.

Organizations should review, with the assistance of their auditors, changes to Form SF-FAC to ensure it is completed accurately and timely.

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