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Practical Insights and Observations

Federal agencies adopted the “Uniform Guidance” as requirements for federal financial assistance by the interim final rule published December 19, 2014.  The “Uniform Guidance” is located at 2 CFR 200 in the Electronic Code of Federal Regulations (

The “Uniform Guidance” superseded OMB Circular A-133 effective for periods beginning after December 26, 2014 (in essence, periods ending December 31, 2015, or later).  Early implementation is not permitted. The entity’s fiscal year dictates whether the audit is to be conducted under OMB Circular A-133 or under Subpart F of the “Uniform Guidance”.

Transitional guidance is available for years ending after December 26, 2014, and before December 31, 2015.  Award recipients have to implement the new administrative requirements and cost principles for all new federal awards made after December 26, 2014, and for funding increments to existing awards after that date.

The auditor may need to test awards that are subject to two different sets of administrative requirements and cost principles.  Auditors should use Part 3.2 of the 2015 Compliance Supplement when testing federal awards after December 26, 2014, and Part 3.1 of the 2015 Compliance Supplement for awards prior to that date.  Because an individual program may be comprised of multiple awards, it is possible that awards may be subject to both sets of requirements.  For years ended December 31, 2015 or later, major programs are determined under Subpart F of the “Uniform Guidance” regardless of which administrative requirements and cost principles apply.

For review of audits subject to Governmental Auditing Standards and the Single Audit Act, peer reviewers should refer to Peer Review Program Manual Section 20,100.  Paragraphs .08-10, “Instructions for Use of Engagement Checklist” contain a matrix for guidance in selecting the appropriate checklists.  For engagements subject to the Uniform Guidance, the review must supplement the applicable engagement checklist with both the appropriate “Government Auditing Standards Checklist” (PRP Sec 22,110), and the “OMB Single Audit - UG Checklists” (PRP Sec. 22,100).

irwinRobert Irwin, CPA, is a manager with RA Mercer and Co, CPAs, PC and former managing partner of the firm. He is a member of the NYSSCPA and a past chairman of the Peer Review Committee.