| Dear Center Members: |
The Federal Audit Clearinghouse (FAC) has released a Federal Register (FR) notice titled, Submission for OMB Review; Comment Request, that discusses proposed changes to the Data Collection Form (DCF or the Form) and its instructions. This effort allows the public a final opportunity to review and comment on the changes made to the Form in response to the previous related April 2018 round of due process. This GAQC Alert covers the following:
- The effective date of the proposed Form;
- How to comment;
- Accessing the draft Form and instructions; and
- A summary of the changes being proposed.
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Effective Date of Proposed Form
Importantly, this proposed version of the Form will not be used for your 2018 single audits, but rather would apply to your future single audits with fiscal period ending dates in 2019, 2020, or 2021. However, you should pay attention to this proposal now to understand its future impact and to provide feedback. The FAC anticipates that the final Form will be issued sometime in early 2019.
How to Comment.
This FR notice is a final 30-day due process document. Therefore, comments are due to the FAC by December 6, 2018. Submission instructions are included in the FR notice. Members are encouraged to comment. If you would like your feedback to be considered for inclusion in the Governmental Audit Quality Center (GAQC) response, send your comments to the GAQC at gaqc@aicpa.org by November 28, 2018. Members should also consider informing clients of the proposal since several changes are directed at auditees.
Accessing the Draft Form and Instructions
The FAC has not yet made the draft Form and instructions available on the FAC Web site but it plans to in the coming week. In the meantime, due to the short comment timeframe, the FAC has given the GAQC permission to post the proposed changes. Access the draft Form and instructions on the GAQC Web site.
Latest Changes Proposed
The FAC has prepared a document that summarizes the comments received on the previous due process effort and its response to each comment. This document is useful for purposes of developing your comments and to help you understand why something has changed or not changed. The following are the key changes being proposed to the Form, all of which were included in the previous due process effort:
- The actual text of audit findings will need to be input by the auditor.
- Auditees will be required to include the text of their corrective action plans and the notes to the schedule of expenditures of federal awards (SEFA).
- A new field has been added that will collect information regarding whether the auditor communicated to the auditee, in a written document(s), any issues that were not audit findings but warranted the attention of those charged with governance.
Systematic or other changes, some of which were not included in the previous due process effort, are discussed in either the FR notice or the FAC summary of previous comments received and are summarized as follows:
- Auditees will need to input the date the full, complete report was received from the auditor into the Internet Data Entry System (IDES) so that the federal agencies can track the 30-day aspect of the Uniform Guidance FAC submission due date requirement.
- When a revision to a previously submitted FAC submission occurs, auditees will need to indicate in IDES what has changed and why.
- The FAC has created an option to enter the federal award information and notes to the SEFA prior to the fiscal period end date and the audit work being performed. Users that take advantage of this option, would export an editable, system-generated SEFA and related notes from IDES that could be included in the reporting package that is ultimately submitted.
- IDES will offer a worksheet-type function for the text of audit findings and corrective action plans using an Excel template document that will be able to be downloaded and uploaded.
- The previous estimate of burden hours for large non-federal entities has been revised upward to 100 hours (from 70). The previous estimated burden hours of 21 hours for all other non-federal entities is retained. These amounts reflect the burden on both auditees and auditors individually (i.e., 100 or 21 hours for auditees and another 100 or 21 hours for auditors).
- Non-federal entities that do not meet the threshold requiring submission of a single audit report will be able to voluntarily notify the FAC that they did not meet the reporting threshold and such information will be posted on the FAC Web site.
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Sincerely,
AICPA Governmental Audit Quality Center |
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| GASB Fiduciary Activities |
| If you audit state and local governments, do not miss our upcoming GAQC Web event, Fiduciary Activities: Understanding the Impacts of GASB 84, on November 15, 2018, from 1:00 PM – 3:00 PM (Eastern Time). Big changes are ahead that will have widespread effects that you should plan for. Register now! |
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