| Dear Center Members: |
This GAQC Alert provides you with information on the following:
- Registration information for the December 15, 2023, GAQC Web event, Key Recipient Roles and Responsibilities in Single Audits;
- Updates on the new General Services Administration (GSA) Federal Audit Clearinghouse (FAC), a no-CPE archive of our recent GSA FAC Web event, and future related GAQC CPE opportunities;
- An update from the Federal Communications Commission (FCC) on the applicability of single audit requirements to Assistance Listing Numbers (ALN) 32.004 and 32.005; and
- Guidance issued by the Federal Emergency Management Agency (FEMA) regarding duplication of benefits.
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UG Recipient Roles and Responsibilities Web Event
You can now register for the next live GAQC Web event, Key Recipient Roles and Responsibilities in Single Audits, on Friday, December 15, 2023, from1:00 PM – 3:00 PM (Eastern Time). This Web event will discuss the Uniform Guidance (UG) definitions of a pass-through entity, subrecipient, contractor, and beneficiary, and outline best practices to correctly identify and report them. Topics to be covered include the following:
- Responsibilities and characteristics of each of the key roles and related auditor considerations;
- Common errors and instances of noncompliance; and
- Best practices, tips and available resources and tools.
GAQC Member Registration with CPE (fee). Access the member CPE registration page.
GAQC Member Registration with no-CPE (free). Access the member no-CPE registration page.
Public Registration with CPE (fee) (to share with your clients). Access the public CPE registration page.
GSA FAC Update
The no-CPE archive is now available of the GAQC's November 8, 2023, Web event on the new GSA FAC and the process for submitting Data Collection Forms. We are also planning a CPE rebroadcast of the event soon and, given the number of questions received, will hold a follow-up FAC lightning round Web event in early 2024 to help provide further clarity on a number of issues. Watch for future registration information.
The new GSA FAC was released as a "minimal viable product" which means GSA is continuing to work to improve various underlying processes. As a result, improvements are being made by the GSA on a regular basis. For example, GSA recently launched a new search function and search resources that will likely be enhanced over time. We encourage you to regularly visit the FAC Update page, which identifies the GSA's current improvement priorities, and the FAC Help Center, which includes answers to frequently asked questions.
FCC Update
As we have previously informed you, the FCC had planned that ALN 32.004, Universal Service Fund – Schools and Libraries, and ALN 32.005, Universal Service Fund – Rural Health Care, would become subject to single audit at some point in the future. This FCC position was included on the SAM.gov pages for these programs. After much discussion and advocacy regarding the challenges surrounding the previous decision, the FCC has announced a change of course. The SAM.gov pages for both 32.004 and 32.005 have recently been revised and now state that each of the programs are "excluded from coverage under 2 CFR 200, Subpart F - Audit Requirements." This is good news for all involved in audits of school districts and rural health care providers. SAM.gov does include a reminder for both programs that participants may still be subject to other program compliance audits that are overseen by the FCC.
FEMA Duplication of Benefits
Federal law and FEMA guidance prohibit FEMA from covering costs that are eligible for coverage by another source, referred to as "duplication of benefits" (DOB). FEMA has been actively reviewing the potential DOB provided to recipients from awards received under ALN 97.036, Disaster Grants – Public Assistance. If you have single audit clients with this funding, you should consider relevant guidance that FEMA issued in October 2022 titled, COVID-19 Patient Care Revenue Duplication of Benefits. The 2023 Office of Management and Budget (OMB) Compliance Supplement section for ALN 97.036 was also updated (in the Allowable Costs/Cost Principles requirement subsection) to raise awareness of FEMA's concerns in this area and to make auditors aware of the FEMA DOB guidance.
FEMA's concerns primarily relate to entities that may have claimed eligible costs for medical care that was also covered by patient care revenue, including insurance proceeds. The FEMA guidance outlines the risk-based approach the agency is using to review projects for potential DOB, as well as the review and reduction processes when a DOB has been found to occur.* * * * *
Sincerely,
AICPA Governmental Audit Quality Center |
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| In This Alert |
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| UG Comments Due Soon |
| Comments on the proposed revisions to the Uniform Guidance are due December 4, 2023. Members are encouraged to comment on regulations.gov. If you identify specific areas of note for our consideration as we develop the GAQC response, e-mail them to us by November 27th at gaqc@aicpa.org. |
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| Additional Resources |
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| Stay Informed |
We welcome any suggestions or questions - please send them by e-mail at GAQC@aicpa.org.
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