Internal Controls for Federal Grants

Internal Controls for Federal Grants

Terenzio Volpicelli, CPA, Partner

Roselli, Clark and Associates MMAAA June Annual Meeting South Yarmouth, Massachusetts

June 13, 2018

Agenda

What are internal controls What does the Uniform Guidance say about I/C Green Book/COSO Common sense implementation Recent adoption project

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What are Internal Controls

? 200.61 Internal controls Internal controls means a process, implemented by a non-Federal entity, designed to provide reasonable assurance regarding the achievement of objectives in the following categories: (a) Effectiveness and efficiency of operations; (b) Reliability of reporting for internal and external use; and (c) Compliance with applicable laws and regulations.

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What are Internal Controls over

Compliance with Federal Awards

? 200.62 Internal control over compliance requirements for Federal awards

Internal control over compliance requirements for Federal awards Means a process implemented by a non-Federal entity designed to provide reasonable assurance regarding the achievement of the following objectives for Federal awards:

(a) Transactions are properly recorded and accounted for, in order to:

(1) Permit the preparation of reliable financial statements and Federal reports;

(2) Maintain accountability over assets; and

(3) Demonstrate compliance with Federal statutes, regulations, and the

terms and conditions of the Federal award;

(b) Transactions are executed in compliance with:

(1) Federal statutes, regulations, and the terms and conditions of the Federal

award that could have a direct and material effect on a Federal program; and

(2) Any other Federal statutes and regulations that are identified in the Compliance

Supplement; and

(c) Funds, property, and other assets are safeguarded against loss from unauthorized use or

disposition.

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Uniform Guidance

Title 2 US "Code of Federal Regulations" (CFR) Part 200, "Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards"

Referred to as "The Uniform Guidance"

Issued December 26, 2013 with an effective date for audits of fiscal years that begin after December 26, 2014 for non-Federal entities; (Massachusetts for fiscal years ending June 30, 2016 forward)

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Non-Federal Entites

Non-Federal entities include:

o States and Commonwealths o Agencies of States and Commonwealths o United States possessions o Indian Tribal Governments o Cities o Towns o School Districts o Special Purpose Districts o Housing Authorities o Redevelopment Authorities o All other Authorities and Districts o Non-Public Organizations

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Section 303 ? Internal Control

? 200.303 Internal controls

The non-Federal entity must:

(a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ``Standards for Internal Control in the Federal Government'' issued by the Comptroller General of the United States and the ``Internal Control Integrated Framework'', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).

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Focus of Section 303

The focus of the Uniform Guidance is internal control over grant administration and reporting

Best practices would be to implement Green Book throughout the organization

Schools Enterprises City/town

However, the requirement is grant administration

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