Fall 2010 issue of Horizons

Public Sector/Colleges & Universities – continued

These exceptions notwithstanding, OMB’s risk requirements for ARRA programs make it extremely likely that large programs containing any ARRA funding at all will be subjected to the single audit. SEFA Requirements for ARRA Projects The 2010 Compliance Supplement also contains requirements regarding how ARRA-funded programs are to be presented on the SEFA. Each ARRA-funded program is to be displayed on a separate line on the SEFA. If a given federal program contains both ARRA and non-ARRA funding, the ARRA piece is to be presented on a separate line. Furthermore, each line-item on the SEFA representing ARRA funding must contain the prefix “ARRA”, in order to make the presence of ARRA funding obvious to the auditors and federal agencies that review the SEFA. In order for organizations to be able to prepare the SEFA in accordance with these requirements, they must know whether any federal programs involve

ARRA funding, the amount of this funding, and the corresponding CFDA number. Fortunately, awarding agencies are required by OMB to provide this information to their grantees. However, organizations are reminded that they, in turn, are required to provide this information to subrecipients. Organizations should also disclose the portion of federal funding (including ARRA funding) passed on to subrecipients within the footnotes to the SEFA. Other Compliance Requirements for ARRA Projects Finally, the ARRA legislation contains numerous miscellaneous requirements and restrictions that organizations receiving ARRA funding must observe. As part of the single audit process, auditors will verify that organizations are abiding by these restrictions. The most significant requirements and restrictions are as follows: • Organizations may not use ARRA funds for any casino, gambling establishment, aquarium, zoo, golf course, or swimming pool. • Organizations must verify that their subrecipients are registered on CCR, and that they are having a Single Audit performed if they exceed the $500,000 threshold. Organizations should obtain and inspect their subrecipients’ Single Audit reports. • Organizations using ARRA funding for capital projects must comply with the Davis Bacon Act. This Act requires that, on federally-funded contracts in excess of $2,000, the contractor must pay all laborers and mechanics the prevailing wage rate for the applicable county as determined by the Department of Labor. Organizations should obtain and review the

Raise Your Expectations

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