Uniform Guidance -Single Audit updates. How will the updates impact your organization?

Earlier in 2024, the Federal Government issued updates to the Uniform Guidance (UG).? These updates will impact organizations who receive Federal grant awards and are subject to Single Audit procedures as part of the annual financial statement audit.? Many of the updates are specific to the procedures performed by CPA firms.? However, there are some key updates which impact the responsibilities of organizations who receive Federal awards.

?Effective date:?

?- Generally, the effective date is for awards issued on or after September 1, 2024.

?- For changes which do not apply to individual awards, changes are effective for fiscal years ending 9/30/2025 and after.

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Key changes for organizations.? Let’s start with what is most likely the most popular change:

?Subpart F, 200.501 Audit Requirements:

Threshold for a Single Audit has been increased from $750,000 to $1 million.

?- REMEMBER!? This is effective for fiscal year-ends of September 30, 2025 and after.? If your organization has a fiscal year ending prior to September 30, 2025 you are still subject to the $750,000 audit threshold.

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Other key changes which will impact organizations:

?Subpart D, 200.303 Internal Controls:

Updated guidance indicates that both the recipient of federal awards, as well as a subrecipient, must both establish and maintain adequate internal controls over Federal awards.? In addition, the recipient needs to have controls in place to ensure a subrecipient is maintaining adequate controls over Federal awards.

?Subpart D, 200.303 has also added requirements that recipients of Federal awards need to now maintain reasonable cybersecurity measures to safeguard personnel protected information. ?However, there were no specific examples provided.

?Subpart D, 200.313 Equipment:

The value for equipment disposal with no further responsibility has increased from $5,000 to $10,000.

?Subpart D, 200.317 Procurements by State and Indian Tribes:

Indian tribes are no longer required to follow Federal procurement standards if the tribe has it’s own procurement polies and procedures.

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Subpart D, 200.332 Requirements for pass-through entities:

Pass-through entities are now required to document that potential subrecipients are not suspended, debarred, or otherwise excluded from receiving Federal funds.

?Subpart E, 200.414 Indirect costs – De minimus rate:

Has increased from 10% to 15%.

?Existing Federal awards at transition date, what is the impact?

What is the impact to the requirements of existing Federal awards on the transition date of September 1, 2024?? ?A Federal awarding agency is not required to amend an existing award? to apply the 2024 revisions to the UG.? It is possible that a recipient organization may have multiple Federal awards, some of which were issued under the pre-2024 revisions, and some issued under the 2024 revisions.? It will be the responsibility of each recipient organization to contact the Federal awarding agency to ask if the existing award will be amended to apply the 2024 revisions.? Recipient organizations will also need to inform their CPA firm which UG requirements apply to each Federal award which are subject to Single Audit procedures.

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This article is not meant to discuss all of the changes to the 2024 Uniform Guidance revisions.? Please contact your respective CPA for more information.