OMB Proposes Changes to Data Collection Form
The current Form SF-SAC, Data Collection Form for Reporting on Audits of States, Local Governments and Non-profit Organizations (Data Collection Form), is being updated for Single Audits performed in accordance with the OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The Office of Management and Budget (OMB) proposed changes to the Data Collection Form and the Data Collection Form instructions.
The proposed changes include revisions to the Data Collection Form that reflect Uniform Guidance Requirements, revise some existing data elements, and add data elements that are expected to make the reports easier for federal agencies, pass-through entities, and the public to use. The proposed changes also delete data elements no longer needed.
Some of the significant proposed changes include the following:
- Cluster Identification. An entity will report whether a program is part of a cluster of programs and, if so, the type of cluster. If the program is not identified as being direct, fields are provided for the name and identifying number of the pass-through entity.
- Federal Program or Cluster Totals. A field will be added to report the total federal awards expended for each federal program.
- End of Audit Period Loan Balance. An entity will disclose loan or loan guarantee balances outstanding at the end of the audit period.
- Subrecipient Information. The amount of funds passed through to subrecipients will now be identified.
- Special Purpose Framework Identification. The financial statement information section collects information when financial statements are prepared in accordance with a special purpose framework.
- Repeat Audit Finding(s). Repeat audit finding(s) from the prior-year audit and any applicable prior-year audit finding reference numbers will be disclosed.
- Primary Type of Compliance Requirements. When an audit finding is disclosed, the type of compliance requirement that led to the finding must be identified.
- Certification Statements. The auditee will certify that the reporting package does not include protected personally identifiable information and will authorize the Federal Audit Clearinghouse (FAC) to publish the reporting package on a publically available website.
For fiscal years starting on or after December 26, 2014, the FAC also proposes to allow nonfederal entities that did not meet the threshold requiring submission of a Single Audit report to voluntary notify the FAC that they did not meet the reporting threshold.
When adopted, the changes will be effective for 2015 audits to align with the implementation of the Uniform Guidance.
Practical Consideration: The proposed Data Collection Form is available at www.whitehouse.gov/sites/default/files/omb/assets/grants_forms/sf-sac-form.pdf and the proposed instructions are available at www.whitehouse.gov/sites/default/files/omb/assets/grants_forms/sf-sac-form-instructions.pdf .
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