OMB New Uniform Guidance Session 1

OMB New Uniform Guidance Session 1


>>HELLO. MY NAME IS DAVID VOGT AND I WANT TO WELCOME
YOU TO THE FIRST OF A NINE PART SERIES ON IMPLEMENTING OMB’S NEW UNIFORM GUIDANCE FOR
INDIAN HOUSING BLOCK GRANT, AND INDIAN COMMUNITY DEVELOPMENT BLOCK GRANT PROGRAMS. IN THIS SESSION, WE’RE GOING TO PROVIDE GENERAL
INFORMATION ABOUT THE UNIFORM GUIDANCE, INFORMATION ABOUT THE WEBCAST SERIES, AND SOME BACKGROUND
INFORMATION ABOUT THE UNIFORM GUIDANCE. LET’S GET STARTED WITH JUST A DESCRIPTION
OF WHAT THE UNIFORM GUIDANCE IS. THE UNIFORM GUIDANCE WAS ESTABLISHED IN THE
FEDERAL REGISTER UNDER 2 C.F.R. 200. THE DESCRIPTIVE TITLE OF THE DOCUMENT IS UNIFORM
ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS. SO AS THE NAME IMPLIES, IT IS COMPREHENSIVE
GUIDANCE. IT’S COMMONLY REFERRED TO AS UNIFORM GUIDANCE,
AND THAT’S WHAT WE’RE GOING TO REFER TO IT AS THROUGH THE WEBCAST SERIES. THIS DOCUMENT CONSOLIDATES EIGHT FEDERAL REGULATIONS
INTO A SINGLE GUIDE. THESE FEDERAL REGULATIONS, THESE EIGHT FEDERAL
REGULATIONS OR OMB CIRCULARS HAVE BEEN IN EFFECT FOR A LONG TIME; THEREFORE, MUCH OF
THE UNIFORM GUIDANCE IS GOING TO LOOK FAMILIAR. IT APPLIES TO ALL FEDERAL GRANTS AND CERTAIN
OTHER TYPES OF FEDERAL AWARDS. THIS GRAPHIC HERE SHOWS THE EIGHT OMB CIRCULARS
THAT HAVE NOW BEEN COMBINED INTO THE UNIFORM GUIDANCE. AS SUCH, THERE’S A SUBSTANTIAL REDUCTION IN
THE VOLUME OF THE MATERIAL. THE GREAT ASSET IS THAT WE DON’T HAVE TO TRY
TO KEEP TRACK OF AND CONNECT WITH THE CORRECT OMB GUIDANCE BECAUSE IT’S CONSOLIDATED INTO
ONE DOCUMENT. AS AN ADMINISTRATOR, THAT’S A FANTASTIC ADVANCEMENT. UNIFORM GUIDANCE INCLUDES MAJOR POLICY REFORMS,
AND AS SUCH, REQUIRES CHANGES TO POLICIES, PROCEDURES, AND PRACTICES. IT CHANGES EXISTING PREVIOUS GUIDANCE; IT
ADDS TO PREVIOUS GUIDANCE, AND DELETES SOME OF THE PREVIOUS GUIDANCE. IT IS 188 PAGES LONG, SO THERE’S A LOT OF
MATERIAL THAT REQUIRES YOU TO BECOME FAMILIAR AND REVIEW THE UNIFORM GUIDANCE. IT ELIMINATES DUPLICATION AND CONFLICTING
GUIDANCE BETWEEN THE DIFFERENT OMB CIRCULARS. THERE’S A SIGNIFICANT CHANGE IN THAT NOW THE
FOCUS IS ON PERFORMANCE AND NOT JUST COMPLIANCE, WHICH WAS THE FOCUS OF THE PREVIOUS OMB CIRCULARS. IT INCLUDES EFFICIENT USE OF INFORMATION TECHNOLOGY
AND TIERED SERVICES. IT PROVIDES FOR CONSISTENT AND TRANSPARENT
TREATMENT OF COSTS. IT REFINES ALLOWABLE COSTS. IT SETS STANDARD BUSINESS PROCESSES AND DATA
DEFINITION. IT ENCOURAGES AND ENABLES FAMILY-FRIENDLY
POLICIES, STRENGTHENS OVERSIGHT AND TARGETS WAIT FRAUD AND ABUSE. LET’S TAKE A LOOK AT THE WEBCAST SERIES THAT
WE HAVE PREPARED FOR YOU. IT PROVIDES AN OVERVIEW OF THE UNIFORM GUIDANCE. OUR FOCUS IS GOING TO BE HIGHLIGHTING AREAS
OF CHANGE. RATHER THAN REVIEWING THE ENTIRE DOCUMENT
IN TOTAL. WE WILL ALSO BE PROVIDING ASSISTANCE TO YOU
IN UNDERSTANDING HOW TO NAVIGATE AND APPLY THE UNIFORM GUIDANCE, INCLUDING PROVIDING
YOU WITH TOOLS TO ASSIST YOU IN IMPLEMENTING THE UNIFORM GUIDANCE. LET’S TAKE A LOOK AT THE WEBCAST SERIES WE
HAVE PLANNED FOR YOU. WE DO RECOMMEND THAT YOU REVIEW ALL NINE OF
THE SEGMENTS; HOWEVER, WE HAVE ORGANIZED IT BY TOPIC SO YOU CAN PICK AND CHOOSE AND GO
BACK AND REVIEW THE AREA OF YOUR PARTICULAR INTEREST. EACH OF THESE SEGMENTS ARE RELATIVELY SHORT,
FROM, SAY, 15 MINUTES TO 45 MINUTES OR SO. LET’S START WITH THE FIRST ONE. OF COURSE, THIS IS THE OVERVIEW AND WE MOVE
INTO NAVIGATING AND ACTUALLY WORK OUR WAY THROUGH THE UNIFORM GUIDANCE BEGINNING WITH
SUBPART A, ACRONYMS AND DEFINITIONS, SUBPART B, GENERAL PROVISIONS, THEN IN THE THIRD SEGMENT,
SUBPART THREE, PRE-FEDERAL AWARD REQUIREMENTS AND SUBPART FOUR, POST FEDERAL AWARD REQUIREMENTS,
AND THAT SECTION IS ACTUALLY COVERED BY THREE DIFFERENT SEGMENTS, FOUR, FIVE, AND SIX. THEN WE GET INTO COST PRINCIPLES, SUBPART
E, THAT’S COVERED IN SEGMENT SEVEN AND EIGHT. AND THEN WE CLOSE OUT WITH SEGMENT NINE, AUDIT
REQUIREMENTS. WE ALSO HAVE A TREMENDOUS AMOUNT OF INFORMATION
TO ASSIST YOU IN IMPLEMENTING AND APPLYING THE UNIFORM GUIDANCE UNDER SUPPLEMENTAL WEBCAST
RESOURCES. WE START WITH THE RED LINED VERSIONS OF THE
UNIFORM GUIDANCE FOR INDIAN HOUSING BLOCK GRANT AND INDIAN COMMUNITY DEVELOPMENT BLOCK
GRANT PROGRAMS. AND THESE ARE ACTUALLY ANNOTATED VERSIONS
OF THE — ANNOTATED VERSIONS OF THE UNIFORM GUIDANCE, AND REFLECTS THE PROGRAM’S SPECIFIC
REQUIREMENTS AND WHAT DOES NOT APPLY BECAUSE OF THE PROGRAM’S SPECIFIC REQUIREMENTS IN
THE UNIFORM GUIDANCE. THEN WE HAVE THE CROSSWALK DOCUMENTS. AGAIN, THIS ACTUALLY COMPARES WHAT IS CURRENTLY
REQUIRED UNDER THE UNIFORM GUIDANCE TO WHAT WAS PREVIOUSLY REQUIRED UNDER THE OMB CIRCULARS. THEN WE HAVE THE CONFORMING AMENDMENTS FOR
HUD PROGRAMS. THIS MODIFIED THE REGULATIONS FOR ALL HUD
PROGRAMS TO CONFORM TO UNIFORM GUIDANCE. AND THE SPECIFIC GUIDANCE FOR THE ONAP PROGRAMS
ARE AT THE VERY END OF THAT DOCUMENT. THEN WE HAVE A PACKAGE OF BACKGROUND AND IMPLEMENTATION
MATERIALS THAT EXPLAINS HOW THIS GOT TO BE AND THE PROCESS IN ADOPTING THE UNIFORM GUIDANCE. WE HAVE A TOPIC INDEX, WHICH IS SIX PAGES
LONG. IT’S IN ALPHABETICAL ORDER BY SUBJECT. AND IT’S CROSS-REFERENCED TO THE CITATION
IN THE UNIFORM GUIDANCE, SO YOU CAN QUICKLY FIND THE CITATION THAT YOU’RE INTERESTED IN. THEN SIX, ASSESSMENT AND UNIFORM GUIDANCE
CHANGES, IMPLICATIONS AND RECOMMENDATIONS SUMMARY CHART. THIS DOCUMENT FOCUSES ON THE CHANGES; IT PROVIDES
INSIGHT INTO THE IMPLICATIONS OF YOUR PROGRAMS AND PROVIDES INFORMATION ABOUT RECOMMENDED
ACTIONS THAT YOU TAKE IN ORDER TO MAKE THE TRANSITION TO THE UNIFORM GUIDANCE. THEN FOLLOWING THAT, IN SEVEN AND EIGHT, WE
HAVE SELF-ASSESSMENT TOOLS TO ASSIST YOU TO ANALYZE YOUR PROGRAMS AND DEVELOP AN ACTION
PLAN TO ADDRESS THE AREAS OF IMPROVEMENT THAT ARE NEEDED. FOLLOWED BY THAT, WE HAVE TWO SAMPLE POLICIES. FINANCIAL MANAGEMENT AND PROCUREMENT POLICY. THESE ARE SAMPLE POLICIES. THEY’RE TO HELP YOU GET STARTED IN MODIFYING
YOUR POLICIES TO CONFORM TO THE UNIFORM GUIDANCE. I MIGHT POINT OUT THAT ONE OF THE CHANGES
IN THE UNIFORM GUIDANCE IS THE REQUIREMENT FOR WRITTEN PROCEDURES. SO THE STANDARD NOW, I THINK, IS HIGHER. IT GOES BEYOND POLICY. IT ACTUALLY REQUIRES PROCEDURES. ALSO, I WANT TO POINT OUT TO YOU THAT THE
COUNCIL ON FINANCIAL ASSISTANCE REFORM WAS CREATED IN ORDER TO ASSIST EVERYONE IN COMING
INTO COMPLIANCE WITH THE UNIFORM GUIDANCE, AND THIS IS A TREMENDOUS RESOURCE, THERE’S
A LOT OF MATERIAL HERE. THIS OF COURSE WOULD BE GENERAL INFORMATION
FOR THE UNIFORM GUIDANCE. INCLUDED ARE MANY VIDEOS, THEY’RE SHORT, THEY’RE
INFORMATIVE. THERE’S ALSO DOCUMENTS AVAILABLE ON THE SITE
TO ASSIST YOU IN UTILIZING UNIFORM GUIDANCE. LET’S TAKE A — JUST A QUICK LOOK AT THE BACKGROUND. HOW DID THIS COME ABOUT? THE OMB CIRCULARS NEEDED TO BE UPDATED FOR
A LONG TIME BUT THE PROCESS GOT KICKED OFF BY PRESIDENTIAL ORDER BACK IN 2009. THEN IN 2011 THERE WAS A MORE DETAILED MEMORANDUM
WHICH REALLY SHOWS INTENT ABOUT WHAT IS DESIRED OUT COME FOR THE UNIFORM GUIDANCE. THAT IS INCLUDED IN THE PACKAGE ON BACKGROUND
IMPLEMENTATION MATERIAL IN THE SUPPLEMENTAL RESOURCE MATERIALS. AND THEN THERE WERE TWO OPPORTUNITIES TO PROVIDE
COMMENTS THROUGH THE OMB PROCESS, AND THE 2012 DOCUMENT IS ALSO INCLUDED IN THE BACKGROUND
AND IMPLEMENTATION MATERIALS. IT PROVIDES INSIGHT AND KIND OF PHILOSOPHICAL
INFORMATION THAT WAS USED IN DEVELOPING THE MATERIALS, WHICH WAS PUBLISHED IN 2013 FOR
COMMENTS AND WAS ISSUED IN FINAL FORM ON DECEMBER 26, 2013. AND THE EFFECTIVE DATE WAS ONE YEAR LATER
FOR GRANTEES, DECEMBER 26TH, 2014. THE OMB AND FUNDING AGENCIES ISSUED A JOINT
FINAL RULE ON DECEMBER 19, 2014, WHERE EVERYONE ADOPTED THE UNIFORM GUIDANCE. SO THIS IS NOW THE RULE FOR ALL FEDERAL FUNDING
AGENCIES. AND THEN AS I MENTIONED BEFORE, THE CONFORMING
AMENDMENTS WERE PUBLISHED ON DECEMBER 7TH, 2015, AND THEY PROVIDE CHANGES TO THE EXISTING
REGULATIONS UNDER PART 1000 FOR IHBG AND PART 1003 FOR ICDBG. SO WHERE ARE WE TODAY NOW? ALL THE FUNDING AGENCIES AND GRANTEES ARE
UNDER THE UNIFORM GUIDANCE BEGINNING ON DECEMBER 26, 2014, UNLESS DIFFERENT PROVISIONS ARE
REQUIRED BY STATUTE OR APPROVED BY OMB. SO WE DO HAVE THE STATUTORY AND REGULATORY
BASIS FOR PROGRAM-SPECIFIC REQUIREMENTS FOR IHBG AND ICDBG, AND AGAIN WE’LL BE REFERRING
TO THOSE AS WE GO THROUGH THE OTHER SEGMENTS. THE QUESTION IS, WHAT ABOUT THE AWARDS THAT
WERE MADE PRIOR TO DECEMBER 26, 2014? WELL, HUD GRANT AGREEMENTS STATE THAT THE
AWARD WILL BE SUBJECT TO REGULATIONS AS AMENDED, THEREFORE ALL THE FEDERAL AWARDS UNDER ONAP
ARE SUBJECT TO THE UNIFORM GUIDANCE. AND THIS IS WHAT A SAMPLE OF THE GRANT AGREEMENT
LOOKS LIKE WHICH INCORPORATES THAT LANGUAGE, AS MAY BE AMENDED. NOW, THERE WERE JUST A COUPLE OF EXCEPTIONS
AS FAR AS IMPLEMENTATION. FOR EXAMPLE, AUDIT REQUIREMENTS, WE ACTUALLY
— THERE WAS ACTUALLY A YEAR TO IMPLEMENT AUDITS COMING INTO COMPLIANCE, DEPENDING ON
YOUR FISCAL YEAR, SO THIS WOULD APPLY TO FISCAL YEARS BEGINNING AFTER DECEMBER 26TH, 2014. AND THEN THERE IS ACTUALLY TWO YEARS TO IMPLEMENT
THE CHANGES FOR PROCUREMENT, AGAIN BASED ON YOUR FISCAL YEAR. SO IF YOUR FISCAL YEAR BEGINS ON SEPTEMBER
30TH — OR ENDS ON SEPTEMBER 30TH, FOR EXAMPLE, THE TWO-YEAR GRACE PERIOD WOULD END ON SEPTEMBER
30TH, 2017. NOW, IT’S IMPORTANT TO NOTE THAT IF YOU ARE
EXERCISING YOUR OPTION TO USE THIS EXTENSION PERIOD TO COME INTO COMPLIANCE WITH THE UNIFORM
GUIDANCE, IT IS REQUIRED THAT YOU DOCUMENT YOUR POLICY TO DEMONSTRATE WHICH SET OF RULES
YOU’RE UNDER. THAT WAY IT’S EXPLICIT FOR AUDITORS AND YOUR
STAFF AS WELL AS HUD TO SHOW WHICH SET OF RULES YOU’RE OPERATING UNDER. THAT COMPLETES THE INTRODUCTORY MATERIAL FOR
OUR WEB SERIES IN A GENERAL OVERVIEW. I INVITE YOU TO WATCH THE REMAINING EIGHT
WEBCAST SERIES AND THANK YOU FOR ATTENDING.

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