In recent months, expressly unallowable costs have emerged as a focal point for the Defense Contract Audit Agency (DCAA). DCAA has issued two Memorandums for Regional Directors (MRDs) providing auditors with new guidance on identifying expressly unallowable costs, much to the dismay of contractors who believe that the guidance does not align with the intent of the applicable cost principles. These MRDs likely mean that contractors will receive more penalty recommendations than in years past, in addition to potential assertions of CAS 405 non-compliances. Continue reading Updated DCAA Guidance on Expressly Unallowable Costs
On September 16, Mary Karen Wills and Ryan Byrd were instructors at a webinar concerning non-governmental organizations and federal awards. Continue reading Understanding the New OMB SuperCircular
On August 13, Mary Karen Wills and Ryan Byrd were instructors at a webinar concerning non-governmental organizations and federal awards. Continue reading Understanding the New OMB SuperCircular (Webinar)
Reform of Federal Policies Relating to Grants and Cooperative Agreements; Cost Principles and Administrative Requirements (including Single Audit Act)
By: Mary Karen Wills
The complete text of this proposal and a crosswalk of policy changes from the existing guidance are available on the OMB website under Proposed Policies.
This guidance is applicable to grants and cooperative agreements that involve state, local, and tribal governments, as well as institutions of higher education and nonprofit organizations. The proposal rule seeks to consolidate and streamline the requirements from OMB Circulars A-21, -89, -110 and -122. In addition, Circulars -50, -89, -102, and -133 on audits would be consolidated and streamlined. This guidance seeks to minimize the burden associated with compliance and audits for the grants and cooperative agreements with the aforementioned organizations. The goal would be to replace these eight circulars with one document, resulting in a single set of rules across these entities that currently have varying degrees of requirements.