THE UGA IS ON FOR DECEMBER. HERE’S WHAT YOU NEED TO KNOW.
Because of COVID-19, there was a pause in the Uniform Guidance Audit. That pause is now over, and the due date to file your audit is 12/31/20.
To help you prepare, here are some key points about the Uniform Guidance Audit (UGA) with links to more in-depth information.
The UGA is a mandatory, annual audit that tests your compliance with the Federal Acquisition Regulations (FAR’s) and your funding agency’s supplemental policies.
You will need to have a UGA completed if you meet the following criteria:
- You have a DOE, NIH, or Army Medical Research grant or any grant with Uniform Guidance Audit embedded in its terms and conditions.
- You’ve spent $750,000 or more during your fiscal year. (This $750k can come from multiple cost-reimbursable awards and includes your subcontractor spending.)
YOU are responsible for hiring the auditor. This must be someone who specializes in government grant awards because their work may be tested. Expect a deep look into your direct and indirect costs, and how they are identified. Go deeper.
Your accounting system and internal controls will be checked. Make sure your business record keeping and financial management are solid and FAR Part 31 compliant. This will include timesheets. Go deeper.
A UGA auditor will look at your SF-425 submissions. If you draw-down grant funds from the Payment Management System (NIH) or ASAP (DOE), you must submit an SF-425 every quarter. Your auditor will want to make sure that you are drawing down funds in a timely manner and can prove that all reimbursed expenses relate to your award. Go deeper.
Subrecipients (direct contractors and consultants) and compliance. Here’s the thing: When you hire others to work on your innovation and further your research, you’re responsible for their compliance and adherence to award regulations and rules. Make sure you can supply a formal, signed agreement and detailed provable invoices. Go deeper.
If there’s a Uniform Guidance Audit finding, it’s not all over. The government isn’t out to get you; they just want you to use their monies properly. If there’s a finding, you will have the opportunity to fix the problem. Yes, this will be checked. Go deeper.
We’re on your side. While we are experts in government award accounting, we do not work as UGA auditors anymore. We prefer to help our clients prepare for and pass audits, as well as represent them during the audit process.
If you need a UGA auditor, we’ll be happy to recommend one. If you want to ensure that your accounting systems, internal controls, and processes are compliant, we’re here to help.
Ed Jameson, CPA, Managing Member
I’ve been in practice for over 40 years helping our small business clients procure, manage, and survive audits on more than $6 billion in federal government contract and grant funding. We’ve been featured presenters and panel moderators at Tech Connect’s National SBIR/STTR conferences since 2011, and I’ve presented at the DOD’s Mentor Protégé Summit and present regularly for several state and local organizations.