Issuance: 2018-11 - May 09, 2018

Operations Issuances
Issuance Number: 
2018-11
Date: 
May 09, 2018
To: 
All Service Providers
From: 
Kai Jackson, Director of Finance
Subject: 

FY 2016-2017 Audit Requirements & Questionnaire 

Purpose: 

This operations issuance is to transmit an updated copy of the Subrecipient Questionnaire (Attachment A) for completion and submittal to the San Diego Workforce Partnership (SDWP), and a reference to the Office of Management and Budget (OMB) Uniform Guidance, 2CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F. 

Background: 

AUDIT THRESHOLD 

The OMB Uniform Guidance audit threshold is $750,000. This applies to non-profits and local government organizations that expend $750,000 or more per year in Federal awards (all sources). This includes all Federal awards and not only those awarded under WIOA. SDWP will consider additional compliance monitoring or other actions for agencies with less than $750,000 per year in Federal awards. Non-profit and government organizations may not charge the cost of an audit to WIOA or any other Federal grant, if the organization expended less than $750,000 in total Federal Awards. Note that this Federal rule supersedes and replaces any conflicting requirements in your contracts, including the SDWP Operations Manual and previous Operations Issuances. 

AUDITOR INDEPENDENCE REQUIREMENTS 

An auditor that prepares the indirect cost proposal or cost allocation plan for an organization, when indirect costs exceeded $1 million in the prior year may not perform the organization’s audit required by OMB Uniform Guidance (Attachment B). 

REPORT DUE DATE

The audit reports of subrecipients are to be completed within 9 months after the end of the subrecipient’s fiscal year and are to be delivered to SDWP within thirty (30) days after the completion of the audit. 

The revised OMB Uniform Guidance contains additional requirements, which are less significant, and we encourage organizations to carefully read the OMB Uniform Guidance and appropriately comply with these regulations if they are not already part of the organization’s policies and procedures. The OMB Uniform Guidance is law and must be followed. 

Action: 

SUBRECIPIENT QUESTIONNAIRE REQUIREMENT 

Subrecipients are required to complete and return the attached “Subrecipient Questionnaire” to SDWP no later than Friday, May 18, 2018. This correctly completed questionnaire will help us to identify your audit requirements. This is not a substitute for, or all inclusive of OMB Uniform Guidance requirements. Appropriate personnel in your organization should review this circular and make decisions as to the particular audit requirements applicable to your organization. 

Failure to submit your correctly completed questionnaire by Friday, May 18, 2018 shall result in a suspension of all contract invoice reimbursements and/or other sanctions for your organization. 

If you have any questions regarding this issuance contact your Program Specialist at (619) 228-2900. 

Attachments 

A. Subrecipient Questionnaire

B. OMB Uniform Guidance

cc: Workforce Partnership Internal Distribution List 

Simpson & Simpson CPA’s. LLP