Operations Issuance: 2020-15
Issuance Number: 2020-15
Date: May 6, 2020
To: Workforce Partnership Subrecipients
From: Kai Jackson, Director of Finance
Subject: FY 2018-2019 AUDIT REQUIREMENTS & QUESTIONNAIRE
Purpose:
This informational 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:
Subrecipients are required to complete and return the attached “Subrecipient Questionnaire” to SDWP no later than Wednesday, May 20, 2020. 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 Wednesday, May 20, 2020 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 contract administrator at (619) 228-2900.
Attachments: