Uniform Guidance was implemented over two years ago, but many Federal award recipients are still challenged by compliance and struggle with the organizational changes necessary to meet the requirements. By following some simple best practices developed by organizations already successfully achieving compliance, non-Federal entities can easily implement policies and procedures to thrive under Uniform Guidance.
Understand the Requirements
The first step for any non-Federal entity subject to Uniform Guidance is to clearly understand what is applicable to you! If management doesn’t already have a solid understanding of Uniform Guidance, now is the time to review the guidance and the award agreements in detail, to determine which areas will have the greatest impact on your operations. Planning ahead will allow your organization to avoid wasting time, effort and valuable resources. Additionally, contact your auditors to discuss any newly-released changes or “hot topics” that you should be aware of.
Whose responsibility is it in your organization to make sure you’re compliant? It depends. Non-federal entities vary dramatically with regard to their size, structure, resources and funding, so responsibility for different aspects of compliance will be different from one organization to the next. For example, stages of procurement may be handled by separate departments. Within your organization, clearly define who is responsible for key parts of the regulations to avoid mishaps.
Changes governing Federal awards dictate that most non-Federal entities revisit their policies and procedures to ensure alignment with the updated regulations. Uniform Guidance requires written policies for a number of various topics. To be sure you are implementing effective and compliant internal controls, start by updating your policies.
If compliance is a challenge for your organization, now is the time to seek help. For questions regarding Uniform Guidance, contact Jennifer Arminger at 301-664-7675 or email@example.com. You can also view a recent webinar on Uniform Guidance at https://www.grfcpa.com/resources/publications/ug-sub-recipient.