The document is a presentation by Mary Lee Brown from February 2013, delivered at a COGR meeting, that examines key aspects of the Proposed OMB Uniform Guidance on Audit Requirements (Subchapter G, pages 135–163), which consolidates Circulars A-133 and A-50. The guidance aims to enhance federal agency oversight, targeting improper payments, waste, fraud, and abuse by increasing the efficiency and effectiveness of required audits. Major changes include raising the audit threshold from $500,000 to $750,000 in federal expenditures, clarifying requirements for subrecipients and contractors, and adjusting several reporting and responsibility requirements for auditees and agencies. Notably, the guidance streamlines various audit processes, such as removing certain extension authorities, eliminating specific report submissions to pass-through entities, mandating electronic report submission, and redefining criteria for major program determination with higher risk-based thresholds and reduced coverage rules.
The summary also highlights changes to the compliance supplement: seven of fourteen compliance requirements remain, focusing on core issues such as allowable activities and costs, cash management, eligibility, reporting, subrecipient monitoring, and special provisions, while seven others—such as Davis-Bacon, equipment management, period of availability, and procurement—are proposed for elimination, though provisions remain for their reinstatement if required by statute or agency needs. Overall, while many of these revisions are deemed beneficial in enhancing focus and reducing administrative burden, the assessment of their impact is nuanced, with several changes carrying both positive and negative implications depending on stakeholder perspective and specific organizational context.
