As the Uniform Guidance requirements continue to change, keeping up-to-date can be difficult. One commonly asked question is “What written policies should our organization develop to maintain compliance with the Uniform Guidance?”.
Not-for-profits receiving federal funding, either directly from the federal awarding agency or through a pass-through entity, are required to spend awards in a way that is compliant with the Uniform Guidance. Good fiscal management practices ensure federal awards are spent efficiently, effectively and in compliance with regulations. Some of the written policies, procedures and standards of conduct required under the Uniform Guidance include:
- Financial management
- Payment
- General procurement standards
- Competition
- Methods of procurement to be followed
- Subrecipient monitoring
- Compensation- personal services
- Compensation- fringe benefits
- Relocation costs of employees
- Travel costs
Note: This listing is not all-inclusive. There are other required documents surrounding compliance requirements in addition to the listing above. Consult with your CPA or financial advisor for more information.
The implementation date for the Uniform Guidance procurement standard has been delayed several times; however, the new procurement standard will apply to all nonfederal entities with fiscal years that begin on or after December 26, 2017. All not-for-profits with years ending after December 31, 2018 should have written policies and procedures addressing the above requirements.
Failure to institute or update written policies and procedures in compliance with current Uniform Guidance could result in management letter comments and potential audit findings.
Organizations should start reviewing existing policies and procedures to ensure compliance with Uniform Guidance regulations. Reaching out to similar organizations and funding sources for examples of their policies and procedures is a good way to get started.
Our team of not-for-profit experts is here to help. We are strategic advisors who are dedicated to serving the not-for-profit community. We can provide examples of policies and procedures that will help to ensure your organization remains in compliance with federal regulations.
