All of the changes in The Data Collection Form Submitted To the Federal Audit Clearinghouse
The Data Collection Form which is annually submitted to the Federal Audit Clearinghouse has changed again for fiscal years ending in 2019. In addition to the form changing from blue to purple, it has undergone several other changes that are more noteworthy.
Part I which contains all the general information such as auditee name, fiscal year, contact name and various auditor related information remains unchanged for 2019. Part II requires the identification of all the federal awards expended by the auditee. If you recall the most recent changes to this section asked for the identification of the program cluster, loan balances (if known), and additional passthrough information. The first page of Part II did not change or ask for additional information. Where we start to see the most major changes to the 2019 form is found on page 2 of Part II.
Most Notable Changes in the New Data Collection Form
Part II, question 2 is titled “Notes to the Schedule of Expenditures of Federal Awards (SEFA).” Note 1 on this page asks the auditee to “Describe the significant accounting policies used in preparing the SEFA.” This requirement is taken directly from 2 CFR 200.510(b)(6). Auditees’ single audit reports should already contain this note, so in order to comply with the new data collection form requirement, auditees can simply copy from their single audit report to an input on the data collection form. There is a 4,000-character limit on this entry, more generous than most forms.
Note 2 of Part II to the Schedule of Expenditures of Federal Awards asks whether the auditee used the de minimis cost rate as noted at 2 CFR 200.414(f). It is a basic “Yes or No” question with a small twist. There is a third option for an answer, and it is “Both. Please explain.” The instructions to the form do not really provide an explanation if you choose “Both,” and it may be the correct option for you if during the year of using the de minimis cost rate the auditee was provided with a negotiated indirect cost rate. So technically, these used both rates during the year. It is important to remember that entities who have NEVER applied and received a negotiated indirect cost rate can be using the de minimis rate and “step” up to the negotiated indirect cost rate, but you cannot go the other way and switch back to the de minimis cost rate.
Indirect Cost Rates & Additional Notes
The significant accounting policy and indirect cost rate notes are the only notes contained on this revised form, however, it is quite easy to add additional notes to the schedule of expenditures of federal awards. Common notes seen in single audits that should be added to the data collection form would be information on subrecipients, noncash transactions, loan information, and federal insurance. All you need to do is click the “Add a Note” button, name it and copy from your single audit report.
Part III, page 1, which is entitled “Information from the Schedule of Findings and Questioned Costs,” does not have any changes from the prior version of the data collection form until you get to question 4. For each finding the form asks you to include the total amount expended for the program to which the finding relates. The requirement to add amount expended is found in column D of question number 4.
Question 5 of Part III requests the “Audit Finding Reference Number” and “Text of the Audit Finding”. Once again this will simply be an exercise of copying the single audit finding information from the auditee single audit report into this form.
Part IV is where we find the last change to the form. It is closely related to Part III, question 5, which contains information on each single audit finding. Part IV then asks for finding a reference number and text of corrective action plan. Once again this is nothing more than an exercise of copying information the auditee would already have.
In conclusion, we have seen the data collection form evolve over the last several revisions with the main purpose to gather more data on single audits and with the goal to improve quality in the single audits. With this increased availability of data, the Office of Management and Budget should be able to identify areas that auditees and auditors can improve the performance and reporting on Single Audits.