Filed under: Federal Grant & Contract Consulting
By Kelly Rancourt, CPA
In July 2016, the Census Bureau, under the Federal Audit Clearinghouse (FAC), released the newest version of the data collection form (DCF) for Single Audits performed under both the Single Audit Act of 1984 (amended in 1966), and Title 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, or the “Uniform Guidance.” The FAC serves as a central repository of all required Single Audits – compiling and monitoring the related data for over $1.1 trillion in Federal assistance, annually.
Federal Agency Inspector Generals and other grant administrators, including pass-through agencies, perform the data monitoring. The DCF is the electronic form completed and certified by organizations and their auditors. It includes the data from the organizations’ Single Audits, such as the Schedule of Expenditures of Federal Awards (SEFA) amounts, audit results and findings, and organizational and auditor information, including EIN, address, and certifier’s name and contact information.
Each year, the FAC implements updates to the DCF. With the implementation of the Uniform Guidance for Single Audit requirements, the current year’s DCF changes have been significant. In addition, the Digital Accountability and Transparency Act of 2014 focuses partially on the transparency and accessibility of information surrounding Federal expenditures. This also had an effect on the changes made to the DCF and the information now available on the FAC website.
Organizations submitting their DCFs should be aware of the major changes of the 2016 data collection form. and areas on which to focus their review prior to submission. An organization that is required to obtain a Single Audit is also required to complete a corresponding DCF each fiscal period.
The significant changes to the 2016 updated DCF include the following:
Username and Password
Each user must have a unique username and password set up in order to access the DCF for their Organization. This requirement is not a new requirement, but organizations should be aware of the setup. Your username will be your primary email address (traditionally a work email). Additionally, the website requires all users to reset their passwords every 90 days as part of the information technology controls for the site.
Accurate and Timely Submission
The due date of the DCF has not changed in the current year. However, it is important to note that it is the auditee’s responsibility to ensure that the DCF is submitted timely and accurately. The due date for the data collection form is the earlier of 30 days after receipt of the Single Audit Report or nine months after the organization’s year-end.
Please note that from time to time, the DCF is not available due to updates on the FAC website, and the FAC will issue an extension to the due dates. However, any extensions granted for the due date do not apply to the completion of the Single Audit and the organization must still complete its Single Audit prior to the nine-month deadline.
Single Audit Thresholds
With the implementation of Uniform Guidance, the threshold for requiring a Single Audit has increased from $500,000 to $750,000 in Federal expenditures in any year for fiscal periods beginning after December 26, 2014. Single Audits for fiscal periods prior to this date are still subject to the $500,000 threshold. The new $750,000 threshold is referenced in the 2016 DCF. Once the DCF is started, the fiscal period noted in the creation of the form cannot be changed, as the fiscal period dictates the type of DCF that is generated by the FAC website.
Certifying Officials
As with prior DCFs, the updated 2016 DCF requires the Auditee Certifying Official’s and the Auditor Certifying Official’s contact information, including their email address, so they can electronically certify the DCF after completion and review. It is important for organizations to consider who is certifying the DCF on behalf of the organization and establish an internal policy that clarifies who is authorized to sign on behalf of the organization.
Multiple EINs or DUNS
If the auditee has multiple Employer Identification Numbers (EINs) or Data Universal Number System (DUNS) numbers that are covered under the Single Audit, the organization should review the DCF to ensure all are properly included. There is a separate tab within the DCF that allows organizations to add additional EINs or DUNS.
CFDA Numbers
Each award from a Federal agency is issued a five-digit number in the Catalog of Federal Domestic Assistance (CFDA). It has a two number prefix that identifies the Federal agency from which the funds originated. The CFDA three-digit extension is assigned based on the specific Federal program.
The DCF requires that organizations’ Federal expenditures be entered into the form by each award’s CFDA number. The new 2016 DCF pre-populates the Federal programs’ names if the CFDA number is entered properly. If the CFDA number is unknown for an award, the CFDA must be entered with the two number prefix for the specific Federal agency.
The three-digit extension is then designated with a “U” plus two additional digits. If the award is part of the Research and Development Cluster, the three-digit extension is replaced with “RD” if the CFDA number is unknown. Note that the 2016 DCF accepts only a three-digit extension or less, versus the previous DCFs, which accepted many digits and characters.
The three-digit extension makes similar data easier to track and compile in the database. A CFDA number may be unknown if it is not communicated within the award agreement.
New Federal Award Fields
The 2016 DCF includes a number of new fields that should be reviewed in detail. One new field is “Additional Award Identification.” If the CFDA three-digit extension number is not known, this field is required and generally is the grant award number. Otherwise, this field is treated as optional.
Additionally, if the organization receives pass-through federal funds from state, local, or other not-for-profit entities instead of directly from the Federal agency, it is required to include the pass-through award number on the SEFA (if known). There is another new field in the DCF to include the pass-through award number and name of the pass-through entity, if applicable.
Lastly, if the organization passes any of the funds it receives to sub-recipients, the amount of passed through funds must be reported on the face of the SEFA instead of disclosed in the footnotes, as was previously done. Because of this, the DCF now includes a field to report the dollar amount of funds passed through to sub-recipients for each federal award. The organization is not required to note the entity to which those funds were passed. The 2016 DCF now will auto-generate Federal program totals and cluster totals based on the information provided.
The FAC website also includes a worksheet to help populate the data for the Federal awards for the DCF. The tool consists of an Excel file, which organizations can populate with each individual award as it appears on their SEFA. Organizations can then directly uploaded it to the DCF, instead of needing to enter each Federal award into the DCF manually.
Audit Results
The DCF includes a section for the organization to document the results of the audit. The information in this section includes the audit of the financial statements, internal controls and compliance over major programs, the Type A and Type B threshold, whether the auditee was considered a low-risk auditee, and whether there were any prior year findings. The organization should review this area in detail to ensure all audit information is properly reflected from the Single Audit Report.
Federal Award Audit Findings
As with prior versions of the DCF, there is a section that covers Federal awards audit findings. The majority of the finding information will prepopulate based on how the Federal award fields were completed, as there is an area to note which audit finding an award related to (if any).
The remaining fields must be completed by the individual drafting the DCF and should be reviewed in detail by the organization to ensure that all items noted are correct. It should be noted that each finding must have an assigned finding number in the format of: four-digit audit year, a hyphen, and a three-digit number. The FAC website also includes an Excel finding worksheet that can be uploaded to the DCF. It includes all required fields to make completing this section easier.
Finalization and Audit Report Submission
The DCF can be finalized once all sections are completed. The system will perform a data check to ensure all fields are completed. However, there is not a check to ensure the actual information is accurate. Therefore, a full review of the DCF should be performed by the organization.
Once the DCF is finalized, the final audit report can be uploaded to the system, the DCF can be certified by the auditor and auditee, and the DCF package can be submitted to FAC for processing. The final audit report must include the financial statement audit and the Single Audit and must be uploaded as a searchable PDF.
Under 2 CFR 200.512(b)(1) of the Uniform Guidance, the DCF and the audit reporting package are now publicly available for download from the FAC website. Organizations should be aware that their financial statement audits and Single Audit reports will now be available to the public.
While these are some of the key areas and major changes to the 2016 DCF, this list is not comprehensive of the entire DCF, or its 2016 updates. We recommend that organizations read the instructions for the DCF that are included on the FAC website before reviewing and submitting their current year’s DCF.
For further resources and information on the Data Collection Form required as part of a Single Audit, please refer to the following:
Federal Audit Clearinghouse: https://harvester.census.gov/facweb/Default.aspx
Federal Audit Clearinghouse – Important Notices: https://harvester.census.gov/facdissem/main.aspx
Federal Audit Clearinghouse – Frequently Asked Questions: https://harvester.census.gov/facweb/FAQs.aspx
Federal Audit Clearinghouse – Instructions and Documents: https://harvester.census.gov/facides/
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