Implementing the Super-Circular
Barbara Loescher & Trisha EdwardsFiscal Integrity & Audit Section
Topics for TodayOverview of FIASSupercircular
New administrative requirementsNew cost guidelinesNew audit requirements
What this means for counties Other hot topics
Fiscal Integrity & Audit SectionPurpose is to monitor compliance with rules,
regulations, licensing requirements and contracts to ensure that DCF funding is used appropriately
Created in 2012Consists of section chief and 5 auditorsBasic responsibilities
Desk reviewsOn-site fiscal reviewsInternal audits
Overview - Super-CircularCombines 8 CircularsPublished December 26,
2013Effective Dates
December 26, 2014Single Audits – December
31, 2015Link: See references pageAdditional guidance later
this year
Impact & ObjectivesReduce administrative
burdenReduce fraud, waste and
abuseImprove program integrityStrengthen accountabilityShift from legacy awards to
merit awardsMore oversight required for
pass-through agencies
Administrative Requirements ReformsPerformance goals &
reporting, cost effectiveness and collaboration
Technology changesComputers now
suppliesFlexibility in
document retentionStandardized
requirements and definitions
Administrative Requirements ReformsStronger oversight
Conflict of interest policies
Internal controlsHow audit results
are treatedSub-recipient
monitoring
Cost Principles ReformsAll entities – same
guidanceExcept for-profit agencies
Indirect/direct costsWritten cost allocation planNo universal rule except
consistencyTime and effort reporting
Emphasis on internal controls rather than PARs
Cost Principles ReformsChanges to specific items of
costAdvertising“Employee morale” costs
eliminatedEntertainmentConference spendingFines, penalties, damages
and other settlementsCollection of unallowable
costsHome officesAnd others
A-133 Audit ReformsSingle audit threshold
increased$500,000 to $750,000
Type A programs increased$300,000 to $750,000
Risk criteria has changed
Questioned costs threshold increased$10,000 to $25,000
A-133 Audit ReformsRepeat findingsCompliance areas
Still not sureWill be published
4/15/2015Online publication of
reportsFederal Audit
Clearinghouse
How Does This Affect Counties?Changes to your
contracts with DCFDiscuss with Executive
committeeChanges to county
contracts with providersNew languageNew referencesNew allowable cost
requirementsNew audit requirements
for 2015 audits
More Ways It Affects CountiesMay be less auditing
for A-133 auditsTraining by DCF for
county financial managers through rest of 2014
New State Single Audit Guidelines for 2015 audits
DCF Oversight of Providers• FIAS Fiscal Reviews:
• Compliance with laws and licensing requirements
• Financial stability• Allowability of costs• Fiduciary responsibility• Contract compliance• Fraud and abuse• Overpayment recovery• Includes all agencies
receiving DCF funding
Fiscal Reviews ResultsInsight from the
trenchesLuxury vehiclesGhost vehicleLavish tripsFraudulent invoicesRelated party
transactionsPersonal items“Me first” mentalityHome office Holiday parties
Box Bucks ticketsGas allowancesATM withdrawalsUndocumented
itemsDonationsOverdraft chargesUnreasonableUnnecessary
County Fiscal ReviewsExpanding into
county fiscal reviewsScheduling first
wave in coming months
Review centered on:Cost allocationAllowable costsSub-recipient
monitoring
Allowable Cost Policy Manual UpdateMajor re-writeCurrently being
reviewed internallyTo be discussed with
Executive CommitteeCurrent (tentative)
ETA – before year end
In ClosingRead the Super-
CircularContinue spending
public funds prudently
Update your contracts
The ACPM is comingAnd we’ll see you
soon!
For Further InformationBarbara Loescher, CIAChief, Fiscal Integrity & Audit SectionDepartment of Children & Families(608)[email protected]
Trisha Edwards, CPAAuditor – SeniorDepartment of Children & Families(608) [email protected]
Questions?