Proposed Data Collection Form Changes

The Office of Management and Budget released changes to the current Data Collection Form related to reporting on Audits of States, Local Governments, Indian Tribes, Institutions of Higher Education and Not-for-profit Organizations (“Data Collection Form” or “DCF”) for future single audits performed in accordance with Uniform Guidance.

What’s changing?

The revised DCF proposes having full text availability for certain elements within the DCF, including:

1. Any management letter comments for matters communicated in writing that were not audit findings, but still warranted the attention of management or those charged with governance.
   • Notes to the Schedule of Federal Expenditures (SEFA) that contain such information as a description of the significant accounting policies used in preparing the SEFA and whether the de minimis cost rate was used.
2. Verbiage of any audit findings as they appear in the Schedule of Findings and Questioned Costs, as well as the actual text of the corrective action plans as they appear in the Corrective Action Plan.

Not-for-Profits should note that, while the proposed DCF requests information on audit findings, corrective action plans, and notes to the SEFA, this information was already required to be submitted to the Federal Clearing House as part of an organization’s submission. The difference, in particular with this proposal, is that the written data or text is actually entered into the DCF document, allowing for more readily-available and easily-searchable data.

The inclusion of the management letter comment requirement was not previously required to be included in the DCF submission, or with the single audit reporting package. As such, organizations that in the past have received such a management letter, should carefully consider the impact such items may also have to the organization, if not resolved.

If these proposed changes are fully adopted, they would be become effective for fiscal periods ending in 2019, 2020, and 2021. Until such time, organizations should continue to utilize the existing form.

Other Resources 

• Federal Clearing House Website 
• Proposed Data Collection Form & Instruction
  

How we can help

Citrin Cooperman’s Not-for-Profit practice professionals can assist you in further understanding the proposed changes to the Data Collection Form and how the new requirements, in particular those surrounding internal controls and management letter items, may impact your organization.