RD – NPO Entity and written policies under UG

ID Status Date Public/Private Industry AHACPA Contact
#15088 Closed public Rural Development Les Sparks
Customer Reply

Hi Les,

I have a client – NPO – that received a new MPR last year. It has been my understanding that the MPR is now considered a UG award and they should have written policies and procedures in place. Especially since areas like cash management/draw down of funds and procurement are relevant and applicable to the program during the renovation phase. Do you have any guidance or information that written policies would not be applicable? The Management company does not agree and has never heard of UG requirements for written policies.  It seems I’m the only auditor they’ve ever worked with that has requested this.

Thank you!

Les Sparks

If you are referring to CFDA # 10.447, then you are correct, but only as far as it relates to NFP organizations. If you are a for-profit, then I would not see me using the compliance supplement for anything other than as an idea generator for developing related audit steps. As far as specific policies and procedures, I am a little unclear about what is required. Based on the reading of UG, here is what I found.

200.110 – Effective/Applicability Date.

(a) The standards set forth in this Part which affect administration of Federal awards issued by Federal agencies become effective once implemented by Federal agencies or when any future amendment to this Part becomes final. Federal agencies must implement the policies and procedures applicable to Federal awards by promulgating a regulation to be effective by December 26, 2014 unless different provisions are required by statute or approved by OMB.

Of course, we have the requirement for procurement in 200.317. There are procedures listed in 200.305 under Payment. 

If we look at just the word “procedures” we get the following references:

  1. Financial management .302
  2. Contract cost principles
  3. Real property .311
  4. Equipment .313
  5. Intangible property 3.15
  6. Procurement .317 & .318-.320
  7. .324 Federal awarding agency or pass-through entity review
  8. Pass-through entities .331
  9. Opportunities to object, hearings and appeals .341
  10. Allowability of costs .403
  11. Indirect (F&A) Costs .414
  12. Audit services .425
  13. Lobbying .450
  14. Program-specific audits .507
  15. Scope of audit .514

Okay, after reviewing this list, I will admit to being just a little confused about how all of these things apply specifically to the program. So, to the extent these items apply to my program, I cannot argue that these policies are relevant, but it is hard to develop a specific method of applying  each of these until you get to the individual items you can identify.

Les Sparks



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