What You Need to Know about Head Start’s New Uniform Administrative Requirements, Cost Principles, and Audit Requirements

In December, the Office of Head Start issued an Memorandum titled New Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. The two things that are important to note are the increase of the single audit threshold from $500,000 to $750,000 for fiscal years beginning on or after December 25, 2014 and the name change from delegate agency, grantee, grant funded organization and sub-recipient to “Non-Federal Entity”.

OHS will hold a webinar on Feb. 10, 2015 to answer questions about the new regulations. Questions can be submitted in advance to fiscalwebinar@hsicc.org.

From the Memorandum…

Non-Federal Entities:
The new uniform administrative requirements, cost principles, and audit requirements (collectively the new fiscal regulations) replace use of the terms “grantee,” “grant funded organization,” “delegate agency,” and “sub-recipient” with uniform use of the inclusive term “non-federal entity” (NFE). This Memorandum will use the terms “non-federal entity receiving Head Start funds” or “NFE” to refer to all covered entities.

Audit Threshold:
The regulation has increased the single audit threshold from $500,000 to $750,000. NFEs receiving at least $750,000 in federal funding from all sources (including Head Start, Early Head Start, and Early Head Start-Child Care Partnership awards) are subject to the single audit requirement for fiscal years beginning on or after Dec. 26, 2014.

Supersession and Impact on the Head Start Act and Performance Standards:
The new regulations, when effective, supersede all current audit circulars and cost principle guidance currently codified under Title 2, Code of Federal Regulations (2 CFR 215, 2 CFR 220, 2 CFR 225 and 2 CFR 230). Grants management regulations at 45 CFR Part 74 and 45 CFR Part 92 are also superseded. NFEs should implement the new regulations as written, but anticipate codifying regulations from the Department of Health and Human Services (HHS) to be found at a new 45 CFR Part 75. An issuance date is not known at this time. Fiscal compliance requirements of the Head Start Act and the Head Start Performance Standards also remain in effect and are not superseded by the new regulations.

Tags: administrative requirements, audit requirements, cost principles, fiscal management, grants administration, grants managements