understanding omb compliance supplement addendum · 2021. 2. 3. · hhs – 93.914 – hiv...

Understanding OMB Compliance Supplement Addendum

COPYRIGHT © 2021 NAFOA. ALL RIGHTS RESERVED.

Kris Nixon, CPA

Kris has over 20 years experience in the Tribal auditing world.

This experience includes work with various Tribal entities and their Governments.

Partner, Stauffer & Associates PLLCP. (509) 344.3200 E. [email protected]


mailto:[email protected]

COVID-19 ImplicationsTribes received funding from various sources related to COVID◦ Should track down the source of the funding, find out the requirements◦ Tool to help find the source of the funding:◦ https://beta.sam.gov/

On the SEFA, recipients are required to note the COVID-19 assistance on the separate line


https://beta.sam.gov/

Single AuditWhen are single audits due?◦ September 30, 2019 – Due December 31, 2020◦ December 31, 2019 – Due December 31, 2020◦ March 31, 2020 – Due March 31, 2021 (if received COVID funding)◦ June 30, 2020 – Due June 30, 2021 (if received COVID funding)◦ September 30, 2020 – Due September 30, 2021 (if received COVID funding)◦ December 31, 2020 – Due September 30, 2021 (normal due date)

This does not change requirements of your debt agreements or other deadlines. Have a conversation with those entities.


COVID-19 ImplicationsFrom Clearinghouse:◦ No further action is required to enact this extension. Individual recipients and

subrecipients are required to maintain documentation of the reason for the delay, and are requested to include a reference to the memorandum in their audit reporting packages so that Federal agencies and pass-through entities are informed.


PROGRAMS COVERED BY ADDENDUMUSDA – 10.001 – Programs Impacted by COVID Wavers

HUD – 14.862 – Indian Community Development Block Grant Program

DOJ – 16.034 – Coronavirus Emergency Supplemental Funding

DOT – 20.218 – Motor Carrier Safety Assistance Program (New Cluster)

Treasury Department – 21.109 Coronavirus Relief Fund

FCC – 32.006 – COVID-19 Telehealth Program

Education – 84.425 – ESF Education Stabilization Fund Under CARES Act

84.425 - HEERF Education Stabilization Fund Under CARES Act


PROGRAMS COVERED BY ADDENDUMHHS – 93.153 – Coordinated Services for WIC

HHS – 94.361 – COVID-19 Testing for the Uninsured

HHS – 93.498 – Provider Relief Fund

HHS – 93.914 – HIV Emergency Relief Project Grants

HHS – 93.917 – HIV Care Formula Grants

HHS – 93.918 – Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease

Student Financial Assistance – Update for this Cluster


COVID-19 ImplicationsFrom Compliance Supplement:

Not all COVID funding is in the compliance supplementObtain grant paperwork on all new funding◦ Outlines terms and conditions of funding◦ Can change the terms of current non COVID programs


COVID-19 ImplicationsFunds passed through to sub-recipients, requirements are to:◦ Identify each subrecipient◦ Document at the time of subaward and at the time of disbursement:◦ The federal award number◦ CFDA number◦ Amount of COVID-19 funds

Subrecipients are subject to the single audit

Subrecipient vs beneficiary

NAFOA Letter from Treasury Department


https://nafoa.org/resources/u-s-dept-of-treasury-reply-to-nafoa-regarding-faq-no-b-13-regarding-crf-beneficiary-vs-subrecipient-clarification-11-20-2020

Allowability of CostsPrior Approval◦ Agencies are authorized to waive prior approval requirements necessary to

address the COVID response◦ All costs must be consistent with guidelines, other than as outlined in

memorandum M-20-17, expired in June and replaced with M-20-26

Awarding agencies may allow wages charged to programs consistent with policies of entity under extraordinary circumstances

Many grants have published program guidance◦ Google Search


Allowability of CostsPPP and other funding◦ Cannot charge costs that were included in PPP or other funding to

federal award programs (cannot “double dip”)

Ensure to maintain appropriate records and cost documentation


Steven A. Jarvis, CPA, MBA

Steven has 11 years of professional experience and has worked with Tribes across the country

Assurance Director, State, Local and Tribal GovernmentsCliftonLarsonAllen LLP (CLA)(509) [email protected]



Coronavirus Relief Funds (CRF)$150 billion for the Coronavirus Relief Fund◦ Administered by U.S. Department of Treasury◦ $8 billion reserved for tribes◦ Remaining went to states and territories


Interpreting the Guidance for CRFTitle VI – Coronavirus Relief Fund, CARES Act

The Coronavirus Aid, Relief, and Economic Security (CARES) Act was passed by Congress with overwhelming, bipartisan support and signed into law by President Trump on March 27th, 2020.

Title VI – Coronavirus Relief Funda. Appropriationb. Authority to make paymentsc. Payment amountsd. Use of fundse. Certificationf. Inspector General oversight, recoupmentg. Definitions

Guidance for State, Territorial, Local, and Tribal Governments

Document created by U.S. Treasury.

The purpose of this document is to provide guidance to recipients of the Coronavirus Relief Fund (the “Fund”)

Frequently Asked Questions (FAQ)

The answers to frequently asked questions supplement Treasury’s Coronavirus Relief Fund Guidance for State, Territorial, Local, and Tribal Governments.Amounts paid from the Fund are subject to the restrictionsoutlined in the Guidance and the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”).

Federal Register

As of 1/15/21, Guidance and FAQs published in the Federal Register at CRF-Guidance-Federal-Register_2021-00827.pdf (treasury.gov)


https://home.treasury.gov/system/files/136/CRF-Guidance-Federal-Register_2021-00827.pdf

Use of Funds Under Title VI, CRF – The CARES Act

Costs are necessary expenditures incurred due to the public health emergency with respect to the

Coronavirus Disease 2019 (COVID–19)

Cost were not accounted for in the budget most recently approved as of March 27, 2020 for the

State or government

Cost were incurred during the period that begins on March 1, 2020, and ends on December 31,

2020 2021

Governments shall use the funds to cover only those costs of the state, tribal government, or unit of local government that meeting all three

(3) requirements.


Compliance Visual

COVID-19

TimeframeBudget

• Every program, transaction, and “use idea” should be analyzed and documented for compliance with these requirements.

• Imprudent application of these concepts could result in a debt to the Federal government.


Necessary Expenditures Incurred Due to Public Health EmergencyDue to Public Health◦ For actions taken to respond to emergency◦ Direct, or◦ Second-order effects such as economic support for employment and business interruptions

Necessary◦ Reasonably necessary as determined by the reasonable judgement of

government official responsible for spending

Revenue replacement is not permissible.


Necessary COVID-19 Expenditures

The Guidance provides a listing of generalized eligible expenditures and ineligible expenditures.

This listing is suggestive of use of funds. This list does not consider the budget and timeframe of the expenditures.


Coronavirus Relief Funds (CRF) –Eligible Expenditures

Medical

Medical facilities

Testing

Telemedicine

Public Health

PPE

Safety measures

Technical assistance

Disinfection

Communication

Payroll

Public safety

Public health

Health care

Human service

Others similar substantially dedicated to COVID-19

emergency

Facilitate Compliance with Public Health

Measures

Food delivery

Distance learning

Telework capabilities

Sick pay and family pay

Prisons and jails

Homeless populations

Economic Support

Grants to small businesses

Payroll support

Unemployment insurances

Other

Other Reasonably necessary expenses related to COVID-19


Coronavirus Relief Funds (CRF) –Ineligible Expenditures

Expenses for the State share of Medicaid.

Replacement of lost revenues, including property tax relief.

Payroll or benefits expenses for employees whose work duties are

not substantially dedicated to mitigating or responding to the

COVID-19 public health emergency.

Expenses that have been or will be reimbursed under any federal

program, such as the reimbursement by the federal government pursuant to the CARES Act of contributions by States to State unemployment funds.

Reimbursement to donors for donated items or services.

Workforce bonuses other than hazard pay or overtime. Severance pay or legal settlements Damages covered by insurance.


Cost Not Accounted for in the BudgetCRF payments use only to cover cost not accounted for in the most recently approved budget as of March 27, 2020◦ i.e. cost you did not consider when preparing your budget◦ i.e. if were going to spend the dollars anyway, not those costs.

(referred to Supplement Not Supplant)


If the Costs are Budgeted and …The cost cannot lawfully be funded using a line item, allotment, or allocation within that budget OR

The cost is a substantially different use from any expected use of funds in such a line item, allotment, or allocation.

Note that a public function does not become a ‘‘substantially different use’’ merely because it is provided from a different location or through a different manner.


Corrine Wilson, CPA, PrincipalOver 30 years combined experience in Public Accounting and CFO for Tribes and their entities, former NAFOA Board member and NAFOA GASAC representative.

National Tribal Practice Leader REDW(602) [email protected]



COVID-19 Provider Relief Funds

Provider Relief Fund ($175B)Federal Agency: DHHSDistributions to For-profits, NFP’s, Governmental EntitiesSubject to Single AuditCFDA 93.498 – Provider Relief Funds◦2020 OMB Compliance Supplement Addendum


Presenter

Presentation Notes

The PRF are to be use for lost revenues due to COVID-19 for healthcare-related expenses. The COVID-19 testing for uninsured must meet the criteria for billing compliance and visits for patient with no third party payer.

Provider Relief FundGeneral Distributions

-Initial Medicare Distribution

-Additional Medicare Distribution

-Medicaid, Dental, & CHIP Distribution

Targeted Distributions

-High-Impact Area Distribution

-Rural Distribution

-Skilled Nursing Facilities Distribution

-Indian Health Services Distribution – May 29, 2020 Allocated $500M to 300 I/T/U facilities

-Safety Net Hospital Distribution


Presenter

Presentation Notes

We wanted to highlight that there are two aspects that fall under the PRF. There were three distributions of funding under the CARES Act, including a targeted distribution to Tribes and the Indian Health Service. In May, 2020.

Selected Items from I.H.S. Relief FundTerms and Conditions

Indian Health Service Distribution -https://www.hhs.gov/sites/default/files/terms-and-conditions-indian-health-service-relieffund.pdf

Recipient certifies that it provides or provided after 1/31/2020 diagnoses, testing, or care for possible or actual COVID-19 casesNot currently terminated from participation in Medicare or precluded from receiving payment from Medicare Advantage or Part DNot currently excluded from participation in Medicare, Medicaid, and other Federal HC programsBilling privileges in good standing


Presenter

Presentation Notes

These next few slides are key items from the I.H.S. Targeted distribution terms and conditions, available on the cited website. Firstly, the recipient must certify that his has been providing COVID related services to patients after January 31st. Additionally the recipient must not be terminated from participation in any of the national payor programs (Medicare, Medicaid etc. and billing privileges in good standing.

https://www.hhs.gov/sites/default/files/terms-and-conditions-indian-health-service-relieffund.pdf

Selected Items from I.H.S. Relief FundTerms and Conditions (continued)

Recipient certifies that the payment will only be used to prevent, prepare for, and respond to Coronavirus

Payment will reimburse recipient only for health care related expenses or lost revenue that are attributable to Coronavirus.◦ Recipient must certify that it will not use the payment to reimburse expenses or

losses that have been reimbursed from other sources or that other sources are obligated to reimburse.


Presenter

Presentation Notes

The money can be used for COVID related expenses or for lost revenue. The biggest highlight of this slide is that a certification that you cant double dip – meaning you cant use expenses that you used as a qualification of another source. This requires tribal healthcare entities to carefully consider and allocate expenses per the various CARES Act funding requirements that you received, and ensure you haven’t duplicated covering the same expenses with different funding streams..

Selected Items from I.H.S. Relief FundTerms and Conditions (continued)

Recipient consents to the HHS publicly disclosing the payment that recipient may receive from the PRF.◦ This disclosure may allow some third parties to estimate the gross receipts or sales, program

service revenue, or other equivalent information.

Recipient must maintain records and cost documentation as described in:◦ 45 CFR Section 75.302 – Financial management and ◦ 45 CFR Sections 75.361-75.365 – Record Retention and Access

Recipient must allow cooperation in all audits the Secretary, Inspector General, or Pandemic Response Accountability Committee conducts to ensure compliance with terms and conditions.


Presenter

Presentation Notes

Another big highlight is that this funding requires the provider to consent to HHS publicly disclosing the payment a provider receives from the Relief Fund and acknowledge that such disclosure may allow some third parties to estimate gross receipts or sales, program service revenue, or other equivalent information. 45 CFR Section 75.302 – Requires records are sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award.

PRF Allowable Expenses

According to the U.S. DHHS qualifying costs must be “health care related expenses attributable to coronavirus.” Examples include:

oSupplies & equipment used to provide healthcare services for COVID-19 patients (possible or actual)

oPersonnel or workforce training regarding COVID-19-related standards and practices

oExpenses for developing and staffing emergency operation and testing centers

oThe cost of reporting COVID-19 test results to federal, state or local governments

oConstructing temporary structures to expand capacity for COVID-19 patient care

oHousing or treating patients in separate areas from COVID-19 patients

oFacilities, practices, staffing and technology related to COVID-19


Presenter

Presentation Notes

This definition is left intentionally broad by HHS to include products, services or payments meant to prevent, prepare for and respond to COVID-19. Some of the examples include: supplies ( so PPE and other testing safety gear) equipment like tents or other purchases necessary to test and care for patients. Personnel working triage etc. Note the last sentence, no double-dipping. In considering allocating costs, use the most restrictive guidelines for costs first within the required timeframes.

PRF Allowable ExpensesThese funds may not be used to reimburse expenses or losses that have been reimbursed from other sources or that other sources are obligated to reimburse.

Funds to be expended no later than June 30, 2021.

DHHS to publish how to return any unused funds.

Funds used for expenditures, lost revenues, or combinations thereof.


Presenter

Presentation Notes

This definition is left intentionally broad by HHS to include products, services or payments meant to prevent, prepare for and respond to COVID-19. Some of the examples include: supplies ( so PPE and other testing safety gear) equipment like tents or other purchases necessary to test and care for patients. Personnel working triage etc. Note the last sentence, no double-dipping. In considering allocating costs, use the most restrictive guidelines for costs first within the required timeframes.

Accounting ConsiderationsGovernmental Entities - GASB

GASB 33, Non-exchange Transactions

Most likely include in non-operating revenue

https://www.gasb.org/jsp/GASB/Document_C/DocumentPage?cid=1176174735840&acceptedDisclaimer=true

Not-For-Profit Entities - FASB

ASC 958-605

If conditions are deemed present, release from liability as conditions are met

Consider treatment for net assets with donor restriction


Presenter

Presentation Notes

Governmental entities will use GASB 33 as their framework for recognition, as the PRF is not earned with services. Not-for-profit entities should apply ASC 958-605 to the government grants they receive including the COVID related awards. . Most COVID-related awards will be characterized as a nonexchange transaction (i.e. contributions received) because the purpose of the award is to provide relief to the recipients of the awards, and not for the direct benefit of the awarding agency. Classification of contributions received depends on whether the transactions are part of the entities ongoing major or central activities (classified as revenue) or peripheral or incidental activities (classified as other income). We expect that most NFPs will classify the COVID related funds as other operating revenue.

https://www.gasb.org/jsp/GASB/Document_C/DocumentPage?cid=1176174735840&acceptedDisclaimer=true

Lost Revenue Calculations - PRFCan be calculated using any reasonable method◦ Budget to actual – (2020 budget approved prior to 3/27/20)◦ Year to year or quarter to quarter change

Include revenues from all sources that can be attributed to COVID-19◦ Cancelled elective surgeries/procedures◦ Fewer outpatient visits

Awaiting HHS guidance on lost revenue calculations for 2021


PRF ReportingThe reporting system was available to recipients to register on January 15, 2021.DHHS will email/notify the due dates to report expenditures through the period ending December 31, 2020 after registration.DHHS will announce reporting date(s) for funds expended after December 31, 2020 through June 30, 2021.Detailed PRF reporting can be found at the below link and on the next slide. https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/reporting-auditing/index.html.Planned notice on OMB’s website for reporting for FYE’s > 12.31.20 in February, 2021, https://www.whitehouse.gov/omb/office-federal-financial-management/.


Presenter

Presentation Notes

On January 15, 2021, HHS issued a public notice about forthcoming reporting requirements for certain providers that accepted one or more payments exceeding $10,000 in the aggregate funding from the Provider Relief Fund program. The most recent reporting requirements are to be communicated to recipients after they register on the reporting website. In February, 2021, a notice is planned to be placed on OMB’s for audits of fiscal years ending after 12/31/2020. Auditors are to test the special reporting based on the reporting requirements to be announced.

https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/reporting-auditing/index.html

https://www.whitehouse.gov/omb/office-federal-financial-management/

DHHS Reporting RequirementsReporting Guidance on Use of Funds Recipients will report their use of PRF payments using their normal method of accounting (cash or accrual basis), by submitting the following information: ◦ 1. Healthcare related expenses attributable to coronavirus that another

source has not reimbursed and is not obligated to reimburse, which may include General and Administrative (G&A) or healthcare related operating expenses (further defined within the data elements section below).

◦ 2. PRF payment amounts not fully expended on healthcare related expenses attributable to coronavirus are then applied to patient care lost revenues. Recipients may apply PRF payments toward lost revenue, up to the amount of the difference between their 2019 and 2020 actual patient care revenue.


Reported in Audit & SEFAFiscal Year Ending SEFA Inclusion

CFDA No. 93.4908How SEFA Amounts are Calculated Other Information

< 12/30/20 Not included - 0 - Report 2020 expenditures & lost revenue in 2021 audit

12/31/20 2020 Expenditures & lost Revenues

Based on 12/31/20 amounts reported to HHS

SEFA reflects & discloses amounts per calendar year 12/31/20 PRF report

>12/31/20 to 6/29/21 2020 Expenditures & lost Revenues

Based on 12/31/20 amounts reported to HHS

SEFA reflects & disclosed amounts per 12/31/20 PRF report

6/30/21 & After ? ? 2021 OMB Supplement to provide guidance


Presenter

Presentation Notes

This program has very different, specific guidance per DHHS and the 2020 OMB Compliance Supplement. Essentially, you will account for what you reported to DHHS/PRF, for the total amount expended, and if any is leftover and not spent, as long as you meet the requirement based on what you reported to the PORF/DHHS, the balance could be recognized as lost revenues. Very critical to maintain the support for what you report for purposes of the Single Audit and SEFA that agrees to what you reported to DHHS for the PRF, and add disclosure to your SEFA footnotes. Keep in mind that the recognition on the SEFA may not agree to when items are recognized in the financial statements –reconciliation footnote of amounts on SEFA to FS.

New SEFA Disclosure - PPEThe SEFA will have to include a footnote with an amount of donated Personal Protective Equipment (PPE) from federal assistance◦ Can be marked unaudited◦ Information related to audit due dates and treatment of donated PPE

can be found in Part 8, Appendix 7 of Addendum to Compliance Supplement.

For <12/31/2020 FYE and FYE 1/1/2021 to 6/29/2021: Disclose that SEFA amounts are based upon the 12/31/20 PRF report.


Provider Relief Fund ResourcesFAQ’s -https://www.hhs.gov/sites/default/files/provider-relief-fund-general-distribution-faqs.pdfDHHS Provider Relief Fund Info -https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/index.html


https://www.hhs.gov/coronavirus/cares-act-provider-relief-fund/index.html

Tasha N. Repp, CPATasha has approximately 25 years of professional experience working with Tribes and is a citizen of the Samish Indian Nation

Partner and Tribal & Gaming National Practice LeaderMoss Adams LLPP. (360) 685.2246 E. [email protected]



2020 OMB Compliance Supplement Addendum ChangesIndian Community Development Block Grant (CFDA 14.862)◦ Added specific information for the imminent threat grants awarded under the CARES Act◦ Provides guidance on relevant regulations and PIH notices issued that provided waivers or

alternatives requirements to existing guidance◦ Provides resources to understand how the CDC’s eviction moratorium applies to HUD/ONAP

programs◦ Provides additional guidance on allowed activities related to preventing, preparing and

responding to COVID-19◦ Clarifies that costs could be incurred prior to the award if they meet the above allowable

activity criteria if they were incurred after January 21, 2020.


2020 OMB Compliance Supplement Addendum ChangesFederal Funding Accountability and Transparency Act reporting (FFATA)◦ For audits of September 30, 2020 financial statements, auditors are required to test FFATA

reporting for only the COVID programs listed in the addendum, excluding Treasury CRF program and where Reporting was considered subject to audit in the Part 2 Matrix.

◦ For audits of periods ending after September 30 (i.e. December 31, 2020 year ends) auditors should plan to test FFATA reporting for all applicable programs.

Tribes will need to closely review the terms and conditions of grant awards to determine whether any of their grants require reporting under FFATA


Presenter

Presentation Notes

Our audit firm believes that we would only be required to test this requirement if it is in the terms and conditions of the award document, as that would indicate to us that the requirement is direct and material to the award.

FFATA – What Reporting is Required?Prime or Direct Recipients of Federal Grant Awards are required to report subawards of $25,000 or more ◦ If you report pass-through awards to sub-recipients on your SEFA you’ll want to evaluate

whether this reporting requirement applies

Prime or Direct Recipients of Federal Contracts are required to report subcontracts of $25,000 or more◦ Currently reporting of subcontracts only applies to federal contracts (not federal grant

awards) but they are looking to expand this reporting requirement to all awards over time)

Reporting is required on a monthly basis through the FFATA Subaward Reporting System (FSRS) in the monthly following the award to a sub-recipient or sub-contractor


FFATA – What Reporting is Required?There may also be some required annual reporting on executive compensation, but it won’t apply to most Tribes as reporting this information is only required if, in the preceding year the entity:◦ 1) Received 80% or more of its annual gross revenues from Federal Awards

AND

◦ 2) Annual gross revenues from Federal Awards exceeded $25,000,000

Note: Auditors are not required to audit compliance with this requirement


Revisions to Uniform Guidance

The revisions were issued on August 13, 2020 and generally effective for awards issued after November 12, 2020, with a few exceptions

The revisions have been incorporated into guidance published at 2 CFR 200 ◦ You can always find the most updated version by looking at ecfr.gov


Revisions to Uniform Guidance – New Guidance

Never Contract With the Enemy (2 CFR 200.215) – Clarifies that 2 CFR Part 183 applies to federal awards over $50,000 where there is working being contracted or performed outside of the United States

Prohibition on Certain Telecommunications and Video Surveillance Services of Equipment (2 CFR 200.216 and 200.471) – Prohibits contracting for telecommunications equipment, services or systems produced by certain corporations and their affiliates (Huawei ban). This section is one of the sections effective as of August 13, 2020.


Revisions to Uniform Guidance – Revised or Amended Guidance

Performance Measurements (2 CFR 200.211(a)) – Continues to increase federal agency focus on developing performance measurements to drive program accomplishments and effectiveness. Where appropriate, you’ll see awards adopt more specific program goals, indicators, targets, baseline data, data collection, expected outcomes and timelines for accomplishments.

Budget Period (2 CFR 200.308 and 200.403(h)) – Adds language to define budget period in addition to the existing guidance around period of performance. Clarifies that for a cost to be allowable it must be incurred within both the correct budget period and overall period of performance and clarifies that written approval by the agency must be obtained to carryforward unobligated balances from one budget period to another.



Procurement – Several revisions here◦ Codifies the increase in the micro-purchase threshold to $10,000 and the simplified acquisition threshold to

$250,000◦ Micro-purchases (2 CFR 200.320) –

◦ Clarifies that the Tribe is responsible for determining and documenting a micro-purchase threshold based on internal controls, an evaluation of risk and its documented procurement procedures.

◦ Allows for an increase of the micro-purchase threshold for up to $50,000 if the entity meetings certain criteria that is evaluated annually or may be over $50,000 if approved by cognizant agency for indirect

◦ Domestic Preference (2 CFR 200.344) revises that you should, to the greatest extent practicable, provide a preference for the purchase, acquisition, or use of goods, products, or material produced in the United States and must include this requirement in all contracts and purchase orders



Closeout Procedures(2 CFR 200.344) – Extends the timeline to liquidate obligations to 120 days after the period of performance and extends dates for final financial and performance close out reports to 120 days.

Indirect Cost Rates (2 CFR 200.414) –◦ Increased flexibility for the use of the 10% de minimis rate, but notes Tribes are not eligible◦ Require most entities to make their indirect cost rate agreement publicly available, but exempts Tribes from this

requirement


GASB – Tribal Working Group Update

oWhat is the Working Group?

oUpdate on Activities

oNext Meeting Scheduled for June 29th


Samuel T. Owl Jr., CPA, CGMA

Sam over 18 years of professional experience and is a member of the Eastern Band of Cherokee Indians.

Principal, National Tribal Services LeaderCliftonLarsonAllen LLP (CLA)(571) 227- [email protected]



GASB Statement No. 95, Postponement of the Effective Dates of Certain Authoritative Guidance


Group 1: Postponed one year.• Many of these previously

implemented.

Group 2: Postponed 18 months.

GASB Statement No. 95: Postponed 1 year


Statement No. 83, Certain Asset Retirement Obligations

Statement No. 84, Fiduciary Activities

Statement No. 88, Certain Disclosures Related to Debt, including Direct Borrowings and Direct Placements

Statement No. 89, Accounting for Interest Cost Incurred before the End of a Construction Period

Statement No. 90, Majority Equity Interests

Statement No. 91, Conduit Debt Obligations

Statement No. 92, Omnibus 2020

Statement No. 93, Replacement of Interbank Offered Rates

Implementation Guide No. 2017-3, Accounting and Financial Reporting for Postemployment Benefits Other Than Pensions (and Certain Issues Related to OPEB Plan Reporting)

Implementation Guide No. 2018-1, Implementation Guidance Update—2018

Implementation Guide No. 2019-1, Implementation Guidance Update—2019

Implementation Guide No. 2019-2, Fiduciary Activities

GASB Statement No 95: Postponed 18 Months


GASB Statement No. 87, Leases

Implementation Guide No. 2019-03, Leases

Earlier application is encouraged and

permitted to extent specified in each pronouncement.

New Effective Dates


GASB 87, Leases, and Implementation Guide 2019-03

Periods beginning after June 15, 2021 (FYE June 30, 2022)

GASB 84, Fiduciary Activities, and Implementation Guide 2019-02

Periods beginning after December 31, 2019. (FYE June 30, 2021)

IMPORTANT NOTE: COMPONENT UNITS SHOULD UNDERSTAND HOW PRIMARY GOVERNMENT

INTENDS TO PROCEED.

Recently Issued GASB Statements


GASB Statement No. 94, Public-Private and Public-Public Partnerships and

Availability Payment Arrangements

GASB Statement No. 96, Subscription-Based

Information Technology Arrangements

GASB 97, Certain Component Unit Criteria, and Accounting and Financial Reporting for

Internal Revenue Code Section 457 Deferred Compensation Plans

Upcoming GASB Activity


Current Projects

Conceptual Framework –

Disclosure Framework

(Exposure Draft comment

period)

Conceptual Framework –Recognition

(Exposure Draft)

Financial Reporting Model (Exposure Draft)

Revenue and Expense

Recognition (Preliminary

Views)

Certain Component Unit

Criteria, and Accounting and

Financial Reporting For Section 457

Plans (Exposure Draft

Redeliberations)

Compensated Absences –

Reexamination of Statement 16

(Initial Deliberations)

Prior Period Adjustments, Accounting

Changes, and Error

Corrections –Reexamination

of Statement 62 (Initial

Deliberations)

Subscription-Based

Information Technology

Arrangements (Final

Pronouncement Expected any

day now!)

Upcoming GASB Activity


Pre-Agenda

Research

• Going Concern Disclosures

• Capital Assets• Investment fees• Interim Financial

Reporting

Questions?

Thank you all for attending today’s webinar!

To stay up to date with COVID-19 resources check NAFOA’s COVID-19 Resource Page regularly for updates:

https://nafoa.org/coronavirus

Panelist Contacts:

Kris Nixon: [email protected]

Steven Jarvis: [email protected]

Corrine Wilson: [email protected]

Tasha Repp: [email protected]

Sam Owl: [email protected]

There are 3 ways to ask:

-The chat box

-The question box

-The raise your hand function

*On a phone press *9 to raise your hand and *6 to unmute


https://nafoa.org/coronavirus






understanding omb compliance supplement addendum · 2021. 2. 3. · hhs – 93.914 – hiv...

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