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Financial aid cost transparency in higher education: Best practices

02.27.23

Read this if you are at a college or university.

Student loan forgiveness was one of the top headlines for 2022. Whether or not you agree with student loan forgiveness, one thing everyone can agree on is that higher education costs have skyrocketed throughout the country. 

In December of 2022, the United States Government Accountability Office (GAO) published its findings from a performance audit into the disclosures made by higher education institutions related to the cost of attendance. The audit, which ran from January 2021 through November 2022 and sampled from 204 public, nonprofit, and for-profit institutions, found that 91% of institutions were not accurately disclosing an accurate net price for attendance within their financial aid offerings. Further, 50% were understating certain expenses students incur through a school year, such as books and living expenses, or were factoring in loans to their net price calculation, even though those loan amounts would be repaid by the students, while 41% did not prepare an estimate of the net price of attendance whatsoever. 

The purpose of the GAO audit is to bring awareness to cost transparency so students can make an educated decision on the actual cost of attendance for each institution they are considering. Failing to disclose all key costs or including loans as an offset to the net price may lead to students having extended financial hardships during and after attendance. 

What are the best practices for cost transparency?

The US Department of Education has issued a list of 10 best practices for cost transparency with financial aid offerings. The best practices for financial aid offerings are as follows:

  1. Itemize key direct and indirect costs
    Itemize each direct (tuition, room, and board, etc.) and indirect (books, living expenses, etc.) cost within the calculation of net cost of attendance.
  2. Provide a total cost of attendance (COA) that includes key costs
    Ensure that a complete COA is included with the offerings, not excluding any indirect or direct costs.
  3. Estimate the net price
    Include the estimated net price of attendance using the COA less gift aid not to be repaid by the student. 
  4. Separate gift aid, loans, and work-study
    Break out gift aid, loans, and work-study separately. Students should easily understand what aid requires repayment (loans) or requires work performed by the student and is not guaranteed to them (work-study).
  5. Do not include a parent PLUS loan or separate and differentiate it from student loans
    There are several key differences between parent PLUS loans and student loans and therefore they should be separated from the student loans in the offering. 
  6. Label types of aid
    Disclosure of the type of aid should be clear and types of aid should be grouped together on the financial aid offering.
  7. Label source of aid
    Students should understand whether the aid is federal, state, or private and this should be disclosed on the financial aid offering.
  8. Include actionable next steps
    Ensure that students are aware of their right to accept, decline, or adjust their aid and the options that they have for all aid offered.
  9. Highlight key details and distinctions about loans, grants, and work-study
    Ensure that all information for the offered programs is included in the financial aid offering. This includes the minimum GPA to retain any forms of aid or specific requirements for all forms of aid.
  10. Do not refer to loans or work-study as “awards”
    Loans will need to be repaid by students and work-study will need to be earned by students. The term “awards” may lead students to believe that these are gifts to the student.

During the performance audit, the GAO identified no institutions performing all 10 best practices and that over half of the institutions were performing five or fewer of the best practices. The most common practices that were missing among the GAO’s audit were failing to label the source of aid, failing to include actionable next steps, failing to highlight key details of various aid, and labeling loans and work-study as “awards”. Each of these were missing in over half of the institutions financial aid offerings. 

Why does this matter and how does it impact compliance requirements?

In addition to the existing requirements outlined in the 2022-2023 Federal Student Aid handbook for cost of attendance and its impact on the awards available to students, as a result of this audit report the GAO is requesting Congress to consider legislation requiring institutions to provide all students offered federal aid clear and standard information that follow the best practices. Early adoption of the 10 best practice standards above would avoid potential future compliance issues based on congressional action and would provide prospective students the tools they need to make an informed decision.   

If you have more questions about cost transparency or your specific situation, please contact our higher education team. We’re here to help. 
 

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  • Emily Parker
    Principal
    Education, Healthcare, Not-for-profit
    T 207.991.5182

BerryDunn experts and consultants

Cloud services are becoming more and more omnipresent, and rapidly changing how companies and organizations conduct their day-to-day business.

Many higher education institutions currently utilize cloud services for learning management systems (LMS) and student email systems. Yet there are some common misunderstandings and assumptions about cloud services, especially among higher education administrative leaders who may lack IT knowledge. The following information will provide these leaders with a better understanding of cloud services and how to develop a cloud services strategy.

What are cloud services?

Cloud services are internet-based technology services provided and/or hosted by offsite vendors. Cloud services can include a variety of applications, resources, and services, and are designed to be easily scalable, cost effective, and fully managed by the cloud services vendor.

What are the different types?

Cloud services are generally categorized by what they provide. Today, there are four primary types of cloud services:

Cloud Service Types 

Cloud services can be further categorized by how they are provided:

  1. Private cloud services are dedicated to only one client. Security and control is the biggest value for using a private cloud service.
  2. Public cloud services are shared across multiple clients. Cost effectiveness is the best value of public cloud services because resources are shared among a large number of clients.
  3. Hybrid cloud services are combinations of on-premise software and cloud services. The value of hybrid cloud services is the ability to adopt new cloud services (private or public) slowly while maintaining on-premise services that continue to provide value.

How do cloud services benefit higher education institutions?

Higher education administrative leaders should understand that cloud services provide multiple benefits.
Some examples:

Cloud-Services-for-Higher-Education


What possible problems do cloud services present to higher education institutions?

At the dawn of the cloud era, many of the problems were technical or operational in nature. As cloud services have become more sophisticated, the problems have become more security and business related. Today, higher education institutions have to tackle challenges such as cybersecurity/disaster recovery, data ownership, data governance, data compliance, and integration complexities.

While these problems and questions may be daunting, they can be overcome with strong leadership and best-practice policies, processes, and controls.

How can higher education administrative leaders develop a cloud services strategy?

You should work closely with IT leadership to complete this five-step planning checklist to develop a cloud services strategy: 

1. 

Identify new services to be added or consolidated; build a business case and identify the return on investment (ROI) for moving to the cloud, in order to answer:

• 

What cloud services does your institution already have?

• 

What cloud services does your institution already have?

• 

What services should you consider replacing with cloud services, and why?

• 

How are data decisions being made?

2. 

Identify design, technical, network, and security requirements (e.g., private or public; are there cloud services already in place that can be expanded upon, such as a private cloud service), in order to answer:

• 

Is your IT staff ready to migrate, manage, and support cloud services?

• 

Do your business processes align with using cloud services?

• 

Do cloud service-provided policies align with your institution’s security policies?

• 

Do you have the in-house expertise to integrate cloud services with existing on-premise services?

3. 

Decide where data will be stored; data governance (e.g., on-premise, off-premise data center, cloud), in order to answer:

• 

Who owns the data in the institution’s cloud, and where?

• 

Who is accountable for data decisions?

4. 

Integrate with current infrastructure; ensure cloud strategy easily allows scalability for expansion and additional services, in order to answer:

• 

What integration points will you have between on-premise and cloud applications or services, and can the institution easily implement, manage, and support them?

5. 

Identify business requirements — budget, timing, practices, policies, and controls required for cloud services and compliance, in order to answer:

• 

Will your business model need to change in order to support a different cost model for cloud services (i.e., less capital for equipment purchases every three to five years versus a steady monthly/yearly operating cost model for cloud services)?

• 

Does your institution understand the current state and federal compliance and privacy regulations as they relate to data?

• 

Do you have a contingency plan if its primary cloud services provider goes out of business?

• 

Do your contracts align with institutional, state, and federal guidelines?

Need assistance?

BerryDunn’s higher education team focuses on advising colleges and universities in improving services, reducing costs, and adding value. Our team is well qualified to assist in understanding the cloud “skyscape.” If your institution seeks to maximize the value of cloud services or develop a cloud services strategy, please contact me.

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Cloud services 101: An almanac for higher education leaders

The late science fiction writer (and college professor) Isaac Asimov once said: “I do not fear computers. I fear the lack of them.” Had Asimov worked in higher ed IT management, he might have added: “but above all else, I fear the lack of computer staff.”

Indeed, it can be a challenge for higher education institutions to recruit and retain IT professionals. Private companies often pay more in a good economy, and in certain areas of the nation, open IT positions at colleges and universities outnumber available, qualified IT workers. According to one study from 2016, almost half of higher education IT workers are at risk of leaving the institutions they serve, largely for better opportunities and more supportive workplaces. Understandably, IT leadership fears an uncertain future of vacant roles—yet there are simple tactics that can help you improve the chances of filling open positions.

Emphasize the whole package

You need to leverage your institution’s strengths when recruiting IT talent. A focus on innovation, project leadership, and responsibility for supporting the mission of the institution are important attributes to promote when recruiting. Your institution should sell quality of life, which can be much more attractive than corporate culture. Many candidates are attracted to the energy and activity of college campuses, in addition to the numerous social and recreational outlets colleges provide.

Benefit packages are another strong asset for recruiting top talent. Schools need to ensure potential candidates know the amount of paid leave, retirement, and educational assistance for employees and employee family members. These added perks will pique the interest of many candidates who might otherwise have only looked at salary during the process.

Use the right job title

Some current school vacancies have very specific job titles, such as “Portal Administrator” or “Learning Multimedia Developer.” However, this specificity can limit visibility on popular job posting sites, reducing the number of qualified applicants. Job titles, such as “Web Developer” and “Java Developer,” can yield better search results. Furthermore, some current vacancies include a number or level after the job title (e.g., “System Administrator 2”), which also limits visibility on these sites. By removing these indicators, you can significantly increase the applicant pool.

Focus on service, not just technology

Each year, institutions deploy an increasing number of Software as a Service (SaaS) and hosted applications. As higher education institutions invest more in these applications, they need fewer personnel for day-to-day technology maintenance support. In turn, this allows IT organizations to focus limited resources on services that identify and analyze technology solutions, provide guidance to optimize technology investments, and manage vendor relationships. IT staff with soft skills will become even more valuable to your institution as they engage in more people- and process-centric efforts.

Fill in the future

It may seem like science fiction, but by revising your recruiting and retention tactics, your higher education institution can improve its chances of filling IT positions in a competitive job market. In a future blog, I’ll provide ideas for cultivating staff from your institution via student workers and upcoming graduates. If you’d like to discuss additional staffing tactics, send me an email.

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No science fiction: Tactics for recruiting and retaining higher education IT positions

As a leader in a higher education institution, you'll be familiar with this paradox: Every solution can lead to more problems, and every answer can lead to more questions. It’s like navigating an endless maze. When it comes to mobile apps, the same holds true. So, the question: Should your institution have a mobile app? The Answer? Absolutely.

Devices, not computers, are how millenials communicate, gather, inform, and engage. Millennials, on average, spend 90 hours per month on mobile apps, not including web searches and website visits.

Students are no exception. A 2016 Nielsen study showed that 98% of millennials aged 18 – 24, and 97% of millennials aged 25 – 34, owned a smartphone, while a 2017 comScore report stated that one out of five millennials no longer use desktop devices, including laptops. Mobile apps have quickly filled the desktop void, and as students grow more reliant on mobile technology, colleges and universities are in the mix, creating apps to bolster student engagement.

So should you create an app? Here are some questions you should answer before creating a mobile app. Welcome to the labyrinth! But don’t be frustrated—answer these questions to help you avoid dead ends and overspending.

1. Is a mobile app part of your IT Strategy? Including a mobile app in your IT strategy minimizes confusion at all levels about the objectives of mobile app implementation. It also helps dictate whether an institution needs multiple mobile apps for various functions, or a primary app that connects users with other functionality. If an institution has multiple campuses, should you align all campuses with a single app, or if will each campus develop their own?

2. What will the app do? Mobile apps can perform a multitude of functions, but for the initial implementation, select a few key functions in one main area, such as academics or student life. Institutions can then add functionality in the future as mobile adoption grows, and demand for more functions increases.

3. Who will use the app? Mobile apps certainly improve engagement throughout the student life cycle—from prospect to student to alumni—but they also present opportunities for increased faculty, staff, and community engagement. And while institutions should identify the immediate audience of the app, they should also identify future users, based upon functionality.

4. Who will manage the app? Institutions should determine who is going to manage the mobile app, and how. The discussion should focus on access, content, and functionality. Is the institution going to manage everything in house, from development to release to support, or will a mobile app vendor provide this support under contract? Depending on your institution, these discussions will vary.

5. What data will the app use? Like any new software system, an app is only as good as its supporting data. It’s important to assess the systems to integrate with the mobile app, and determine if the systems’ data is up-to-date and ready for integration. Consider the use of application program interfaces, or APIs. APIs allow apps and platforms to interact with one another. They can enable social media, news, weather, and entertainment apps to connect with your institution’s app, enhancing the user experience with more content for users.

6. How much data security does your app need? Depending on the functionality of the app you create, you will need varying degrees of security, including user authentication safeguards and other protections to keep information safe.

7. How much can you spend for the app? Your institution should decide how much you will spend on initial app development, with an eye toward including maintenance and development costs for future functionality. Complexity increases costs, so you will need to  budget accordingly. Include budget planning for updates and functionality improvements after launch.

You will also need to establish a timeline for the project and roll out. And note that apps deployed toward the end of the academic year experience less adoption than apps deployed at the beginning of the academic year.

Once your institution answers these questions, you will be off to a good start. And as I stated earlier, every answer to a question can lead to more questions. If your institution needs help navigating the mobile app labyrinth, please reach out to me

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The mobile app labyrinth: Seven questions higher education institutions should ask

Under the old lease reporting standards, there were many similarities between governmental and non-governmental standards, so when FASB changed its guidance on leases last year, many expected a carbon copy of that from GASB. GASB did not follow suit with GASB 87.

The major difference between GASB 87 and FASB ASU 2016-02, (February 2016), is the accounting treatment for operating leases. Unlike FASB, GASB treats all leases as financing—there is no distinction between operating and financing lease classifications and you will have to report operating leases on the statement of net position.

There are two primary reasons why GASB strayed from FASB and felt changes to the existing standards were necessary:

  1. Under the new statement, lessees and lessors have to report leases under a single model and GASB felt this change improves comparability of financial statements, and;
  2. GASB felt expanded disclosures which relate to the timing, significance and purpose of the leasing arrangements provide financial statement users with useful decision-making information.

GASB 87 was published on June 28, 2017 (effective for reporting periods beginning after December 15, 2019). Early adoption is permitted with these impending changes coming. Some terms you need to know about:

Lease term: the period during which a lessee has a noncancelable right to use an underlying asset. Clauses, events and options within the lease agreement will likely result in modifications to the original lease term.

Short-term lease: maximum possible lease term of 12 months or less. Recognize lease payments as outflows or inflows of resources by the lessee and lessor.

Here is a brief summary of general accounting treatment by the lessee and lessor under GASB 87.

What is recognized at the beginning of the lease term

Lessee Lessor
Lease liability and a lease asset
 
Lease receivable and a deferred inflow of resources

How do you measure the lease?  

Lessee    Lessor

Lease liability: present value of payments expected to be made during the lease term

Lease asset: value of the lease liability plus payments made to the lessor at or before the beginning of the lease term and certain direct costs

Lease receivable: present value of lease payments expected to be received during the lease term

Deferred inflows of resources: value of the lease receivable plus any payments received at or before the beginning of the lease term that relate to future periods

What is the lease accounting treatment? 

Lessee Lessor

Lease liability: reduce liability as payments are made and recognize an outflow of resources for interest expense

Lease asset: amortize lease asset over the shorter of the lease term or useful life of the underlying asset

Lease receivable: recognize interest revenue on the receivable

Deferred inflows of resources: recognize revenue from the deferred inflows of resources over the term of the lease

What do you have to disclose in the financial statements? 

Lessee Lessor
You must disclose:

Description of leasing arrangement

Amount of lease assets recognized

Schedule of future lease payments to be made
 
You must disclose:

Description of leasing arrangement

Recognize total amount of inflows of resources from leases

How do you account for a terminated lease?

Lessee Lessor

Reduce the carrying value of the lease liability and lease asset

Recognize any difference as a gain or loss
 

Reduce the carrying value of the lease receivable and deferred inflows of resources

Recognize any difference as a gain or loss

Other transactions to consider:

  • Sublease: if the original lessee becomes a lessor in a sublease, account for the original lease and the sublease as separate transactions.
  • Sale-leaseback transaction: account for the sale and lease transactions separately. Record the difference between the carrying value of asset sold and the net proceeds from the sale as a deferred inflow or a deferred outflow of resources — recognize over the term of the lease.
  • Lease-leaseback transaction: account for as a net transaction and disclose the gross amount of each portion of the transaction.

Please contact Danielle Baron if you have questions on how to implement GASB 87.

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GASB 87: Single lease classification: What's changing and what you need to do

NEW UPDATE October 2017:

The Federal Perkins Loan Program expiration date has passed without extension and now the countdown is on for the program wind-down. On October 6, the Department of Education issued a Dear Colleague Letter, GEN-17-10, which provides important wind-down information and indicates the Department will begin collecting the Federal share of institutions’ Perkins Loan Revolving Funds following the submission of the 2019-2020 FISAP (due October 1, 2018) using a similar process to the Excess Liquid Capital currently in place under HEA section 466(c). The Department of Education has promised more information on this process ahead of the October 2018 deadline.

Institutions should be reviewing their portfolios to determine if they will choose to assign their Perkins Loans to the Department or continue servicing their portfolio. Once the loans are assigned, institutions lose all rights to future loan collections, including their institutional share.

Loans that are not assigned to the department should continue to be serviced under Perkins Loan Program regulations until all loans are paid in full, fully retired or assigned to the Department. The process of requiring the distribution of assets from the Perkins Loan Revolving Fund will continue each year based on the annual submission of the FISAP, until all of the Perkins Loans held by the institution have been paid in full, fully retired or assigned to the Department of Education.

An administrative cost allowance cannot be charged against the Perkins Loan Revolving Fund after June 30, 2018.

For those considering liquidation and assignment, the Assignment and Liquidation Guide provides step-by-step instructions through the process, including the required a Perkins closeout audit. We are experienced with the Perkins closeout and stand ready to assist.
 

NEW UPDATE March 30, 2016: 

A new combined Federal Perkins Loan Assignment and Liquidation Guide has been posted. You can see the announcement and links to the updated guide here.

The Federal Perkins Loan Program has expired, effective October 1. While guidance has not yet been issued by the Department of Education in response to program’s expiration, there is a published process for institutions to follow to liquidate a Perkins Loan Revolving Fund.

We'll keep you informed as guidance is issued

BerryDunn’s Higher Education experts are monitoring the situation and assessing the implications for colleges and universities and their loan recipients with outstanding balances.

Need help or have additional questions?

Our experience with Perkins loan liquidation/closeout audits can be of great help to you as you navigate the complexities of closing your Perkins loans. Feel free to contact Renee Bishop, Emily Parker, Mark LaPrade or any of our Higher Education experts.

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New federal perkins loan update

While GASB has been talking about split-interest agreements for a long time (the proposal first released in June of 2015, with GASB Statement No. 81, Irrevocable Split-Interest Agreements released in March of 2016), time is quickly running out for a well-planned implementation. With the effective date looming on the horizon, (statement effective for periods beginning after December 15, 2016 unless early adopted), now is the time to start gathering needed information to record existing agreements under GASB 81.

We have learned from GASB’s not-for-profit FASB cousins that irrevocable agreements are rarely where they should be: in the hands of financial professionals. Compiling these agreements will require participation from many stakeholders. Your finance team will likely have to provide some education to avoid a great deal of confusion when asking the “do we have any irrevocable split-interest agreements?” question.

So, where do you start?

  1. Have you been tracking this information right along, nicely documented in a folder by your desk? Great! Do a quick check of others in your organization to be sure your file is complete and skip steps 2-5.
     
  2. Dig into your general ledger. Have you been receiving regular distributions from a trust? Some of these trust agreements pay out on a quarterly or annual basis and your accounting staff should be able to identify these payors. It may require a quick call to the administrator for the trust agreement to be sure the agreement qualifies under GASB 81.
     
  3. Look to your fundraising professionals. Development departments like to keep track of all types of donations. It helps to quantify their good fundraising work. Be clear about what you need from them. Remember, irrevocable split-interest agreements, often trusts or other legally enforceable agreements, are agreements wherein a donor irrevocably transfers resources to a third party to hold for the benefit of the government and at least one other beneficiary —the “split” in “split-interest agreement”!
     
  4. Keep talking to your fundraising professionals. Many of the split-interest agreements we find are very old, often created well before your current development software was put into place. Do you have old files that track this kind of information? It may require some digging in the paper files. Remember those?
     
  5. All hands on deck. While the finance and fundraising teams are scouring their records, look to others in the organization that might have record of these types of agreements. You know who holds the keys to historical knowledge at your organization, so be sure to include them in your search.

Once the finance department has collected all of the agreements, take one more look to be sure they meet the requirements of GASB 81.“Are they really irrevocable? Or do we just hope they are?” Then you can get down to the business of accounting for them. If you have questions about the accounting for these agreements, please contact me. I would love to chat. And that is irrevocable.

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GASB 81: Five quick steps to irrevocable split-interest agreement success

Recently the Governmental Accounting Standards Board (GASB) finished its Governmental Accounting Research System (GARS), a full codification of governmental accounting standards. The completion of the project allows preparers easy access to accounting guidance from GASB. The overall project, starting from the codification of older pre-1989 Financial Accounting Standards Board (FASB) pronouncements in 2010, was focused on pulling together all authoritative guidance, similar to what FASB had done in 2009.

Here’s what we found interesting.

Poking around the GARS (Basic View is free) I was struck by a paragraph surrounded by a thick-lined box that read “The provisions of this Codification need not be applied to immaterial items.” If you have ever read a GASB or FASB pronouncement, you have seen a similar box. But probably, like me, you didn’t fully consider its potential benefits. Understanding this, GASB published an article on its website aimed at (in my opinion) prompting financial statement preparers to consider reducing disclosure for the many clearly insignificant items often included within governmental financial statements.

After issuing more than 80 pronouncements since its inception in 1984, including 19 in the last five years, GASB accounting requirements continue to grow. Many expect the pace to continue, with issues like leases accounting, potential revision of the financial reporting model, and comprehensive review of revenue and expense recognition accounting currently in process. With these additional accounting standards come more disclosure requirements.

With many still reeling from implementation of the disclosure heavy pension guidance, GASB is already under pressure from stakeholders with respect to information overload. Users of financial statements can be easily overwhelmed by the amount of detailed disclosure, often finding it difficult to identify and focus on the most significant issues for the entity. Balancing the perceived need to meet disclosure requirements with the need to highlight significant information can be a difficult task for preparers. Often preparers lean towards providing too much information in an effort to “make sure everything is in there that should be”. So, what can you do to ease the pain?

While the concept of materiality is not addressed specifically in the GASB standards, by working with your auditors there are a number of ways to reduce the overall length and complexity of the statements. We recommend reviewing your financial statements periodically with your auditor, focusing on the following types of questions:

  • On the face of the financial statements, are we breaking out items that are clearly inconsequential in nature and the amount?
  • Are there opportunities to combine items where appropriate?
  • In the notes to the financial statements are we providing excessive details about insignificant items?
  • Do we have an excess amount of historical disclosure from years past?
  • In the management’s discussion & analysis, is the analysis completed to an appropriate level? Is there discussion on items that are insignificant?

The spirit behind the box is that GASB was specifically thinking about material amounts and disclosures. It was not their intention to clutter the financials with what their article referred to as “nickel and dime” items. With more disclosure requirements on the way, now might be the time to think INSIDE the box.  

For more guidance on this and other GASB information, please contact Rob Smalley.

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Extra information for GASB organizations: How to lessen information overload

As we begin the second year of Uniform Guidance, here’s what we’ve learned from year one, and some strategies you can use to approach various challenges, all told from a runner's point of view.

A Runner’s Perspective

As I began writing this article, the parallels between strategies that I use when competing in road races — and the strategies that we have used in navigating the Uniform Guidance — started to emerge. I’ve been running competitively for six years, and one of the biggest lessons I’ve learned is that implementing real-time adjustments to various challenges that pop up during a race makes all the difference between crossing — or falling short of — the finish line. This lesson also applies to implementing Uniform Guidance. On your mark, get set, go!

Challenge #1: Unclear Documentation

Federal awarding agencies have been unclear in the documentation within original awards, or funding increments, making it hard to know which standards to follow: the previous cost circulars, or the Uniform Guidance?

Racing Strategy: Navigate Decision Points

Take the time to ask for directions. In a long race, if you’re apprehensive about what’s ahead, stop and ask a volunteer at the water station, or anywhere else along the route.

If there is a question about the route you need to take in order to remain compliant with the Uniform Guidance, it’s your responsibility to reach out to the respective agency single audit coordinators or program officials. Unlike in a race, where you have to ask questions on the fly, it’s best to document your Uniform Guidance questions and answers via email, and make sure to retain your documentation.  Taking the time to make sure you’re headed in the right direction will save you energy, and lost time, in the long run.    

Challenge #2: Subrecipient Monitoring

The responsibilities of pass-through entities (PTEs) have significantly increased under the Uniform Guidance with respect to subaward requirements. Under OMB Circular A-133, the guidance was not very explicit on what monitoring procedures needed to be completed with regard to subrecipients. However, it was clear that monitoring to some extent was a requirement.

Racing Strategy: Keep a Healthy Pace

Take the role of “pacer” in your relationships with subrecipients. In a long-distance race, pacers ensure a fast time and avoid excessive tactical racing. By taking on this role, you can more efficiently fulfill your responsibilities under the Uniform Guidance.

Under the Uniform Guidance, a PTE must:

  • Perform risk assessments on its subrecipients to determine where to devote the most time with its monitoring procedures.
  • Provide ongoing monitoring, which includes site visits, provide technical assistance and training as necessary, and arrange for agreed-upon procedures to the extent needed.
  • Verify subrecipients have been audited under Subpart F of the Uniform Guidance, if they meet the threshold.
  • Report and follow up on any noncompliance at the subrecipient level.
  • The time you spend determining the energy you need to expend, and the support you need to lend to your subrecipients will help your team perform at a healthy pace, and reach the finish line together.

Challenge #3: Procurement Standards

The procurement standards within the Uniform Guidance are similar to those under OMB Circular A-102, which applied to state and local governments. They are likely to have a bigger impact on those entities that were subject to OMB Circular A-110, which applied to higher education institutions, hospitals, and other not-for-profit organizations.

Racing Strategy: Choose the Right Equipment

Do your research before procuring goods and services. In the past, serious runners had limited options when it came to buying new shoes and food to boost energy. With the rise of e-commerce, we can now purchase everything faster and cheaper online than we can at our local running store. But is this really an improvement?

Under A-110, we were guided to make prudent decisions, but the requirements were less stringent. Now, under Uniform Guidance, we must follow prescribed guidelines.

Summarized below are some of the differences between A-110 and the Uniform Guidance:

A-110 UNIFORM GUIDANCE
Competition
Procurement transaction shall be conducted in a manner to provide, to the maximum extent practical, open and free competition.
Competition
Procurement transaction must be conducted in a manner providing full and open competition consistent with the standards of this section.
 
Procurement
Organizations must establish written procurement procedures, which avoid purchasing unnecessary items, determine whether lease or purchase is most economical and practical, and in solicitation provide requirements for awards.
Procurement
Organizations must use one of the methods provided in this section:
  1. Procurement by Micro Purchase (<$3,000)
  2. Procurement by Small Purchase Procedures (<$150,000)
  3. Procurement by Sealed Bids
  4. Procurement by Competitive Proposal
  5. Procurement by Noncompetitive Proposal

While the process is more stringent under the Uniform Guidance, you still have the opportunity to choose the vendor or product best suited to the job. Just make sure you have the documentation to back up your decision.

A Final Thought
Obviously, this article is not an all-inclusive list of the changes reflected in the Uniform Guidance. Yet we hope that it does provide direction as you look for new grant awards and revisit internal policies and procedures.

And here’s one last tip: Do you know the most striking parallel that I see between running a race and implementing the Uniform Guidance? The value of knowing yourself.

It’s important to know what your challenges are, and to have the self-awareness to see when and where you will need help. And if you ever need someone to help you navigate, set the pace, or provide an objective perspective on purchasing equipment, let us know. We’re with you all the way to the finish line.

Grant Running.jpg

Article
A runner's guide to Uniform Guidance, year two