Implementing the Super-Circular

Barbara Loescher & Trisha EdwardsFiscal Integrity & Audit Section

Topics for TodayOverview of FIASSupercircular

New administrative requirementsNew cost guidelinesNew audit requirements

What this means for counties Other hot topics

Fiscal Integrity & Audit SectionPurpose is to monitor compliance with rules,

regulations, licensing requirements and contracts to ensure that DCF funding is used appropriately

Created in 2012Consists of section chief and 5 auditorsBasic responsibilities

Desk reviewsOn-site fiscal reviewsInternal audits

Overview - Super-CircularCombines 8 CircularsPublished December 26,

2013Effective Dates

December 26, 2014Single Audits – December

31, 2015Link: See references pageAdditional guidance later

this year

Impact & ObjectivesReduce administrative

burdenReduce fraud, waste and

abuseImprove program integrityStrengthen accountabilityShift from legacy awards to

merit awardsMore oversight required for

pass-through agencies

Administrative Requirements ReformsPerformance goals &

reporting, cost effectiveness and collaboration

Technology changesComputers now

suppliesFlexibility in document

retentionStandardized

requirements and definitions

Administrative Requirements ReformsStronger oversight

Conflict of interest policies

Internal controlsHow audit results

are treatedSub-recipient

monitoring

Cost Principles ReformsAll entities – same guidance

Except for-profit agenciesIndirect/direct costs

Written cost allocation planNo universal rule except

consistencyTime and effort reporting

Emphasis on internal controls rather than PARs

Cost Principles ReformsChanges to specific items of

costAdvertising“Employee morale” costs

eliminatedEntertainmentConference spendingFines, penalties, damages and

other settlementsCollection of unallowable costsHome officesAnd others

A-133 Audit ReformsSingle audit threshold

increased$500,000 to $750,000

Type A programs increased$300,000 to $750,000

Risk criteria has changed

Questioned costs threshold increased$10,000 to $25,000

A-133 Audit ReformsRepeat findingsCompliance areas

Still not sureWill be published

4/15/2015Online publication of

reportsFederal Audit

Clearinghouse

How Does This Affect Counties?Changes to your contracts

with DCFDiscuss with Executive

committeeChanges to county

contracts with providersNew languageNew referencesNew allowable cost

requirementsNew audit requirements

for 2015 audits

More Ways It Affects CountiesMay be less auditing

for A-133 auditsTraining by DCF for

county financial managers through rest of 2014

New State Single Audit Guidelines for 2015 audits

DCF Oversight of Providers• FIAS Fiscal Reviews:

• Compliance with laws and licensing requirements

• Financial stability• Allowability of costs• Fiduciary responsibility• Contract compliance• Fraud and abuse• Overpayment recovery• Includes all agencies

receiving DCF funding

Fiscal Reviews ResultsInsight from the

trenchesLuxury vehiclesGhost vehicleLavish tripsFraudulent invoicesRelated party

transactionsPersonal items“Me first” mentalityHome office Holiday parties

Box Bucks ticketsGas allowancesATM withdrawalsUndocumented

itemsDonationsOverdraft chargesUnreasonableUnnecessary

County Fiscal ReviewsExpanding into

county fiscal reviewsScheduling first

wave in coming months

Review centered on:Cost allocationAllowable costsSub-recipient

monitoring

Allowable Cost Policy Manual UpdateMajor re-writeCurrently being

reviewed internallyTo be discussed with

Executive CommitteeCurrent (tentative)

ETA – before year end

In ClosingRead the Super-

CircularContinue spending

public funds prudently

Update your contracts

The ACPM is comingAnd we’ll see you

soon!

For Further InformationBarbara Loescher, CIAChief, Fiscal Integrity & Audit SectionDepartment of Children & Families(608)264-6992Barbara.Loescher@wisconsin.gov

Trisha Edwards, CPAAuditor – SeniorDepartment of Children & Families(608) 267-2981Trisha.Edwards@wisconsin.gov

Questions?