*As Sent to COGR Listserv 10/20:
COGR has sent the following letter to Gilbert Tran at OMB.
Some of your institutions have been challenged in recent single audits. Specifically, a new auditor position is that prior to billing a federal sponsor for reimbursement, the institution must have evidence that the institution’s payment to the vendor has been cleared by the institution’s bank. This is in conflict with existing policy per 2 CFR Part 200.305(b): … payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity.
Public Comments are due October 31, 2017. The COGR letter to OMB and Mr. Tran is attached. We encourage you to submit a letter if this issue is a concern at your institution. A letter in support of the COGR letter, with any examples specific to your institution, is appropriate.
DIRECTIONS FOR SUBMITTING LETTERS: As specified in an August 14th Federal Register Notice, comments should be submitted to Gilbert Tran at hai_m._tran@omb.eop.gov. Include “2 CFR Part 200.305, Subpart F-Audit Requirements, Appendix XI-Compliance Supplement-2017” in the subject line and the full body of your comments in the text of the email and as an attachment. Include your name, title, organization, postal address, telephone number, and email address in the text of the message. Comments may also be sent through regulations.gov.
This is an important issue to a number of institutions and comment letters from your institution, in addition to the COGR letter, will elevate the unease around this issue. Contact David Kennedy at dkennedy@cogr.edu if you have questions on how to best craft your concerns to OMB.
