"UGG"! Are you ready?

Greg Bollenbacher,
Fiscal Director

Uniform Grant Guidance (UGG) or “Super Circular” will become effective for non-federal agencies beginning December 26, 2014. Is your organization ready? Fifty five staff members at 21 of Ohio’s Community Action agencies are more prepared now than they were.

OACAA/OCATO (Ohio Community Action Training Organization) hosted two regional trainings on September 23^rd and 24^th in Jeffersonville and Huron. Mary Pockl and Michael Zeno of Zeno, Pockl, Lilly & Copeland (ZPLC) presented information regarding the upcoming changes included in the Super Circular.

Prior to this change there have been multiple different circulars providing guidance for administrative requirements, cost principles and audits depending on whether your organization was a nonprofit, local government or an institution of higher education. The UGG provides this guidance for all of these types of organizations in 2 CFR 200. There are six subparts and eleven appendices, so don’t worry, there is plenty of detail included.

Mary and Michael summarized new acronyms and definitions, some key terms, pre-award changes, post-award requirements, procurement standards, pass-through entity (PTE) and cost principle changes as well as adjustments to audit requirements. Some examples include:

• Acronyms and Definitions: PPI (Personally Identifiable Information) and PPII (Protected Personally Identifiable Information
• Key Terms: “Contractor” will be used to replace “Vendor” and the term “Non-Federal Entity” (that’s us!) has been added.
• Procurement Standards: Do you know what is required for micro-purchases (<$3,000)?
• Audit Requirements: Will you still qualify as a low-risk auditee?
• Cost Principles: Are advertising costs allowable? Do we still need activity reports?

Michael even offered to provide a copy of his searchable PDF file on the portion of the UGG that covers cost principles. This file was sent to all the agencies in the Fiscal Group, which is comprised of Fiscal Directors (CFOs) from most Community Action agencies in the state. If you didn’t receive your copy and would like to, please give our office a call. If you are not a member of the Fiscal Group, and would like to increase communication and share ideas with agencies in Ohio, contact me at greg@oacaa.org to join and take advantage of this membership benefit.

All in all, the trainings were very well received and OACAA/OCATO is planning to continue and increase the number of regional trainings provided across the state. To stay up-to-date on upcoming trainings, subscribe to our blog and visit our website www.oacaa.org.