Audits, External Reporting & Disclosure

OMB circular A-133-Reporting

OMB Circular A-133-Reporting

Reporting requires the use of standard reporting forms authorized by the OMB or the awarding agency and establishes due dates for report submission.

Financial Reporting

Recipients should use the standard financial reporting forms or such other forms as may be authorized by the Office of Management and Budget (OMB). There is an OMB paperwork control number on the forms. The Financial Status Report is SF-269, OMB No. 0348-0039.

Other forms may include financial, performance, and special reporting. Each recipient must report program outlays and program income on a cash or accrual basis, as prescribed by the federal-awarding agency.

If the federal-awarding agency requires accrual information and the recipient’s accounting records are not normally maintained on the accrual basis, the recipient is not required to convert its accounting system to an accrual basis but may develop such accrual information through analysis.

The awarding agency may accept identical information from the recipient in machine-readable format, computer printouts, or electronic outputs in lieu of the prescribed formats. The reporting requirements for subrecipients are as specified by the pass-through entity. In many cases, these will be the same as or similar to the following requirements for recipients. The standard financial reporting forms are as follows:

  1. Financial Status Report (FSR) (SF-269 (OMB No. 0348-0039) or SF-269A (OMB No. 0348-0038)). Recipients use the FSR to report the status of funds for all non-construction projects and for construction projects when the FSR is required in lieu of the SF 271.
  2. Request for Advance or Reimbursement (SF-270 (OMB No. 0348-0004)). Recipients use the SF 270 to request Treasury advance payments and reimbursements under non-construction programs.
  3. Outlay Report and Request for Reimbursement for Construction Programs (SF-271 (OMB No. 0348-0002)). Recipients use the SF-271 to request funds for construction projects unless advances or the SF-270 is used.
  4. Federal Cash Transactions Report (SF-272 (OMB No. 0348-0003) or SF-272-A (OMB No. 0348-0003)). Recipients use the SF-272 when payment is by advances or reimbursements. The federal-awarding agency may waive the requirement for an SF-272 when electronic payment mechanisms provide adequate data.

Electronic versions of these standard forms are located on OMB’s Internet home page (http://www.whitehouse.gov/omb/grants/grants_forms.html).

 

Reporting Under the Payment Management System

Many recipients utilize the Payment Management System (PMS) operated by the Division of Payment Management (DPM) within the Department of Health and Human Services’ Program Support Center.

After a federal agency awards a grant, DPM is responsible for controlling payments to the recipient; receiving collections for unexpended funds, duplicate payments, and interest earned on federal funds; accounting for disbursement information provided by the recipient; and reporting data equivalent to the SF-272, Federal Cash Transactions Report, to the recipient and the federal agency.

Federal-awarding agencies enter authorization amounts in PMS to allow recipients to draw federal funds. There are three methods by which recipients can request funds: (1) the PMS 270 cash request, (2) SMARTLINK II, or (3) CASHLINE systems. SMARTLINK II enables recipients to request federal funds through computer link with DPM, while CASHLINE allows funds to be requested via a touch-tone telephone. Once a quarter, using the authorization amounts provided by the federal agency, payments requested by recipients, cash collection activity, and disbursement information provided by recipients, DPM generates PSC-272 reports.
The PSC 272 is a series of reports consisting of:

  1. PSC 272, Federal Cash Transactions Report, Status of Federal Cash (OMB No. 0937-0200). This report provides a total accountability of all federal cash received by the recipient. It is partially prepared by DPM based on data reported to DPM, and is completed and certified by the recipient.
  2. PSC 272-A, Federal Cash Transactions Report (OMB No. 0937-0200). This report is a continuation of the PMS-272 and is used by the recipient to report cash disbursements to DPM.
  3. PSC 272-B, Statement of Cash Accountability (OMB No. 0937-0200). This report is furnished for the recipient’s information and shows how the recipient’s cash accountability was derived by DPM.
  4. PSC 272-C, Error Correction Document (OMB No. 0937-0200). This report can be used by the recipient to report data reconciliation problems for awards on the PSC 272-A or the Advances to Payee portion of the PSC 272-B.
  5. PSC 272-E, Major Program Statement (OMB No. 0937-0200). This report is furnished to states, Indian tribes, and cross-serviced organizations for their information only. This report lists individual payments during the quarter among the various programs, and provides a cash accountability for all advances received through PMS by major program. All information provided is pre-printed by DPM.
  6. PSC 272-F, Authorizations for Future Periods (OMB No. 0937-0200). This report is provided for information only and requires no action by the recipient. It represents all awards posted in the PMS database that have effective dates in future reporting periods.
  7. PSC 272-G, Inactive Documents Report (OMB No. 0937-0200). This report lists all awards posted in the PMS database that have become inactive or fully disbursed during the current period or a previous period. In the event that disbursement adjustments are required, they should be reported via the PSC 272-A.

 

The reports are either mailed to the recipient or electronically downloaded by the recipient using DPM’s Electronic 272 System. Recipients should verify the reported amounts. If discrepancies are noted, the report is annotated (or the PSC 272-C is completed) and returned to DPM. The recipient uses the PSC 272-A to report the amount of disbursements made, then signs, dates, and returns the report to DPM. Recipients may report disbursements data electronically using the Electronic 272 process. PSC 272 reporting requirements do not apply to block grant programs; however, DPM does provide block grant recipients with a PSC 272-E, Major Program Statement, quarterly. This report is provided solely for information and no action is required by the recipient.

Performance Reporting

Recipients shall submit performance reports at least annually but not more frequently than quarterly. Performance reports generally contain, for each award, brief information of the following types:

  1. A comparison of actual accomplishments with the goals and objectives established for the period.
  2. Reasons why established goals were not met, if appropriate.
  3. Other pertinent information including, when appropriate, analysis and explanation of cost overruns or high unit costs.

 

Special Reporting

Non-federal entities may be required to submit other reporting which may be used by the federal agency for such purposes as allocating program funding. Compliance testing of performance and special reporting are only required for data that are quantifiable and meet the following criteria:

  1. Have a direct and material effect on the program.
  2. Are capable of evaluation against objective criteria stated in the laws, regulations, contract or grant agreements pertaining to the program.

 

Author: 
John Meriscko
Author's Organization: 
National Association of County and City Health Officials