[nfbmi-talk] very interesting from rsa on fraud and false statements

[joe harcz Comcast]

ALERT: New Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards

Dear Grantee:

The Office of Management and Budget (OMB) issued the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards on
January 1, 2014.  The new regulations supersede and streamline requirements from OMB Circulars A-21, A-87, A-110, and A-122; Circulars A-89, A-102, and
A-133; and the guidance in Circular A-50 on Single Audit Act follow-up.  These regulations, codified at
2 CFR 200.415,
take effect on December 26, 2014.

2 CFR 200.415
requires that annual and final fiscal reports or vouchers requesting payment under the agreements must include a certification, signed by an official who
is authorized to legally bind the non-Federal entity, which reads as follows: “By signing this report, I certify to the best of my knowledge and belief
that the report is true, complete, and accurate, and the expenditures, disbursements and cash receipts are for the purposes and objectives set forth in
the terms and conditions of the Federal award. I am aware that any false, fictitious, or fraudulent information, or the omission of any material fact,
may subject me to criminal, civil or administrative penalties for fraud, false statements, false claims or otherwise. (U.S. Code Title 18, Section 1001
and Title 31, Sections 3729-3730 and 3801-3812).”  In order to comply with this regulation, RSA will be requiring grantees to certify the statement above
for all reports submitted on or after December 26, 2014.

To accomplish this, RSA will be adding a feature to the
RSA website
to enable grantees to electronically record that the Authorizing Official has signed a hard copy of the report, as well as the date it was signed and the
name of the person who verified this information.  The report screens on the
RSA website
will include the above required standard language from
2 CFR 200.415
and a checkbox for users to indicate the report has been signed.  The website will display the name of the official who is to sign the report.  By checking
the signed box, the individual submitting the report is attesting that a hard copy of the submitted form has been printed from the
RSA website,
has been signed by an official that is authorized to legally bind the grantee, and the signed form has been retained in the grantee’s official files.  Users
will also be asked to enter the date signed.  The date signed must fall within 5 (five) days of the date the electronic version is marked as complete.
 Any revisions to reports after submission must be signed and retained in the same manner.  Verification of the signed forms being maintained by the grantee
will be subject to periodic review by RSA.

If you have any questions regarding this information, please contact your
state liaison or your project officer.

Thank you for your attention to and anticipated compliance with this regulation.

Sincerely,

David

David Steele
Chief, Fiscal Unit
Rehabilitation Services Administration
550 12th St., SW, Room 5034
Washington, DC  20202-2800
Phone:  202.245.6520
Fax:  202.245.7591
David.Steele at ed.gov
Rehabilitation Services Administration |
Technical Assistance Unit |
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WIOA

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