Federal awards for local government were previously audited under the provisions of Circular Nos. A-87, A-102, and A-133.  The new guidance Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards published in Title 2 of the Code of Federal Regulations (2 CFR 200) supersedes requirements from these circulars by way of consolidation into a streamlined format to improve transparency.

The “uniform requirements” place heavy emphasis on written policies and procedures.  To meet the new federal requisites, it is necessary to revise the City’s existing administrative policy.

The focus and intent of these policies and procedures is to ensure that those within the organization who carry out the objectives of the award understand:

• the federal statutes, regulations, and terms and conditions of the award,
• how to evaluate and properly monitor compliance, and
• the steps to take if noncompliance is identified.

Section 4.9 Code of Conduct pertains to all elected officials, employees, and agents of the City and therefore requires Council approval.  The new policy must be approved prior to December 14, 2017 in order to avoid an audit finding.