Implementation

• Implementation Phases
• Subcommittee Structure
• Effective Dates

The GATA implementation structure involves GATA subcommittees which are made up of representatives of State agencies, grantees and subrecipients, and the Grant Accountability and Transparency Unit (GATU) at GOMB.

Each subcommittee and its workgroups has a GATU representative and co-chairs, one representing State agencies and one representing grantees.

The subcommittees will go through three phases of GATA implementation:

Phase 1 Rulemaking

• Review the Uniform Requirements; the rules can be more stringent, but not less stringent
• Determine if we need to add additional requirements for all awards
• Need to be flexible so that we can modify in the future, whenever necessary

Phase 2 Implementation

• Based on the rules, set forth uniform framework for Statewide policies and procedures
• Ensure that policies and procedures are flexible enough to add specific conditions for individual grant programs
• Ensure that the rules meet the objectives of GATA to lessen the administrative burden and remove duplication
• Ensure that the rules recognize the limitations of small providers and grant awards while helping to build capacity through training and technical assistance

Phase 3 Monitoring

There will be an ongoing process of review and continuous improvement after the initial implementation of GATA

The Illinois Single Audit Commission (ILSAC) is a bipartisan commission created by Public Act 98-047. The members include a representative from each of the four legislative caucuses, one representative from each of the thirteen largest grant-making agencies, and one representative of GOMB. ILSAC was originally charged with conducting research regarding the Federal government practices with respect to grants and whether Federal grant rules should be adopted for State grants. ILSAC’s final report summarized its recommendation that the State adopt uniform standards for the administration of grants in the State. This led to the adoption of the Grant Accountability and Transparency Act, 30 ILCS 708/1 et seq.

Currently, ILSAC serves in an advisory capacity for recommendations to the Joint Committee on Administrative Rules (JCAR) with respect to the rules necessary to implement GATA and provides advice and technical assistance to the ILSAC subcommittees and workgroups in their development of rules recommendations for submission to JCAR.

The GATA Steering Committee is made up of the GATU staff, and the co-chairs of the ILSAC subcommittees. The purpose of the GATA Steering Committee is to:

• Provide oversight and guidance to ILSAC and its subcommittees and workgroups
• Review and submit the ILSAC subcommittee recommendations to ILSAC
• Develop funding mechanisms for GATA implementation

ILSAC subcommittees and workgroups are critical to the success of GATA.

The subcommittees are responsible for making recommendations for rules in areas where the State and Federal regulations allow for flexibility. Each subcommittee is responsible for:

• Reviewing the State and Federal regulations that govern their topic in 2 CFR Part 200 and the Grant Accountability and Transparency Act in order to make informed recommendations to the GATA Steering Committee.
• Developing recommendations for performance metrics to measure the effectiveness of GATA.
• Developing recommendations for training programs to meet the needs of State agency and grantee staff.

New Federal Rules Effective Dates

• Federal agencies implemented December 26, 2014
• Subpart F Audit Requirements – fiscal years beginning after December 26, 2014
• Administrative requirements and cost principles will apply to new awards or funding increments, where the Federal award was made on or after December 26, 2014
• In cases where the Federal agency considers funding increments to be an opportunity to modify the terms and conditions of the Federal award, the new rules will apply
• The new Federal rules will not retroactively change the terms and conditions applicable to funds a non-Federal entity has already received
• Existing Federal awards that do not receive incremental funding with new terms and conditions will continue be governed by the original terms and conditions of the Federal award
• The effective date for subawards is the same as the effective date of the Federal award from which the subaward is made. The requirements for a subaward, no matter when made, flow from the requirements of the original Federal award
• Existing negotiated indirect cost rates will remain in place until they are due to be renegotiated
• A non-Federal entity may elect to keep current Federally-approved rate in place for an additional 4 years

Effective Dates and Grace Period for Procurement

• One-year grace period after the effective date of the Uniform Requirements
• For procurement policies and procedures, the non-Federal entity must, in the first full fiscal year that begins on or after December 26, 2014:
• Document whether it is in compliance with the old or new standard, and must meet the documented standard
• For example, a non-Federal entity with a June 30th year end would be the year ending June 30, 2016
• The Single Audit Compliance Supplement will instruct auditors to review procurement policies and procedures based on the documented standard
• For future years, all non-Federal entities will be required to comply fully with the Uniform Requirements
• For example, a non-Federal entity with a June 30th year end would be the year ending June 30, 2016
• The Single Audit Compliance Supplement will instruct auditors to review procurement policies and procedures based on the documented standard
• For future years, all non-Federal entities will be required to comply fully with the Uniform Requirements

GATA Effective Dates

The Grant Accountability and Transparency Unit (GATU) within GOMB will be responsible for the following:

• Providing advice and technical assistance, effective immediately
• Providing training to ILSAC subcommittee members regarding the administrative rules applicable to State-funded grants, effective immediately
• Maintaining the State Debarred and Suspended List
• Coordinating audit report reviews – FY 2017 audits, due in FY 2018
• Indirect cost rates will be negotiated during FY 2016 to be included in FY 2017 grant agreements
• Coordination of on-site reviews beginning in FY 2018
• Development and implementation of uniform grant agreements – FY 2016
• Catalog of State Financial Assistance – during FY 2016