Revise fac.gov minimum expenditure reporting threshold from $750k to $1mil

Leighdiddy commented 3 weeks ago

The Federal Audit Clearinghouse (FAC) requires organizations that spend $1,000,000 or more in federal funds during a fiscal year to submit a Single Audit report. This is due to the Office of Management and Budget's (OMB) 2024 Uniform Guidance revisions, which increase the federal single audit threshold from $750,000 to $1,000,000. The new threshold applies to audits with periods beginning on or after October 1, 2024.

Currently our site and databases are set up to accept SARs for expenditures over $750k in a fiscal year/reporting period. We must determine what changes need to be made to implement the new $1mil reporting threshold. Because the new threshold applies to spending beginning after October 1st, 2024 we can anticipate about one year before they start to be submitted.

DOD:

The FAC will continue accepting SARs for reporting periods dated before 10/01/2024 at the $750k threshold

The FAC will disallow SARs for under $1mil for reporting periods after 10/01/2024

Tasks

- [ ] Review current database and site structure to propose solution

rnovak338 commented 3 weeks ago

From the backend perspective, I have an idea for easier maintenance on tweaking this threshold moving forward.

Currently, we are hard coding the $750,000 minimum in many different places. I propose that we programmatically populate this across the frontend, and have it pull from a JSON array we can tweak from the backend.

This is an example of how we could start managing the dates from /config/settings.py.

DOLLAR_THRESHOLDS = [
    {
        "start": None,
        "end": datetime.date(2014, 12, 25),
        "minimum": 500000,
    },
    {
        "start": datetime.date(2014, 12, 26),
        "end": datetime.date(2024, 9, 30),
        "minimum": 750000,
    },
    {
        "start": datetime.date(2024, 10, 1),
        "end": None,
        "minimum": 1000000,
    },
]

In the meantime, I have a branch that handles this logic should the team decide to build upon this approach. The changes in this branch take the hardcoded values and dates for the single audit threshold and will populate it based on the current date.

jperson1 commented 3 weeks ago

Should we decide to enforce the DOLLAR_THRESHOLD (beyond the checkbox attestation in the pre-submission steps), some logic for cross validation exists here: https://github.com/GSA-TTS/FAC/pull/4128. I was certain I had logic to include it in the intake steps for the Federal Awards workbook instead, but now I can't find it. Either way, the same checks apply.

See also https://github.com/GSA-TTS/FAC/issues/3869 for concerns about reimbursements.

GSA-TTS / FAC

Revise fac.gov minimum expenditure reporting threshold from $750k to $1mil #4198

Tasks