Non-Governmental Entities Receiving Governmental Assistance
The Uniform Compliance Guidelines for Examination of Entities Receiving Financial Assistance From Governmental Sources(Guidelines) has been updated and reissue here in 2016. New information includes the electronic submission process through the Indiana Gateway for Governmental Units and the superseding of OMB Circular A-133 by Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards. As with all such revisions, we have attempted to provide up-to-date, relevant information to all interested parties in the most complete and concise manner possible. Please take the time to review the Guidelines and feel free to contact us if clarification of any item is needed.
Entities are defined as providers of goods, services, or other benefits maintained in whole or in part at public expense, or supported in whole or in part by appropriations, public funds or taxation. The definition does not include agencies of the state, Indiana local government, or quasi‑government agencies, but does include for‑profit and not‑for‑profit corporations, unincorporated associations, organizations, and individuals.
Entities are nongovernmental organizations, many of whom conduct their business as not‑for‑profit corporations. By contract or other form of agreement, entities provide a service or benefit to the public on behalf of government. Since 1986, more than 2300 entities in more than 30 distinct categories have been identified that are subject to the audit and reporting requirements of IC 5‑11‑1.
Our involvement in the entity audit process is triggered primarily by the filing of an Entity Annual Report (Form E-1).Based on the financial information reported, we advise the entity if an audit, in accordance with our guidelines is required, or if they qualify for a waiver of this requirement.
Indiana Code 5-11-1-27(e) provides that through the compliance guidelines authorized under IC 5-11-1-24 the state board of accounts shall define the acceptable minimum level of internal control standards for internal control systems of political subdivisions, including the following: (1) Control Environment. (2) Risk Assessment. (3) Control Activities. (4) Information and Communication. (5) Monitoring.
In response, the SBOA developed the Uniform Internal Control Standards for Indiana Political Subdivisions manual, which contains the acceptable minimum level of internal control standards.
Generally Accepted Government Auditing Standards (the "Yellow Book") prohibits the SBOA from prescribing the actual internal control procedures to be used by a political subdivision. However, the manual provides examples and case studies to demonstrate implementation strategies.
Internal Control Policy and Required Certifications
After June 30, 2016 IC 5-11-1-27(g) provides that the legislative body of each political subdivision must adopt the minimum internal control standards as defined by SBOA. Additionally, the legislative body must ensure that personnel receive training concerning the internal control standards and procedures adopted by the political subdivision.
At the time of submission of the Annual Financial Report (AFR) through Gateway, the fiscal officer must certify that the minimum internal control standards have been adopted and that personnel who are not otherwise on leave status have received training regarding these standards and procedures. Instructions for filing will be found as part of the AFR submission.
Apart from the required certification to be filed by the fiscal officer in Gateway during the submission of the 2016 AFR due March 1, 2017(or August 29, 2017 for Schools)], a certification for each elected official, appointee, and employee that meets the definition of personnel in IC 5-11-1-27(c), should be signed as evidence for their individual training. A certification form is provided below and can also be found under the Appendix found in the Uniform Internal Control Standards for Indiana Political Subdivisions manual. These certifications are to be maintained by the political subdivision on-site.
Indiana Code 5-11-1-27(f) provides that the SBOA develop or designate approved personnel training materials concerning internal controls.
The SBOA has developed and is providing the following training materials on internal controls:
- Uniform Internal Control Standards for Indiana Political Subdivisions manual by the SBOA
- Live presentations by the SBOA at the annual called meetings and conferences around the state.
- The following Webinar:
The webinar can also be downloaded to your local computer by clicking here.
The SBOA has designated the following training materials on internal controls:
- Internal Control - Integrated Framework (2013) by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
- Guidance papers, principals, or frameworks on Governance and Operational Performance, Internal Controls, Enterprise Risk Management, or Fraud Deterrence by COSO.
- Standards for Internal Control in the Federal Government (the "Green Book") set forth by the Comptroller General of the United States.
In addition, the SBOA recognizes that political subdivisions may find appropriate internal control training materials on their own initiative. So, the following training materials may be designated:
- Materials identified and submitted by political subdivisions, which are approved by the SBOA and/or posted on the SBOA's website. Please contact Debbie Gibson at (317) 232-2512 for further information.
This is a form that our agency may provide to you at the beginning of (or before) an engagement. This form allows us to gain a better understanding of your internal control structure and helps us in the planning of our engagement. There are section on this form that may not be applicable to your unit.
Internal Control Manual
Entity Annual Report (E-1) Filing
Pursuant to IC 5-11-1-4(a), the SBOA has implemented a new electronic submission process for the filing of Entity Annual Reports through the Indiana Gateway for Government Units (Gateway). With the completion of this new electronic submission process, not-for-profit and for-profit entities will join local units of governments in submitting their statutorily required annual reporting to the SBOA through the Gateway modernizing the way we collect entity financial information. Gateway was developed as a collaborative effort between many state agencies and the Indiana Business Research Center (IBRC) at the Kelley School of Business through the Information for Indiana (IFI) Initiative.
Gateway submission will be the only means of submitting your E-1 Entity Annual Report for 2015 reporting. An E-1 Entity Annual Report submitted by any other means or in any other format WILL NOT BE ACCEPTED. Reports for years ending December 31, 2014 and prior cannot be submitted through Gateway and should be filed using the traditional E-1 report. If you need a copy of that report, please contact us at email@example.com. The due date for submission is 60 days after your entity's annual year-end.
Gateway Entity Annual Financial Report User Accounts
Logon to Gateway using your User Name (your e-mail address) and password. Logon and password information was sent out to all units with the email address that we add on file for your entity. If you forget your password, click the Forgot Password link on the login screen. For additional login assistance please email IBRC at firstname.lastname@example.org. If you do not have a Gateway account and need one established or if you need to change who will be responsible for submitting for your entity, please send an email to us at email@example.com using your official email address and we will establish a Gateway account for you. In this request, include the entity's name, your name and job title, and your SBA File Number which can be located on any previous correspondence from our office.