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

[Leighdiddy]

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

Originally tickted here: #3872

Tasks

Tasks

Beta Give feedback

1. Implement a structure similar to this (below) for tracking the thresholds.
2. Add a new federal_awards validation that checks that the threshold is met (see below)
3. Update the form itself with text like the below (needs microcopy check from @James-Paul-Mason )
4. [FAC threshold] Follow up with an auditor about the notion of the threshold #4415
   +0
5. [FAC threshold] Update submission guide (copy and screenshots), FAQs, and possibly other static sites FAC-transition-site#165
   +0
   
6. Double check UG on dates

Microcopy

• $750,000 or more with a Fiscal Year starting before October 1, 2024
• $1,000,000 or more with a Fiscal Year starting on or after October 1, 2024

Regarding the validation...

We can begin with JP's code here:

#4128

Instead of grabbing the pre-computed total from the coversheet, let's add up all the values in the workbook in the amount_expended column. HOWEVER, apply an abs() to each value. We will, for now, count reimbursements as positive values, and therefore, if we get an audit like:

1. Expended: 500K
2. Reimbursed: 300K

we will count them as over the 750K threshold. (And, we could also check to see if they asserted they are above the threshold... e.g. "above_threshold" AND "abs_summation".)

This approach might change, based on feedback from auditor(s).

[rnovak338]

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]

Should we decide to enforce the DOLLAR_THRESHOLD (beyond the checkbox attestation in the pre-submission steps), some logic for cross validation exists here: #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 #3869 for concerns about reimbursements.

[danswick]

Possible duplicate of #3872

[James-Paul-Mason]

Microcopy listed here in the ticket looks GTG.