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Focus on Not-For-Profits: OMB Issues New Data Collection Form and Online Instructions

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Every 3 years the Office of Management and Budget has the opportunity to revise the Data Collection Form (the Form or DCF) used for submitting to the Federal Clearing House A-133 report packages.
August 26, 2008

Every 3 years the Office of Management and Budget has the opportunity to revise the Data Collection Form (the Form or DCF) used for submitting to the Federal Clearing House A-133 report packages. After a significant due process period, the Federal Audit Clearinghouse (FAC) on Friday August 22, 2008 posted the Internet Data Entry System (IDES) instructions for the 2008 – 2010 Data Collection Form and began accepting submissions of the Form and related single audit reporting packages for fiscal periods ending on or after January 1, 2008. What makes these changes so noteworthy is that the U.S. Office of Management and Budget (OMB) proposed a fully electronic submission process for both the Form and related reporting package. The final instructions did not change from the exposure draft and for 2008 fiscal year-end submissions and beyond, there will no longer be any paper copy submissions of the Form and reporting package to the FAC.

The 2008 – 2010 IDES instructions can be found on the FAC Web Site. The FAC has included access to a new 2008 question and answer page via the FAC home page to address questions that they anticipate may arise with the new Form and process.

For audit periods ending in 2004, 2005, 2006 and 2007 you should be using the previous version of the Form which you can access on the FAC Web site. Further, reporting packages for previous fiscal periods ending prior to 2008 must be mailed in hard copy.

Changes to the Form

There are not a large number of major changes to the 2008 – 2010 Form and related instructions. The two major changes identified in the IDES instructions are as follows:

Change in Terminology: The term “reportable condition” has been changed to “significant deficiency” in Part II Items 3 & 4 and Part III Items 4 & 5 to be consistent with changes made in 2007 to OMB Circular A-133, Audits of States, Local Governments, and Non-Profit Organizations.

Secondary Auditor Information May Be Entered: The primary auditor may choose to enter contact information for secondary audit organizations used in conducting the audit work. This information is considered optional.

The New Online Submission Process

Required Electronic Filing: The major area of change is the requirement that the submission of reporting packages, including the DCF, must be submitted entirely online—no more paper submissions. The new submission process requires the Form be submitted online using the IDES. Further, after the Form passes all edits, an electronic image file containing the reporting package must be attached. Before final submission of the Form and reporting package (that is, once both the auditee and auditor are ready to begin the certification process), the IDES will send an e-mail to the auditee and auditor certifying officials with a unique number that will be used to serve as a signature code.

Process for Submission: To use the system, auditees and auditors must have Internet access and valid e-mail accounts. They must also have the ability to upload a PDF file to the IDES. You must enable cookies in your Internet browser to allow proper data transfers between your computer and the IDES. Instructions on how to enable cookies are provided in the IDES instructions.

Because of the new electronic requirements all governments and not-for-profits should review the IDES instruction booklet and the 2008 question and answer document to ensure you fully understand the new online submission process well in advance of your reporting deadlines.


Under U.S. Treasury Department guidelines, we hereby inform you that any tax advice contained in this communication is not intended or written to be used, and cannot be used by you for the purpose of avoiding penalties that may be imposed on you by the Internal Revenue Service, or for the purpose of promoting, marketing or recommending to another party any transaction or matter addressed within this tax advice. Further, RubinBrown LLP imposes no limitation on any recipient of this tax advice on the disclosure of the tax treatment or tax strategies or tax structuring described herein.

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