Part III: Compliance and Legislation | Fall 2024

by Nina Bahazhevska

Federal Audit Clearing House Update

The Federal Audit Clearinghouse (FAC) has introduced a new process to accommodate incomplete submissions under specific conditions. If your submission encounters issues such as an invalid Unique Entity Identifier (UEI), an unavailable certifying official, or a non-unique finding reference number, you may qualify for a submission exception. If your submission falls under one of these scenarios for exception, you will need to contact FAC Helpdesk for further guidance.

The Census data migration project has now been successfully completed. Users can explore a comprehensive array of historical records via the Search feature at fac.gov.

NYS Contracting Reform Legislation

The contracting reform legislation, S4877-A (Mayer) / A2740-B (Paulin), is now pending approval from Governor Kathy Hochul. This legislation targets significant challenges in New York State’s process of contracting with not-for-profit organizations. Key elements of the bill include:

  • Non-Compliant State Agency Category: This establishes a classification for agencies that fail to act promptly on contracts, requiring them to report detailed information about contract delays to the State Comptroller.
  • Progress Reports: Mandates that non-compliant agencies submit regular updates to the legislature and Governor, outlining steps taken to rectify contract deficiencies and suggesting policy modifications.
  • Transparency and Accountability: Enhances openness by mandating that the state’s payment schedule be included in all written directives and enforces the payment of interest on late payments to increase accountability.
  • Financial Stability for Nonprofits: Focuses on reducing financial strains on nonprofits caused by payment delays, which often compel these organizations to resort to high-interest lines of credit or personal loans.

As the latest development, over 200 nonprofit organizations have endorsed the legislation, collectively urging Governor Hochul to sign it into law to facilitate improved service delivery and financial stability among nonprofits.

Suffolk County Introductory Resolution 1687 (IR 1687)

Introductory Resolution 1687 (IR 1687) seeks to limit Suffolk County funding to nonprofit contract agencies that pay any employee a salary greater than $250,000, exceeding the New York State Governor’s salary. If passed, the legislation would effectively cap executive pay for nonprofit agencies that contract with the county. Due to pushback, parts of the bill are being amended. The next regular meeting of the Suffolk County Legislature to discuss this bill is scheduled for November 26, 2024.


More in This Series:

Part I: Accounting and Auditing Update | Fall 2024
Part II: Tax and IRS Update | Fall 2024
Part IV: Expert Insights | Fall 2024

Nina Bahazhevska

With over 20 years dedicated to serving a diverse array of non-profit organizations— from social services and cultural institutions to educational entities and religious organizations—Nina Bahazhevska has carved out a niche as a leading expert in audit quality and regulatory compliance.

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