The 2016 OMB Compliance Supplement (CS) is effective for single audits of fiscal years beginning after June 30, 2015, and supersedes the 2015 OMB CS.
The link where to find the CS has changed. If you have a bookmark in your browser, be sure to change it to this link.
Please click this link to access the 2016 OMB CS.
There are several changes to the 2016 CS, this is a brief summary of notable changes:
- The Uniform Guidance (2 CFR 200) is referenced throughout the compliance supplement.
- The usage of the terms “must” and “should” was reviewed and clarified.
- Requirements D and K are still shown as “reserved”.
- The “old” requirement D (Davis-Bacon Act) is now part of requirement N (Special Tests and Provisions) for certain federal grants.
- The “old” requirement K (Real Property Acquisition and Relocation Assistance) has been removed.
- The matrix of compliance requirements (Part 2) will clearly show “N” if the program normally does not have activity subject to that type of compliance requirement. This is a small change, in that the 2015 CS showed shaded cells when a requirement was not applicable.
- Keep in mind that although a compliance requirement is labeled as “N” in the matrix, understanding the program’s grant agreement or contract is key since it might require the auditor to test the compliance requirement if the requirement could have a direct and material effect on a major program.
- Part 3 – Compliance Requirements
- This part is still divided in two: Part 3.1 (requirements for Federal awards made prior to December 26, 2014) and Part 3.2 (requirements for Federal awards made on or after December 26, 2014).
- Discusses effect of Council on Financial Assistance Reform (COFAR) published Frequently Asked Questions (FAQs) updated September 2015, related to the Uniform Guidance and its application.
- Per the 2016 CS these FAQs should be considered when planning and performing single audits subject to the Uniform Guidance.
- The FAQs can be found here.
- Discusses the current micro-purchase, small purchase and simplified acquisition thresholds for procurements methods.
- Reflects the two full fiscal year grace period for the implementation of the procurement standards specified in the Uniform Guidance.
- Part 6 – Internal control is added back to the 2016 CS, it was removed from the 2015 CS.
- This section discusses: the objectives of internal control, the 5 components of internal control, and the 17 principles of internal control. It also provides overall assistance for the auditor to plan and perform the audit.
- Appendix VII Other Audit Advisories
- Discusses the effect that the Uniform Guidance has on the major program determination.
- Covers the effect that the non-availability of the Federal Audit Clearinghouse has, during part of 2015 for the submission of the data collection form, on the low-risk auditee status.
For a full list of the 2016 CS changes consult Appendix V “List of Changes for the 2016 Compliance Supplement”.
The AICPA GAQC has released Alert # 311 listing other key changes and important aspects of the 2016 CS.
For more information, please contact a member of the Whitley Penn Public Sector Audit Team.
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