The 2017 OMB Compliance Supplement

August 2017 | Posted in Audit
Audit

It’s that time of year that auditors who work on single audits look forward to every year – the release of the latest Office of Management Budget (OMB) Compliance Supplement! The new compliance supplement is now available and is effective for single audits with fiscal years beginning after June 30, 2016.

The link to the new compliance supplement can be found here:

https://www.whitehouse.gov/omb/circulars/a133_compliance_supplement_2017

You can refer to Appendix V to see a list of changes, but I’ve listed the highlights below:

  • Table of Contents:
    • Modified by changing the program titles in Part 4 so that they are consistent with the names in the Catalog of Federal Domestic Assistance (CFDA). If you have a grant under the Department of Agriculture, Department of Housing and Urban Development or Department of Health and Human Services, be sure to check out the new program names
    • Part 4, in the DOI, a cross-cutting cluster, 477 Cluster, that includes programs in the DOI, DOL and the Department of HHS.
    • Adds program CFDA 20.224 to the existing Highway Planning and Construction Cluster
    • Adds to Part 4 a new agency, Gulf Coast Ecosystem Restoration Council with two programs – CFDA 87.051 and CFDA 87.052
    • Adds to Part 4 a new cluster with CFDA 93.870 and 93.505
    • Deletes 3 programs from Part 4 – CFDA 11.558, 93.889 and 10.781
    • Modifies program names in the Student Financial Assistance Cluster to match their CFDA program names
  • Part 1 – Background, Purpose, and Applicability
    • No significant updates other than contact information, clarity and effective dates
  • Part 2 – Matrix of Compliance Requirements
    • Updated the matrix on several programs – be sure to review it carefully when testing!
  • Part 3 – Compliance Requirements
    • Updated the Procurement and Suspension and Debarment to reflect the extension of the grace period in 2 CFR part 200 from 2 years to 3 years
  • Part 4 – Agency Program Requirements
    • Several changes to multiple programs. Most changes direct users to new information, links, and applicability of requirements or clarifies requirements
    • The quickest way to see if there are changes to a program you’re testing – check Appendix V for your CFDA number, if it’s there – take a quick look at the changes related to your program before diving into the Compliance Supplement
  • Part 5 – Clusters of Programs
    • Student Financial Assistance Cluster – for the ED and HHS programs, updated cash management provisions, eligibility, matching, level of effort and earmarking, period of performance, program income, reporting and special tests and provisions.
    • R&D Cluster – updated the weblink to for the NIH’s historical summary of the salary cap
    • Other clusters – updated for the changes mentioned in the Table of Contents

The 2016 Compliance Supplement had some significant changes related to the Uniform Guidance. This year’s compliance supplement does some clean-up on programs, removes some outdated ARRA programs, and adds programs to existing clusters.

The key to making sure you pick-up on any changes significant to a program you may have or are testing, is to start with Appendix V – look for your specific program number in the Appendix, find out which section the changes are related to, and you can go straight to it.

Make sure to bookmark the new supplement – and happy auditing!

For more information, please contact a member of the Whitley Penn Public Sector Audit Team.

Laura Lynch

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