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Posted by on Jul 8, 2015

OMB Releases the 2015 Compliance Supplement

OMB Releases the 2015 Compliance Supplement

Blog Image_Office of Mgmt and Budget_160x160 (2)The Office of Management and Budget (OMB) released the long-awaited 2015 Compliance Supplement this week. The Compliance Supplement is annual guidance designed to assist auditors conducting single audits and to determine recipient compliance with applicable Federal laws and requirements.

It has always been an important resource for the grants community, however, the 2015 Compliance Supplement has additional significance as it provides guidance on implementing 2 CFR 200.

Appendix V of the Compliance Supplement identifies the list of changes from the previous year. Important changes to the 2015 Compliance Supplement include

  • The name of the guidance has been changed from the A-133 Compliance Supplement to the Compliance Supplement
  • The compliance requirements for the Davis-Bacon Act and Real Property Acquisition and Relocation Assistance have been removed
  • Additional audit advisories, including updated coverage of low-risk auditee criteria
  • Updated references to 2 CFR 200

The grants community should pay particular attention to the two sections in Part 3. Section 3.1 identifies compliance requirements for awards issued before December 26, 2014. Section 3.2 identifies compliance requirements for awards that adhere to 2 CFR 200.

It is important to note that the audit requirements under 2 CFR 200 – Subpart F do not apply until a non-Federal entity’s first full fiscal year after December 26, 2014. The following table identifies the applicable audit requirements.

 

Fiscal Year Dates Guidance for Audit Requirements
7/1/2014 – 6/30/2015 OMB Circular A-133
10/1/2014 – 9/30/2015
1/1/2015 – 12/31/2015 2 CFR 200
7/1/2015 – 6/30/2016
10/1/2016 – 9/30/2016

 

The grants community will find Part 6 of the Compliance Supplement disappointing. In the past, OMB has identified internal control requirements in Part 6. This year, however, Part 6 reads:

In 2013, the Committee of Sponsoring Organizations of the Treadway Commission (COSO) updated the “Internal Control – Integrated Framework,” and, in September 2014, the Government Accountability Office (GAO) issued an updated “Standards for Internal Control in the Federal Government,” commonly referred to as “The Green Book.” Due to the need to update other parts of this supplement for the Uniform Guidance in 2 CFR Part 200, OMB was unable to also update Part 6 for the revisions to COSO and The Green Book without delaying the issuance of this supplement. Since the 2014 version of Part 6 is out of date, it was not carried forward to this supplement. Non-federal entities and their auditors should look to the COSO and Green Book for guidance on internal controls until Part 6 is updated. OMB plans to update Part 6 for the 2016 Compliance Supplement.

Until OMB updates Part 6, it will be critical for the grants community to review both the Green Book and the COSO Integrated Framework. 2 CFR 200 does not require non-Federal entities to adopt either guidance, however, each contains best practices that would be beneficial to protect Federal funds from waste, fraud, and abuse.

The Compliance Supplement also noted that Federal agencies are expected to publish their final implementing rules for 2 CFR 200 in 2015. OMB notes that agencies “may include changes to their interim final regulations.”

What are your thoughts on the 2015 Compliance Supplement? Are you disappointed that OMB did not include information about internal controls? Leave your thoughts in the comment section below.

3 Comments

  1. So folks will have auditors having to use both the old A-133 and the new 2 CFR 200 since under 2 CFR 200 – Subpart F does not apply until the first full fiscal year after December 26, 2014, which would be Fiscal Year 2016 for most entities. Therefore, the single audit threshold for Fiscal Year 2015 audits remains $500,000. However, the administrative requirements and cost principles under 2 CFR 200 become applicable based on the date of the award or funding increment. As a result, auditors may have to test the recipient compliance under different set of requirements while still conducting the audit under A-133 requirements.

    • Dose Davis Bacon requirements in place conducting the single audit under A-133 requirements?

      • Elli –

        Thanks for your message. Davis-Bacon was removed from the requirements in 2015. But if you have concerns about David-Bacon compliance, I recommend talking to your auditor. You should also review your grant agreements to see how and where Davis-Bacon applies. Remember, a good auditor will not only follow the Compliance Supplement, but also adhere to award terms and conditions.

        Cheers,

        Erica Preston on behalf of Shane Jernigan

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