OMB Releases 2017 Compliance Supplement

Last week, I was talking to Shane Jernigan (grants expert and blogger extraordinaire) about what he’d be working on before he leaves for vacation. And I correctly predicted that the 2017 OMB Audit Requirements, Appendix XI – Compliance Supplement (2017 Supplement) would come out late on Wednesday, and I’d have to write this post. The Federal Register gave me hope on Monday. But all 1,667 pages didn’t appear on the OMB website until Wednesday.

So, here go my highlights of what you need to know from this year’s edition. And luckily, we have Shane’s post from last year to follow.

First, like last year, there aren’t too many changes. In fact, the Federal Register Notice lists the changes so that you don’t have to hunt and peck. From there, I recommend going straight to Appendix V within the 2017 Supplement for more details.

• Part 1 – Background, Purpose, and Applicability was mostly administrative (like new weblinks). Pay attention to the should and musts in this part.
• Part 2 – Matrix of Compliance Requirements follows last year’s format. But has quite a few changes to be consistent with changes elsewhere in the document.
• Part 3 – Compliance Requirements still has two sections. Before the Uniform Guidance and after the Uniform Guidance. I know that December 2014 seems like an eternity ago; there are outstanding awards that will follow the “old way.” This section also reflects the recently updated FAQs and extension of the procurement requirements grace period.
• Part 4 – Agency Program Requirements and Part 5 – Clusters of Programs reflect numerous technical changes. Look for CFDA numbers and clusters that apply to you for details. If I were a grantee, I’d want to make sure I understood what the changes might mean in preparation for any audit.
• Appendix VII – Other Audit Advisories, II. Effect of Changes to Compliance Requirements and Other Clusters piqued my interest. There are instructions on how to treat a program that has been removed from the Part 2 Matrix. Auditors will know better how to translate this. But I am able to say that if there was a finding in the previous year, it needs to pull forward. Read this carefully and refer to 2 CFR 200.518. PS: Section III of this Appendix states that ARRA findings also must pull forward.The part on Addition of New Program to an Other Cluster makes me want to whiteboard. If the language always trips you up like me, scroll down to the examples. Perhaps close to a whiteboard. I know it’s confusing the way it’s written. But remember, the goal is not to audit every program, every year.

Before I end this – two more things. First, Read the FAQs. There are five updates to questions for Subpart F that correspond to the 2017 Supplement. Second, keep in mind that the 2017 Supplement isn’t just about the numbers. It’s about compliance with all of an award’s requirements.

Shane – wish you were here.

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The 2017 Supplement wasn’t the only big thing released in the past few weeks. We’ll catch you up on the Uniform Guidance Frequently Asked Questions and the DATA Act Pilot Program Report in our next edition of eCLIPS. Not a subscriber of eCLIPS? Sign up here.