I’m Jennifer Louis, CPA. In this article, I’ll explain the components of the new 2021 version of the Compliance Supplement that was recently released by the OMB. Let’s get started!
What is the Compliance Supplement?
The Office of Management and Budget (OMB) has released the 2021 version of the Compliance Supplement (the Supplement.) This annual document identifies important compliance requirements and provides clarifying guidance for auditors satisfying Single Audit objectives. The 2021 Compliance Supplement takes effect for fiscal years beginning after June 30, 2020, and supersedes all previous versions.
What are the different components of the Supplement?
Part 2 of the Supplement provides an annually updated matrix, organized by assistance listing number, that indicates which compliance requirements each responsible federal agency considers to be relevant for compliance audit testing. The compliance auditor determines which of these designated compliance requirements are both direct and material to the specific award being tested, and then uses professional judgement to design sufficient and appropriate audit procedures while using guidance from other parts of the Supplement.
2021 Supplement highlights: A breakdown
The following are important highlights in the 2021 Supplement:
- There are new procurement and other Uniform Guidance rules effective for awards made after November 12, 2020. The auditor must be aware of applicable award terms, as the old and new requirements are not separately identified within the Supplement.
- Guidance related to the Coronavirus Relief Fund (CRF) reflects the extended date through which awards may be expended (now December 31, 2021). In addition, it clarifies that Federal Funding and Accountability and Transparency Act (FFATA) reporting requirements do not apply to this program.
- Several programs related to COVID-19 funding are flagged as “higher risk.” This designation is not meant to supersede the risk-based major program determination process contained in Uniform Guidance. While this may impact the auditor’s selection of major programs, it does not require these programs to be selected for compliance testing based on this designation alone.
- When testing performance and special reporting requirements, the auditor is not required to evaluate information that is not quantifiable or capable of evaluation against suitable, objective criteria.
One or more future 2021 addenda are expected to be released to address programs including the Capital Projects Fund, Homeowner Assistance Fund, and more.
This latest version of the Compliance Supplement will require auditors to take new considerations into account when performing certain types of audits. As such, it’s in every auditor’s best interest to review these new stipulations as soon as possible.
Keep reading the Becker blog for more important audit updates that all auditors, accountants and CPAs should be in-the-know of.
