OMB Releases 2015 Compliance Supplement, Despite Title Complexities

July 15, 2015 | By Jerry Ashworth | Post a Comment

OMB-SealAs the line from the Shakespeare novel Romeo and Juliet goes, “What’s in a name?” We’ve been asking ourselves that question as well when reviewing the 2015 Office of Management and Budget Compliance Supplement. Or is it still the 2015 OMB Circular A-133 Compliance Supplement?

As if it wasn’t complex enough by including audit requirements under both former Circular A-133 and Subpart F of the uniform grant guidance, even the title page shows some inconsistencies. OMB released the compliance supplement last week on its website, and the formal announcement about the supplement was in yesterday’s Federal Register. On the website link and in the Federal Register announcement, it is listed as the 2015 Circular A-133 Compliance Supplement. However, when you actually click through to the supplement itself, the title page calls it the 2 C.F.R. Part 200, Appendix XI Compliance Supplement.

To explain this new title, the nearly 1,600-page supplement — almost 100 pages longer than the 2014 version — is incorporated into OMB’s uniform grant guidance as Appendix XI, codified under the Code of Federal Regulations (C.F.R.) at 2 C.F.R. Part 200 Appendix XI.

The 2015 supplement is effective for audits of fiscal years beginning after June 30, 2014. If a nonfederal entity’s fiscal year begins July 1, 2014, and ends June 30, 2015, for example, the entity’s single audit will follow the uniform guidance; however, there are exceptions in this first transition year. The uniform guidance became effective Dec. 26, 2014, in the middle of the fiscal year. Audits of federal funds received from July 1, 2014, to Dec. 26, 2014, will follow Circular A-133, and audits of federal funds received from Dec. 26, 2014, to June 30, 2015, will follow the uniform guidance. Therefore, audits of federal funding within one fiscal year are split between two sets of guidance, and the 2015 Compliance Supplement addresses both.

Of special interest is that this year’s supplement contains two sections in Part 3. Because the supplement may cover audits of awards that must comply either with the former circulars or the uniform guidance, Part 3 of this year’s supplement contains Part 3.1, which applies to audits under Circular A-133 for funding received prior to Dec. 26, 2014, and Part 3.2, which applies to audits under Subpart F of the uniform guidance for funding received on or after Dec. 26. 2014. Auditors and auditees should be pay special attention to determine which applies.

There are other numerous changes in this year’s supplement. Two of the 14 existing compliance requirements have been removed from this year’s supplement, and there are other changes related to the completion of many American Recovery and Reinvestment Act programs. The internal controls section in Part 6 also has been dramatically changed from previous years.

Auditors, and auditees as well, should be fully aware of the new changes in this year’s supplement and take appropriate steps. The changes, even the name, can be confusing, even for those that have been involved with grants and audits for many years. It may be lengthy and the name may vary, but we suggest you take the time to read it as it applies to your program or programs. Thompson’s Single Audit Information Service will have full coverage of the compliance supplement.

Let us know what your reaction is to the changes in the compliance supplement? We’d like to hear from you.


Post a Comment

Your email is never shared. Required fields are marked *