2016 Compliance Supplement Release is Days Away

June 28, 2016 | By Jerry Ashworth | Post a Comment

exclamation-point-icon-1444386We have some news on the Office of Management and Budget’s (OMB’s) 2016 Compliance Supplement.  It hasn’t been released yet, but it’s close. We’re not ready to post our traditional fireworks picture in honor of its release, but maybe we can put the snails to bed for another year; therefore, let’s go with an exclamation point.

We had hoped that OMB would release the 2016 Compliance Supplement prior to this week’s American Institute of Certified Public Accountants’ (AICPA) Not-for-Profit Conference at National Harbor, Md. Alas, it was not forthcoming. However, AICPA Director Mary Foelster told conference attendees that OMB had contacted her to say that it had finished the clearance process and the document was undergoing final edits. She anticipated its release to be no later than mid-July, if not sooner. For all those waiting expectantly for this year’s version, let’s hope she’s right.

Because some audit community members were shown a draft version of the document for comment earlier this year, Foelster noted that this year’s version, if similar to the draft, will revise all instances of “musts” and “shoulds” to make it consistent with the OMB uniform guidance, and will remove all references to Circular A-133 that were shown as dual references to Circular A-133 and the uniform guidance. The draft also will retain the two sections in Part 3 contained in the 2015 version; Part 3.1 for compliance testing of awards received under the former OMB circulars and Part 3.2 for testing of awards under the uniform guidance.

Also of interest in the draft, the language on internal controls in Part 6, which was taken out in the 2015 version to include a single paragraph related to the internal controls provision (§200.303) in the uniform guidance, will be reinserted in this year’s version to include more information about internal control principles under the COSO framework.

Many more details will be available when the actual document is released. Subscribers to Thompson’s grants publications will be kept up-to-date on these changes when it is unveiled, and our handbooks will be revised with the analysis you need to stay compliant with audit requirements, whether you are an auditor or auditee. Stay tuned to this blog; more on this will come soon. We hope!

Let us know your expectations about the 2016 Compliance Supplement. We’d love to hear from you.


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