OMB (Finally) Releases 2016 Compliance Supplement

August 9, 2016 | By Jerry Ashworth | Post a Comment

fireworks-collage-1-1460531Finally, fireworks! The 2016 Compliance Supplement is now available. Perhaps in the spirit of the Olympic Games currently underway in Brazil, the Office of Management and Budget (OMB) set a record of its own this year — marking the latest date in which the Compliance Supplement has ever been released. An announcement of its release was made in today’s Federal Register.

Perhaps one of the most telling changes can be seen right away. For years, it was known as the OMB Circular A-133 Compliance Supplement, even on OMB’s online version of the supplement last year. Now, as the current supplement is effective for audits of fiscal years beginning after June 30, 2015, this year’s version is known as the 2016 OMB 2 C.F.R. 200, Appendix XI Compliance Supplement. The supplement is Appendix XI of the uniform guidance, and the 2016 supplement supersedes the 2015 supplement. Therefore, throughout this year’s document, OMB removed references to Circular A-133 that in last year’s version were shown as dual references to Circular A-133 and Subpart F.

The 2016 Supplement adds two new programs, and deletes five programs that were completed under the American Recovery and Reinvestment Act. Like last year’s version of the supplement, two compliance requirements in Part 3 have been removed — Davis Bacon (formerly compliance requirement D) and Real Property Acquisition and Relocation Assistance (formerly compliance requirement K). Also like last year’s supplement, Part 3 is divided into two subparts — Subpart 3.1 for testing of awards issued prior to Dec. 26, 2014, and Subpart 3.2 for testing of awards issued on or after Dec. 26, 2014.

In the 2015 supplement, OMB removed previous language in Part 6, Internal Control, as it was outdated. This year’s version contains new language on internal control to be consistent with the guidance contained in the Government Accountability Office’s (GAO’s) “Standards for Internal Control in the Federal Government” (also known as the Green Book) and the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).

To help auditors better understand and use the various supplement parts together, OMB has included the applicable row from the matrix of compliance requirements in Part 2 to each program or cluster in the supplement in Parts 4 and 5. Other changes include a listing in Appendix II providing the dates of in which federal agencies’ issued their final rules or regulatory actions to implement the uniform guidance, and a list in Appendix III of the National Single Audit Coordinators and Single Audit Key Management Liaisons, along with their distinct roles for answering public inquiries regarding single audits.

There are other numerous changes to the 2016 supplement, which can be found at Appendix V. Although announced today, OMB has yet to post the supplement in its previous online format, which broke it down into chapters, making them available in either PDF or Word format. Currently, it is only available as the entire 1,600-plus-page supplement in PDF format.

Auditors and auditees should review all the changes in this year’s supplement as we continue to move away from the former Circular A-133 requirements to those under Subpart F of the uniform guidance. Auditors also should understand when it is appropriate to test under Part 3.1 and 3.2 under the supplement. This information is fully covered in Thompson’s Single Audit Information Service. Let the auditing games begin!

Let us know your reaction to the 2016 supplement. We’d like to hear from you.

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