The Waiting Begins for the 2017 Compliance Supplement

May 31, 2017 | By Jerry Ashworth | Post a Comment

ketchup-1516795A close inspection of the calendar shows us that tomorrow is the first day of June. And with June’s arrival, we begin asking the annual question, “When will the Office of Management and Budget (OMB) release this year’s version of the Compliance Supplement?” Auditors for years have urged OMB to release the supplement earlier in the spring to allow them more time to use it in preparing for their audits, and yet, OMB historically has not released it until deep into the summer. Because of these delays, we have featured a series of snail pictures to highlight this deliberateness in the delivery of the annual document.

So now that June is almost upon us, the wait for the 2017 supplement begins in earnest. However, I don’t think our traditional snail picture is appropriate this year, as there are other factors in play that could delay its arrival.

First, we now have a new presidential administration that has its own political priorities. The Trump administration is calling for numerous budget cuts and governmental restructuring, diverting attention away from other typical duties of White House staffers. That aspect alone made it obvious that this year’s supplement would be released later rather than earlier.

Second, OMB in recent days issued a Federal Register announcement making a correctional amendment to the uniform guidance to extend the procurement grace period in §200.110 by one more fiscal year. Therefore, if an nonfederal entity has a fiscal year ending June 30, the grace period would allow it to use provisions in the prior OMB circulars until June 30, 2018, and then afterward, it would be required to follow the provisions in the uniform guidance. Because this amendment was just released recently, OMB now must adjust the Compliance Supplement accordingly to enable auditors to follow the most up-to-date OMB guidance.

Third, there were serious objections to provisions in a draft version of the 2017 Compliance Supplement released to stakeholder groups earlier this year. For example, the Department of Education (ED) in the draft had proposed a new section on securing student information under the Student Financial Aid cluster. Organizations representing institutions of higher education, state auditors and certified public accountants voiced numerous concerns about this new section. Based on these concerns, ED reportedly has agreed to delay this section in the SFA cluster until the 2018 Compliance Supplement.

Therefore, we don’t really think it would be fair to feature our usual snail photo this year. Instead, I’m reminded of the old ketchup commercial featuring the song “Anticipation” as the ketchup slowly seeped from the bottle. This seems more fitting as we continue the watch for its release, so for now, we’ll use a ketchup photo.  “Anticipation, it’s making me wait…”

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