Can the 2019 Compliance Supplement Really Come Out in January?

June 20, 2018 | By Jerry Ashworth | Post a Comment

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fast-cat-1309253Now that 2018 is almost half over, why not turn our attention to 2019? Perhaps one of the most eye-opening statements we heard at this week’s American Institute of Certified Public Accountants’ annual Not-for-Profit Conference at National Harbor, Md., occurred during the single audit update session yesterday. During this session, the presenters covered numerous audit-related topics, including the 2018 Compliance Supplement, the upcoming 2018 Yellow Book revision, laws affecting the uniform guidance and other audit issues. At one point, the discussion turned to the 2019 Compliance Supplement, and these words were uttered:

“OMB has stated that the target issuance date is January 2019.”

Did we hear this right? Yes, that’s what they said. January! Now for those not as familiar with the annual release of the Compliance Supplement, it traditional is issued in the summer, although auditors have for years clamored for the Office of Management and Budget (OMB) to release it earlier in the year to better prepare for their audits. Because of this, we in this blog have featured snails in past years when writing posts about the delays in releasing the supplement.

This year’s supplement was actually released in May, which was somewhat earlier than most years, but this year’s version was a “skinny” supplement (about 260 pages compared to the tradition 1,600-plus pages) as OMB only made necessary changes to the 2107 version. Auditors are required to use the 2017 and 2018 Compliance Supplement in tandem to perform single audits of federal fiscal years beginning after June 30, 2017.

So that’s why we were shocked when we heard that the target date for the 2019 supplement is January. Further, the presenters said that if this occurs, it is unknown what the effective date will be. So what is the reason for this hastened timeframe? Look to the President’s Management Agenda (PMA) released earlier this month for your answer. The PMA includes a cross-agency priority goal on grants that includes the identification of practices and data tools to enable agencies to incorporate performance into their grant award operations. To that end, OMB sought to spend little time on the 2018 Compliance Supplement, thereby making only the necessary changes, with the intent of spending more time and resources on streamlining the 2019 Compliance Supplement to provide an increased focus on compliance requirements that address performance.

Frankly, we’ll be shocked if OMB meets this target date, but will be the first to offer kudos if it does. Only time will tell. But after giving OMB so many snails over the years, we thought that this one time we’d feature an animal that’s a bit faster. Thus, we present our first cheetah! We’ll see if he sticks around.

Let us know if you think OMB will meet this target date, and what you’d like to see in the 2019 Compliance Supplement.

As a reminder, we have all of our Federal Funding Training Forums scheduled for 2018. Please let me know if you have questions or can make any of these. We hope to see you there!

  • Wednesday July 25 – Friday July 27 in MINNEAPOLIS

  • Wednesday October 17 – Friday October 19 in ATLANTA


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