OMB Issues Final 2020 Compliance Supplement

On August 18, the Office of Management and Budget released its final 2020 Compliance Supplement. The release comes five months after the OMB issued a number of memoranda in response to COVID-19- related concerns surrounding single audits, including filing dates and the allowability of costs not normally chargeable to awards.

Changes to the 2020 Supplement are more routine in nature when compared to last year’s overhaul of program requirements, which included the move to reduce testing compliance attributes for programs to no more than six. A comprehensive list of changes from the 2019 Supplement can be found in Appendix V.

High-level information has been added regarding CARES Act-established programs and their single audit impact, included within Appendix VII: Other Audit Advisories, which clarifies that new clusters of programs will not be added nor will any revisions be made to existing clusters listed in Part 5 of the Supplement. Recipients of federal awards have been instructed to separately identify COVID-19 expenditures on the Schedule of Expenditures of Federal Awards by CFDA number.

Further guidance surrounding requirements specific to federal programs under the CARES Act are not included in the final 2020 Compliance Supplement. The OMB will issue an addendum to the Supplement for some COVID-19 programs but has not communicated an anticipated release date. For single audit reports issued prior to release of the addendum, adherence to the additional requirements is not required. In these instances, COVID-19 programs identified as major programs will be required to follow the framework provided by Part 7.

Schneider Downs will continue to monitor the OMB’s progress towards the addendum release. You can access the full final supplement here.