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.

You’ve heard our thoughts… We’d like to hear yours

The Schneider Downs Our Thoughts On blog exists to create a dialogue on issues that are important to organizations and individuals. While we enjoy sharing our ideas and insights, we’re especially interested in what you may have to say. If you have a question or a comment about this article – or any article from the Our Thoughts On blog – we hope you’ll share it with us. After all, a dialogue is an exchange of ideas, and we’d like to hear from you. Email us at

Material discussed is meant for informational purposes only, and it is not to be construed as investment, tax, or legal advice. Please note that individual situations can vary. Therefore, this information should be relied upon when coordinated with individual professional advice.

© 2020 Schneider Downs. All rights-reserved. All content on this site is property of Schneider Downs unless otherwise noted and should not be used without written permission.

our thoughts on

The Impact of COVID-19 on Community Colleges
Don’t Forget About Your HEERF Reporting Requirements
The FFIEC’s Take on Addressing Pandemic Planning within Business Continuity Processes
Cybersecurity Tips from Home Video Series
Paycheck Protection Program – Interim Final Rule: Additional Revisions to Loan Forgiveness and Loan Review Procedures Interim Final Rules
Update: Could your PPP loan affect the sale of your business?

Register to receive our weekly newsletter with our most recent columns and insights.

Have a question? Ask us!

We’d love to hear from you. Drop us a note, and we’ll respond to you as quickly as possible.

Ask us

contact us

Map of Pittsburgh Office

One PPG Place, Suite 1700
Pittsburgh, PA 15222
p:412.261.3644     f:412.261.4876

Map of Columbus Office

65 East State Street, Suite 2000
Columbus, OH 43215
p:614.621.4060     f:614.621.4062

Map of Washington Office
Washington, D.C.

1660 International Drive, Suite 600
McLean, VA 22102