The OMB has issued various documents that provide guidance to auditors and program managers. Below is a list of guidance issued thus far by OMB that should be of interest to auditors, starting with the latest documents:
- NEW OMB's memorandum M-10-14, Updated Guidance on the American Recovery and Reinvestment Act, issued on March 22, 2010, provides additional information to the federal agencies on their oversight roles and responsibilities as it relates to Recovery Act funds expended by grantees. For example, it provides guidance to the agencies on the following: 1) steps federal agencies must take to review the quality of the data being entered into www.FederalReporting.gov as part of the section 1512 recipient reporting requirements of the Recovery Act; 2) limitations on the program-specific recipient reporting guidance that federal agencies may issue; 3) information on tracking the number of awards issued and the total dollars associated with such awards; 4) a requirement to compile a quarterly comprehensive list of all awards subject to section 1512 reporting; and 5) guidance on the ability of state and local governments to recover administrative costs associated with the Recovery Act. The memorandum can be found at http://www.whitehouse.gov/omb/assets/memoranda_2010/m10-14.pdf.
- OMB's memorandum titled, Updated Guidance on the American Recovery and Reinvestment Act – Data Quality, Non-Reporting Recipients, and Reporting of Job Estimates, issued on December 18, 2009, replaces Section 5 “Reporting on Jobs Creation Estimates by Recipients” of the OMB June 2009 guidance document titled, OMB's memorandum titled, issued on December 18, 2009, replaces Section 5 “Reporting on Jobs Creation Estimates by Recipients” of the OMB June 2009 guidance document titled, Implementing Guidance for the Reports on Use of Funds Pursuant to the Recovery Act (see GAQC Alert #118) and reflects important simplifications to the manner in which job estimates are calculated and reported. Among the matters required to be reported by recipients under Section 1512 of the Recovery Act are estimates on the number of jobs created and retained. The new OMB guidance focuses on this particular aspect of the 1512 reporting and incorporates lessons learned from the reporting period that ended September 30, 2009 (the first reporting period under the Recovery Act). Click here to read the memorandum.
- OMB's Compliance Supplement Addendum #1 to the March 2009 Compliance Supplement is effective for audits of fiscal years beginning after June 30, 2008 (that is, for your June 30, 2009, single audits and year-ends thereafter), where your clients have expended Recovery Act funds. It should be used in conjunction with other Parts and Appendices of the Compliance Supplement in determining the appropriate audit procedures to support the auditor's opinion on compliance for each major program with expenditures of Recovery Act awards. The guidance in Part 5, Clusters of Programs, of the Addendum includes critical information on how Recovery Act programs are to be clustered which will have an effect on your major program determination process. You should also read GAQC Alert #118 for a summary of Recovery Act guidance included in Compliance Supplement Addendum #1.
- Implementing Guidance for the Reports on Use of Funds Pursuant to the Recovery Act (issued June 22, 2009): http://www.whitehouse.gov/omb/assets/memoranda_fy2009/m09-21.pdf
- The 2009 OMB Circular A-133 Compliance Supplement, issued on May 26, 2009, (and dated March 2009) with a new Appendix VII, which includes information and guidance for auditors on the Recovery Act and its implications on audits performed under Circular A-133. It is effective for audits of fiscal years beginning after June 30, 2008: http://www.whitehouse.gov/omb/circulars_a133_compliance_09toc/
- M-09-18, Payments to State Grantees for Administrative Costs of Recovery Act Activities (issued May 11, 2009)
- Follow-Up OMB Implementing Guidance at (issued April 3, 2009): http://www.whitehouse.gov/omb/assets/memoranda_fy2009/m09-15.pdf
- Initial Implementing Guidance at (issued February 18, 2009): http://www.whitehouse.gov/omb/assets/memoranda_fy2009/m09-10.pdf
- Frequently Asked Questions (FAQ) on OMB Recovery Act Guidance: http://www.whitehouse.gov/omb/recovery_faqs/