2021 OMB Compliance Supplement Resource Center
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2021 OMB Compliance Supplement Resource Center

10 months ago · 1 min read

2021 OMB Compliance Supplement Resource Center

On August 12, 2021, the Office of Management and Budget (OMB) released the final 2021 OMB Compliance Supplement (the Supplement). See GAQC Alert #430 for more details. The Supplement was released on the OMB Web site in one large PDF file at: https://www.whitehouse.gov/omb/office-federal-financial-management/ .As a public service, the GAQC is making available the 2021 Supplement broken down by individual section below (see the left column). These individual sections were excerpted from the full PDF file posted on the OMB Web site.

Two follow-up Supplement Addenda have been issued and posted to the cfo.gov Web site at: https://www.cfo.gov/2021-addendum-1and2/. Addendum #1 was issued in December 2021 and Addendum #2 in January 2022. The Addenda include several additional programs created by the American Rescue Plan Act (ARP) and update several existing programs for the impact of ARP. The cfo.gov Web page states that the guidance issued is applicable only for audits with report dates subsequent to issuance of each Addendum. The GAQC has posted the contents of each Addendum in the relevant sections of the center column below. To learn more about the 2021 Supplement, we encourage you to listen to various archived no-CPE GAQC Web events covering the 2021 Supplement.

The GAQC has also provided important information about the original Supplement release and the Addenda in the “GAQC Observations” column.

First 2021 Supplement Release2021 Supplement AddendaGAQC Observations
Title Page
Table of Content
Part 1
Part 2
Part 3The approach to implementing the 2020 Uniform Guidance (UG) revisions is different as compared to prior UG implementation in the Supplement (i.e., there is no Part 3.1 and 3.2 mechanism used). Instead, the 2020 UG revisions are incorporated in Part 3 throughout. Part 3 reminds auditors to check the proper and applicable versions of the UG depending on the occurrence date of the transactions reviewed. Auditors will need to consider how to approach this nuance in their testing, particularly when testing awards subject to the previous version of the UG.
Part 4 Introduction
CORPORATION FOR NATIONAL AND COMMUNITY SERVICE
DEPARTMENT OF COMMERCE
DEPARTMENT OF DEFENSE
DEPARTMENT OF EDUCATION84.425 - Education Stabilization Fund (ESF)The Education Stabilization Fund (ESF) program was included in the original release of the 2021 Supplement and can be accessed in the “First 2021 Supplement Release” Column. The original release did not include updates to Section 1 of the ESF program section for the implications of the American Rescue Plan (ARP) Act relevant to subprograms 84.425U and 84.425X. Instead, Addendum #1 provided those needed updates which solely impacted Section 1. Note that Section 2 of the ESF program is not included in Addendum #1 because ARP Act updates were already made to that section in the original release. Auditors having clients with funding under subprograms 84.425U or 84.425X and also funding under Section 2 ESF subprograms will have to use the ESF Section 1 in Addendum #1 and ESF Section 2 in the original release. The ESF program in Addendum #1 states that auditors should document whether they use the 2021 Compliance Supplement or 2021 Compliance Supplement Addendum for the audit. Remember that for major program purposes, auditors must evaluate 84.425 in its entirety even though the program is broken down by subprograms with separate alpha characters. Remember also that the ESF program is a higher risk program.
DEPARTMENT OF ENERGY
DEPARTMENT OF HEALTH AND HUMAN SERVICES93.499 - Low Income Household Water Assistance Program 93.558 - Temporary Assistance for Needy Families 93.575 – part of the Child Care Development Fund ClusterAddendum #2 included 1 new program (93.499) targeting assistance to those households with the lowest incomes that pay a high proportion of household income for water and wastewater services. It also included changes to 2 existing programs (93.558 and 93.575) to primarily address new ARP Act funding provisions. Auditors auditing the existing Child Care Development Fund cluster (93.489/93.575/93.596) should note that Addendum #2 makes the reporting type of compliance requirement subject to audit (which includes testing of a financial report and special reporting requirements associated with the Federal Funding Accountability and Transparency Act). HHS received approval to exceed the 6-requirement mandate to add this requirement. Auditors that have previously audited this cluster and issued an audit report dated prior to January 19, 2022, would not be required to go back and test reporting. Notable in the first Supplement release were: (1) Significant changes to the Provider Relief Fund (PRF) (93.498) which is identified as a higher risk program (see Appendix IV below); (2) The COVID-19 Uninsured Program (93.461) is also identified as a higher risk program and has several changes, including changes to the requirements subject to audit; and (3) The Medicaid cluster (93.778/93.775/93.777) also continues to be identified as a higher risk program and includes guidance relevant to COVID-19 flexibilities. Significant changes were also made to several other HHS programs. Review Appendix V below to learn more about those changes.
DEPARTMENT OF HOMELAND SECURITY
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT14.871 - Section 8 Housing Choice VouchersAddendum #2 included 1 existing program (14.87) with changes to address new ARP Act funding provisions. As it relates to the first Supplement release, there are a number of HUD programs with more significant changes this year. Review Appendix V below to learn more about those changes.
DEPARTMENT OF JUSTICE
DEPARTMENT OF LABORThere are several Labor programs with more significant changes this year. Review Appendix V below to learn more about those changes.
DEPARTMENT OF THE INTERIOR
DEPARTMENT OF TRANSPORTATION20.315 - National Railroad Passenger Corporation GrantsAddendum #2 included 1 new program targeted to one recipient, Amtrak. As it relates to the first Supplement release, the Department of Transportation (DOT) has identified the Airport Improvement Program and the Federal Transit Cluster as higher risk programs (see Appendix IV below). Significant changes were also made to several other DOT programs. Review Appendix V below to learn more about those changes.
ENVIRONMENTAL PROTECTION AGENCY
FEDERAL COMMUNICATIONS COMMISSION
GULF COAST ECOSYSTEM RESTORATION COUNCIL
NATIONAL ENDOWMENT FOR THE HUMANITIES
SOCIAL SECURITY ADMINISTRATION
TREASURY21.027 - Coronavirus State and Local Fiscal Recovery Fund (CSLFRF)Addendum #1 included a new program section for CSLFRF which will be a major program for many entities. It is a new ARP Act program and thus, per Appendix IV of the Supplement (access below), is a higher risk program. The Coronavirus Relief Fund program (21.019) is included in the original Supplement release and is also identified as a higher risk program in Appendix IV.
UNITED STATES AGENCY FOR INTERNATIONAL DEVELOPMENT
UNITED STATES DEPARTMENT OF AGRICULTURE10.542 - Pandemic EBT – Food Benefits 10.649 - Pandemic EBT – Admin CostsAddendum #2 included 2 new programs (10.542) to provide school age children with nutrition assistance on Electronic Benefit Transfer (EBT) cards and (10.649) going primarily to defray administrative cost of executing the pandemic EBT initiative.Both programs are state government programs.
Part 5The Student Financial Assistance cluster has significant changes this year. In particular, the Earmarking and Special Tests and Provisions were impacted. Two new Special Tests and Provisions were added as follows: (1) Perkins Loan Recordkeeping and Record Retention; (2) Clock to Credit Hour Conversion. There are a few changes to the “Other Clusters” listing. Assistance Listing 10.579 (Child Nutrition Discretionary Grants Limited Availability) was added to the Child Nutrition Cluster and the Foreign Food Aid Donation Cluster was deleted.
Part 6
Part 7
Appendix I
Appendix IIContent changed for 2021 to identify the federal agencies that have adopted the 2020 revision to the Uniform Guidance and those that have not.
Appendix IIIIncludes contact information for federal contacts for various programs and each agency’s single audit coordinator.
Appendix IVAppendix was significantly revised to expand the list of programs with higher risk designation due to COVID-19 funding and to further explain the impact of that designation on the risk assessment process for both Type A and B programs. Programs on the list are: Medicaid Cluster, Provider Relief Fund, COVID-19 Uninsured Program, Airport Improvement Program, Federal Transit Cluster, Coronavirus Relief Fund, Emergency Rental Assistance, and Education Stabilization Fund.
Appendix VCheck this appendix early on as it describes at a high level the changes made in all of the various sections, including by individual program.
Appendix VI
Appendix VIINew sections added and existing sections updated relevant to COVID-19 funding. Auditors are cautioned that this Appendix (which was included in the original Supplement release) indicates that it includes a ”complete” listing of programs to be included in “a follow-up Supplement Addendum.” However, ultimately, two Addendum were issued, and the listing of programs provided does not reflect what was actually included in the final Addenda. See the “2021 Addenda” column and the “GAQC Observations” column for more description on what the contents of each Addendum.
Appendix VIII
Appendix IX

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