The AICPA Governmental Audit Quality Center (GAQC) is a voluntary membership center for CPA firms and state audit organizations (SAO) that promotes the quality of governmental audits. As a public service, the GAQC annually makes the Office of Management and Budget (OMB) Compliance Supplements available by section in this Compliance Supplement Resource Center. Learn more about the GAQC and its activities.
On May 12, 2022, OMB released the 2022 OMB Compliance Supplement (the 2022 Supplement), which is effective for audits of fiscal years beginning after June 30, 2021. It supersedes the 2021 Compliance Supplement (dated August 2021) and its Addenda (dated December 2021 and January 2022). See GAQC Alert #441 for more details.
The 2022 Supplement was released on the OMB Web site in one large PDF file. The 2022 Supplement is broken down below by individual section . These individual sections were excerpted from the full PDF file posted on the OMB Web site. The GAQC has provided observations on Supplement sections listed below that had significant changes.
The OMB has told the GAQC that there will not be an Addendum to the 2022 Supplement. Instead, any new programs that are established as a result of the Infrastructure Investment and Jobs Act will be included in the 2023 Supplement.
To learn more about the 2022 Supplement, listen to the no-CPE archive of the GAQC Web event, titled 2022 Compliance Supplement and Single Audit Update.
DEPARTMENT OF COMMERCE
Changes were made to the Economic Development Cluster (ALN #11.300 / 11.307) to incorporate the requirements related to the CARES / American Rescue Plan (ARP) Acts.
DEPARTMENT OF EDUCATION
The Education Stabilization Fund (ESF) (84.425) is identified as a higher risk program and continues to be broken down into two sections covering the various ESF subprograms. The following new subprograms were added: 84.425(V) in Section 1 and 84.425T in Section 2. 84.425P was moved to Section 2 (it was included in the listing of programs not included in either sections 1 or 2 in the 2021 Supplement).
Regulatory changes and other updates have also been made throughout the ESF section. Section 2 also has identified the Cash Management type of compliance requirement as subject to audit for the first time.
Finally, the Supplement continues to include the requirement for the identification of the ESF subawards on the SEFA by the ALN alpha. 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.
Several other Education programs also have regulatory updates and other compliance requirement clarifications. Review Appendix V below to learn more about the specific changes.
DEPARTMENT OF HEALTH AND HUMAN SERVICES
Updates made to the HRSA COVID-19 Uninsured Program (93.461) and the Provider Relief Fund and American Rescue Plan Rural Distribution (PRF) program (93.498) to incorporate additional regulatory changes and other guidance issued by HHS over the past year. Both programs were again identified as higher risk programs (see Appendix IV below). Updates to the PRF program include the addition of Period 5 to the table detailing the various periods of payment received/periods of availability/reporting periods. In addition, the Special Tests and Provisions requirement was removed for the PRF Program.
The Medicaid cluster (93.778/93.775/93.777) also continues to be identified as a higher risk program (see Appendix IV below). Guidance added to this section states that although an auditor is not precluded from concluding Medicaid is low-risk, that any such designation should be supported by audit documentation and consideration of the program risks described in the program section. Other regulatory changes and updates were made including several resulting from the ARP Act.
In addition, the Family Violence Prevention and Services/Domestic Violence Shelter and Supportive Services (93.671) was newly added to the Supplement.
Changes were also made to several other HHS programs. Review Appendix V below to learn more about those changes.
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Lead-based Paint Capital Fund Program and Housing-Related Hazards Capital Fund (14.888) was newly added to the 2022 Supplement.
Other updates made to several HUD programs to reflect regulatory changes and to clarify the compliance requirements. Review Appendix V below to learn more about those changes.
DEPARTMENT OF LABOR
Local Veterans’ Employment Representative (LVER) Program (17.804) was removed from the Employment Service Cluster and from the 2022 Supplement.
Other updates made to several Labor programs to reflect regulatory changes and to clarify the compliance requirements. Review Appendix V below to learn more about those changes.
DEPARTMENT OF TRANSPORTATION
The following programs, noted by Assistance Listing, were removed from the Highway Safety Cluster: 20.601, 20.602, 20.609, 20.610, 20.612, and 20.613
FEDERAL COMMUNICATIONS COMMISSION
Significant changes made to the COVID-19 Telehealth Program (32.006) to expand on the program requirements. In addition, the Emergency Connectivity Fund Program (32.009) was newly added to the Supplement and was designated as a higher risk program.
SMALL BUSINESS ADMINISTRATION (SBA)
SBA has never been included in the Supplement until this year. The Shuttered Venue Operators Grant (SVOG) program (59.075) was added and states that the program section is to be used for audits of non-federal entities with SVOG funding. However, for-profit entities and their auditors should be aware that separate audit requirements and guidance for audits of for-profit entities with SVOG funding issued by the Small Business Administration will be posted upon completion at: https://www.sba.gov/funding-programs/loans/covid-19-relief-options/shuttered-venue-operators-grant/manage-your-svog-grant.
The SVOG section includes a note emphasizing that an auditor can utilize the 2022 Supplement section as a resource when developing the audit approach in a single audit subject to the 2021 Supplement (in conjunction with the use of Part 7 of the Supplement).
New key programs added to the Supplement and identified as higher risk programs:
Emergency Rental Assistance Program (21.023)
Homeowner Assistance Fund Program (21.026)
Coronavirus Capital Projects Fund (21.029)
The Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) (21.027), which continues to be identified as a higher risk program, was updated for the CSLFRF Final Rule. Among other updates, the section includes the changes announced in the recent Technical Update to the 2021 Supplement which introduced an alternative compliance examination engagement for certain recipients.
The Coronavirus Relief Fund (CRF) (21.019) is no longer identified as a higher risk program in the Supplement.
UNITED STATES DEPARTMENT OF AGRICULTURE
Fresh Fruit and Vegetable Program (ALN #10.582) was added to the Child Nutrition Cluster with several related changes made in the requirements section.
The Child Nutrition Discretionary Grants Limited Availability program (10.579) was removed from the Child Nutrition Cluster.
In addition, regulatory updates and other clarifications were made to several other programs. Review Appendix V below to learn more about those changes.
The Student Financial Assistance Cluster had several changes, clarifications, and updates for 2022 to reflect regulatory changes and other updates. These changes relate primarily to various Special Tests and Provisions such as Disbursements to or on Behalf of Students, Return of Title IV Funds, Enrollment Reporting, Program Eligibility, and Distance Education.
In addition, several changes were made to the Other Clusters section of Part 5 this year, including the Child Nutrition Cluster, Employment Service Cluster, and Highway Safety Cluster.
Content changed for 2022 to identify the federal agencies that have adopted the 2020 revision to the Uniform Guidance and those that have not.
Includes contact information for federal contacts for various programs and each agency’s single audit coordinator.
Appendix was updated with the complete list of programs with higher risk designation due to COVID-19 funding and now also includes specific identification of higher risk ARP Act programs.
The section now also identifies which of the higher risk programs are 100% COVID-19 funding which is an important distinction in determining whether a higher risk program should be audited in the current year.
Check this appendix early on as it describes at a high level the changes made in all the various sections, including by individual program.
Much of the guidance in this Appendix has been carried forward from the prior year including guidance on how to correctly present COVID-19 funding on the schedule of expenditures of federal awards and the Data Collection Form. In addition, the Appendix includes new information on the upcoming Federal Audit Clearinghouse (FAC) transition from Census to the General Services Administration (GSA) and the related timing. It also includes submission guidance for fiscal year 2022 single audits completed prior to the new GSA FAC being available (expected October 1, 2022).
Still working on a 2021 single audit? Access the GAQC posting of the 2021 Compliance Supplement and related Addenda. Note that the 2021 Supplement is effective for audits of fiscal years beginning after June 30, 2020, through June 29, 2021.