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2022 OMB Compliance Supplement

On April 2, 2022, the OMB released the 2022 Compliance Supplement. The Compliance Supplement is an important tool used by auditors for completing a single audit. The 2022 supplement supersedes the previous compliance supplement and addendum released in 2021.

2022 Compliance Supplement Changes

The 2022 supplement identified several changes from the previous version of the supplement. A summary of key changes includes:

  • Numerous changes to agency program requirements are noted in Part 4 of the supplement. This section, along with Appendix V should be reviewed for changes to specific federal programs.
  • Appendix IV has been updated for a list of programs currently designated as higher risk. Assistance Listing 32.009 (Emergency Connectivity Fund Program) and 20.315 (National Railroad Passenger Corporation Grants) have been added to the prior list of higher risk programs due to receiving funding related to COVID-19. A higher risk designation often results in a program or cluster being audited. However, an auditor is not required from determining a higher risk program qualifies as low risk.
  • Provider Relief Fund (Assistance Listing 93.498) has been renamed to Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution.
  • If your organization received Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), the 2022 Compliance Supplement offers an alternative to a single audit or program-specific audit. The CSLFRF program is a $350 billion U.S. Treasury Program. This funding was awarded to many small entities that would have been required to have a single audit performed for the first time. Alternatively, if your organization received this funding, you can have a compliance examination performed in accordance with the AICPA Statements on Standards for Attestation Engagements and Government Auditing Standards. To qualify for this engagement, the total CSLRF award is at or below $10 million and other federal funds expended during the year (excluding CSLRF award funds) are less than $750,000 during the organization’s fiscal year.
  • Appendix VII provides information on other audit advisories and announcements from the OMB that may impact your 2022 single audit.
    • On October 1, 2022, the Federal Audit Clearinghouse (FAC) will transition from Census to General Services Administration (GSA). Single audits with a fiscal period ending in 2021 (or earlier) should continue to submit their data collection form (DCF) to Census. Single audits with a fiscal period ending in 2022 will be submitted to GSA beginning on October 1, 2022. The DCF is due typically the earlier of 9 months after year-end or 30 days after the issuance of the report date. The OMB has noted that if it is not possible to meet the requirement listed above for a timely DCF filing due to the timing of the opening of the GSA FAC for submission, the audit will not be considered late if they are submitted within nine months after the end of the audit period.

Please contact us if you have questions about the information outlined above, our seasoned and experienced nonprofit professionals are here to help. You can also learn more about our Nonprofit services by visiting our website.

About the Author

Jackie Winchell

Jackie joined McKonly & Asbury in 2013 and is currently a Principal with the firm. Jackie is a member of the firm’s Audit & Assurance Segment, specializing in serving clients in the nonprofit industry, providing expertise on audi… Read more

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