Navigating the 2024 Revised Uniform Guidance: What You Need to Know
In May 2024, the Office of Management and Budget (OMB) released the 2024 Compliance Supplement. This document serves as a critical resource for entities receiving federal funds, offering guidance on how to comply with the myriad of regulations and requirements imposed by various federal agencies. The 2024 supplement supersedes the previous compliance supplement released in 2023.
Understanding the Compliance Supplement
The Compliance Supplement serves as a critical roadmap for auditors conducting single audits of entities that expend over $750,000 in federal awards annually. It delineates specific compliance expectations, ensuring federal funds are utilized efficiently and in accordance with regulations.
Key Updates and Changes for 2024
The 2024 edition introduces significant updates aimed at reflecting evolving federal programs and legislation:
- Changes to numerous agency program requirements, including several new programs being added, are noted in Part 4 of the supplement. Some of these new programs are being funded through the Infrastructure Investment and Jobs Act (IIJA). You should review Appendix V and Part 4 for changes to specific federal programs applicable to your organization.
- The Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing 21.027) purpose was expanded to add providing emergency relief from natural disasters or the negative economic impacts of natural disasters, use of funds for surface transportation projects, and use of funds for projects eligible under the programs established in Title I of the Housing and Community Development Act of 1974 (Title I Projects). There is also language included related to alternative compliance examination engagements over Coronavirus State and Local Fiscal Recovery Funds for organizations that may newly be required to complete a single audit.
- Appendix IV was updated for federal programs that contain a higher risk designation identified by federal agencies. This impacts the auditor’s major program determination process and can affect federal programs selected for testing as part of an organization’s single audit.
The 2024 higher risk designation programs include:
| Agency | Assistance Listing Number | Title |
| HHS** | 93.778/93.777/93.775 | Medicaid Cluster |
| Treasury* | 21.023 | Emergency Rental Assistance |
| Treasury* | 21.027 | Coronavirus State and Local Fiscal Recovery Funds |
| Interior* | 15.252 | Abandoned Mine Land Reclamation (AMLR) |
** This program was an existing program that received additional IIJA or COVID-19 funding from one or more acts that provided assistance related to the COVID-19 pandemic.
*These programs were created by one or more acts that provided assistance related to the COVID-19 pandemic and thus considered 100% COVID-19 funding.
Programs removed from the higher risk designation include:
| Agency | Assistance Listing Number | Title |
| Treasury | 21.026 | Homeowner Assistance Fund |
| Treasury | 21.029 | Coronavirus Capital Projects Fund |
| Education | 84.425 | Education Stabilization Fund |
| HHS | 93.498 | Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution |
| Social Security | 96.001/96.006 | Disability Insurance/Supplemental Security Income |
- Appendix VII provides several audit advisories. The most noteworthy is the advisory related to 2024 Revisions to OMB’s Guidance for Federal Assistance. These revisions are effective October 1, 2024; however, federal agencies may elect to implement the revisions as early as June 21, 2024. The revisions will increase the audit threshold from $750,000 to $1,000,000 for auditee fiscal years beginning on or after October 1, 2024.
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