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Focus on Public Sector and Not-For-Profits: 2017 Compliance Supplement

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On August 14, 2017, the Office of Management and Budget (OMB) announced the release of the 2017 OMB Compliance Supplement. The compliance supplement contains the policies and procedures required to be followed by federal, state and local entities in regards to expending federal funding and the procedures required to be performed by auditors when conducting the single audit over these federal programs.
September 13, 2017

On August 14, 2017, the Office of Management and Budget (OMB) announced the release of the 2017 OMB Compliance Supplement. The compliance supplement contains the policies and procedures required to be followed by federal, state and local entities in regards to expending federal funding and the procedures required to be performed by auditors when conducting the single audit over these federal programs. Organizations that receive and expend federal funding should familiarize themselves with the provisions of the 2017 Compliance Supplement in order to ensure they are adhering to all associated federal regulations and to prepare for the single audit.

The regulations included in the 2017 Compliance Supplement are effective for years ending June 30, 2017 or later unless otherwise specified within the supplement. The 2017 Compliance Supplement contains a number of key changes from the previous 2016 Compliance Supplement (issued in July 2016). Appendix V, Lists of Changes for the 2017 Compliance Supplement summarizes the majority of the key changes.

Some of the key changes to the supplement noted in Part 2 - Matrix of Compliance Requirements include updating the matrix to add and remove various programs. A number of programs also had changes to the applicable compliance requirements for the specific program. Most notable changes were made to the following programs:

  • CFDA 84.002, Adult Education – State Grant Program
  • CFDA 93.224 and 93.527, Health Center Programs
  • CFDA 93.600, Head Start
  • Student Financial Aid Cluster

The only significant notable change to Part 3 – Compliance Requirements is the inclusion of the extension of the grace period for compliance with the new procurement requirements set forth in the Uniform Guidance from 2 to 3 years. This extension was made on May 17, 2017 and extends the requirement for recipients of federal funds to follow the new procurement standards starting with fiscal years beginning on or after December 26, 2017.

For more information regarding the grace period, see RubinBrown's Focus on Public Sector, Not-For-Profit and Colleges & Universities: Extension of Grace Period for Uniform Guidance Procurement Rules.

A number of programs added, removed or revised requirements due to regulatory changes in Part 4 – Agency Program Requirements. Other federal agencies also included other changes to a smaller number of programs. Most notable changes other than those noted above were noted for the following programs:

  • CFDAs 10.565, 10.568 and 10.569, Food Distribution Cluster
  • CFDAs 14.218 and 14.225, CDBG Entitlements Grant Cluster
  • CFDA 16.738, Edward Byrne Memorial Justice Assistance Grant
  • CFDAs 17.258, 17.259 and 17.278, WIOA Cluster
  • CFDAs 20.205, 20.219, 20.224 and 23.003, Highway Planning and Construction Cluster
  • CFDA 84.010, Title I Grants to Local Educational Agencies and CFDA 84.367, Supporting Effective Instruction State Grant

Part 5 – Clusters of Programs of the supplement had minimal changes for clusters other than the Student Financial Assistance Cluster in 2017. Key changes for the Student Financial Assistance Cluster include:

  • Information regarding the Perkins Loan Extension Act of 2015 which extended the Perkins Loan program through September 30, 2017 was included in section III.E.1 “Eligibility for Individuals” section.
  • Department of Education programs were no longer considered applicable for Period of Performance requirements in Section III.H.

An additional cluster, the 477 Cluster, was added in the current year to include a number of Tribal grants funded through the DOI, DOL and DHHS. The Maternal, Infant and Early Childhood Home Visiting Center Cluster was also added to the list of clusters which includes grants funded by HHS. The respective compliance requirements of the programs included in these clusters are included in Part 4 of the Compliance Supplement.

Part 6 – Internal Control and Part 7 – Guidance for Auditing Programs Not Included in This Compliance Supplement are unchanged in the 2017 Supplement from the 2016 Supplement. Additional changes were noted in Appendix III – Federal Agency Single Audit, Key Management Liaison, and Program Contacts to update contact information for program contacts and other key single audit offices and officials.

For more information, please visit the Federal Register Notice announcing the release of the 2017 Compliance Supplement or see the full 2017 Compliance Supplement.

 

Any federal tax advice contained in this communication (including any attachments): (i) is intended for your use only; (ii) is based on the accuracy and completeness of the facts you have provided us; and (iii) may not be relied upon to avoid penalties.

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