On May 12, 2022, the Office of Management and Budget released the 2022 Compliance Supplement, which is the earliest release of the Compliance Supplement in recent years. The 2022 Compliance Supplement is to be utilized as the primary audit guide for single audits for entities with annual periods beginning July 1, 2021 or later. However, the 2022 Compliance Supplement can be used immediately for the Shuttered Venue Operators Grant (59.075) for any audits of this program for entities whose single audits are not yet complete for periods that began prior to July 1, 2021.

Consistent with the 2021 Compliance Supplement and 2021 Compliance Supplement Addendums, a number of programs are still designated as “higher risk” in the 2022 Compliance Supplement in the respective Part 4 sections and in Appendix IV. A “higher risk” designation will often result in a Type A program being audited as a major program. However, this is not an absolute.

Several significant programs excluded from the 2021 Compliance Supplement are included in the 2022 Compliance Supplement as follows:

• 14.888 – Lead-Based Paint Capital Fund Program and Housing-Related Hazards Capital Fund
• 21.023 – Emergency Rental Assistance (ERA)
• 21.026 – Homeowner Assistance Fund
• 21.029 – Coronavirus Capital Projects Fund
• 32.009 – Emergency Connectivity Fund
• 59.075 – Shuttered Venue Operators Grant (SVOG)
• 93.671 – Family Violence Prevention and Services/Domestic Violence Shelter and Supportive Services

Some key changes to existing programs are as follows:

• 84.425 – ESF – Section 2 – Added Cash Management as applicable for Higher Education Emergency Relief Fund (HEERF) funding which was primarily provided to institutions of higher education.
• 21.027 – Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) – Revisions were added to incorporate the CSLFRF Final Rule. Clarified that the expenditures reported on the Schedule of Expenditures of Federal Awards (SEFA) should not be the total amount of the lost revenue calculated for this program, but the amount of expenditures for government service. Added guidance for the alternative compliance examination engagement that can be completed if 1) the recipient’s CSLFRF award is below $10 million and 2) all other federal awards expended in the fiscal year are less than $750,000.
• 93.498 – Provider Relief Funds (PRF) – Guidance was added regarding the removal of the Special Tests and Provisions requirement and clarifies lost revenue reporting on the SEFA.
• 59.075 – SVOG – Activities Allowed, Allowable Costs, and Period of Performance are the only applicable compliance requirements. Notice was provided that audits of for-profit entities with SVOG would be forthcoming from the Small Business Administration (SBA) and auditors should only use the Compliance Supplement for non-profit or governmental entities.

The Federal Audit Clearinghouse (FAC) is changing providers. Single audits with a fiscal period ending in 2021 or earlier will continue to be reported to the current FAC until October 1, 2022 at which time the FAC will transition to a new provider. Single audits with a fiscal period ending in 2022 will be submitted to the new FAC beginning October 1, 2022.

Other less significant changes were noted to other programs and parts of the 2022 Compliance Supplement. The 2022 Compliance Supplement can be found here. 

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