2022 Compliance Supplement Misses Stated Deadline Date

It was so clear — the date was published in a federal document. We were all fully expecting its release. And yet … we still wait for the issuance of the 2022 OMB Compliance Supplement.

Long-time readers of this blog should be familiar with our tradition for doing posts discussing the annual release of the Compliance Supplement and our use of turtles to symbolize the slow progress surrounding its release. Well, this year, we have to feature a huge turtle because we actually had a release date quoted to the public that came and went with no document forthcoming.

Auditors for years have been clamoring for the Compliance Supplement, which typically is released sometime during the summer, to be released earlier in the year so that they can better conduct their audits. In a controller alert issued last December, OMB stated that it was giving federal agencies a strict timeline for submitting audit guidance on financial assistance programs to enable OMB to publish the 2022 Compliance Supplement by April 30, 2022 (see “OMB Sets Schedule To Publish Next Compliance Supplement in April 2022”).

To ensure that agencies provided the most important updates for auditor testing under Part 4 of the supplement, OMB told them to limit changes in the 2022 supplement to four areas: (1) updates or additions required due to changes in statutory or regulatory requirements; (2) updates or additions necessary to highlight coverage of an area found to be critically vulnerable to waste, fraud, abuse or increased likelihood of improper payments; (3) updates or additions necessary to highlight the review of performance reporting and results; and (4) removal of references to programs no longer required for audit or no longer warranting inclusion in Part IV, requirements not supported by statute or regulation and reporting requirements not supported by a valid Paperwork Reduction Act clearance number.

After working with agencies on this strict timeline, OMB had hoped to issue a draft version of the 2022 supplement this past winter and collect all stakeholder comments on that draft by Jan. 18, which would enable it to finalize any changes to the draft and release the final version on April 30.

So here we are, the first week of May, and the 2022 supplement still has not been issued as promised. In fact, OMB was still making updates to the 2021 version as of last month (see “OMB Issues Update to 2021 Compliance Supplement”). We have contacted OMB to find out if they have any updates on its release date but have yet to receive a response.

And so we wait! Thompson Grants will continue to follow the progress of the 2022 Compliance Supplement and will let our subscribers know when it is released, as well as what important details it includes.

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