OMB Tells Audit Community To Expect Two Compliance Supplement Addenda
Just when we thought everyone was on the same page with all the latest information, something new comes along.
We at Thompson Grants recently provided analysis on the 2021 Compliance Supplement released earlier this month. The 2021 supplement replaced the 2020 version and the 2020 Compliance Supplement addendum, and applies to audits of fiscal years beginning after June 30, 2020. OMB issued an addendum in November 2020 to last year’s supplement to address audit requirements for COVID-19 programs that it could not timely include in the 2020 supplement.
Just like last year, the 2021 supplement in Appendix VII explained that OMB, for a second year in a row, plans to issue an addendum again this fall with more details on Part 3 compliance testing and Part 4 program requirements for funds allocated for COVID-19 programs under the American Rescue Plan (ARP) Act (Pub. L. 117-2) and the Coronavirus Response and Relief Supplemental Appropriations Act (Pub. L. 116-260).
However, we recently found out from the American Institute of Certified Public Accountant’s Government Audit Quality Center (GAQC) that OMB, since the finalized version of the supplement was published, has informed the audit community that it now plans to issue not one, but two, addenda. According to GAQC, the first will be issued in the early fall and likely include two programs ― the Coronavirus State and Local Fiscal Recovery Fund and the update to the Education Stabilization Fund. Then a second addendum will be issued later in the fall to address three Treasury Department programs (Capital Projects Fund, Homeownership Assistance Fund and the Local Assistance and Tribal Consistency Fund), and may even include other new programs.
GAQC noted that it will be “strongly advocating” that OMB publish a complete listing of programs to be included beyond those identified in Appendix VII as soon as possible so that auditors are aware of what is coming and whether there will be implications on their single audits. The addenda, when published, will be posted at CFO.gov.
As we find out more, we will provide information on these addenda. Needless to say, these last few years have been especially trying for auditors attempting to conduct work on their audits.
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Thompson Grants Workshop: The American Rescue Plan Act | August 26, 2021
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