The Uncommon Journeys of the 2021/2022 Compliance Supplements

We’re definitely navigating some unchartered waters these days when it comes to Office of Management and Budget (OMB) Compliance Supplement developments. In normal years, the annual supplement would be issued during the summer, and early the following year, OMB would make a review draft available for audit community comment of that year’s upcoming supplement. Like two ships passing in the night, we currently are still waiting on the completion of audit guidance under the 2021 supplement, while reviews of the 2022 draft supplement are already under way.

To clarify, OMB released the 2021 Compliance Supplement in August. Because federal agencies did not have enough time to develop audit guidance for their programs under the American Rescue Plan Act (ARPA) (Pub. L. 117-2), OMB announced that it would provide further guidance under two addenda later in 2021. In early December, it issued the first of these addenda to provide guidance related to certain Education Department and Treasury Department programs. However, 2021 ended before OMB could release the second addendum, which will provide specific programs from other agencies. We have never seen a instance where audit guidance related to a specific year’s supplement has not been wrapped up before the end of the year.

Meanwhile, federal agencies have been tasked by OMB to follow an expedited review of its programs and prepare audit guidance quicker to enable OMB to issue the 2022 Compliance Supplement in April 2022, which would prove especially helpful to auditors and grantees to get their audits done in a more expedited manner. Agencies developed this guidance this fall, and OMB in December 2021 made a “vet draft” version of the 2022 supplement available to the audit community for review and comment. The draft includes programs overseen by the departments of Agriculture, Commerce, Education, Energy, Health and Human Services, Housing and Urban Development and Labor, as well as the Corporation for National and Community Service, Federal Communications Commission and Small Business Administration. Stakeholder comments are due by Jan. 18, and agencies will assess these comments when finalizing their audit guidance for inclusion in the 2022 supplement.

Hopefully, the second addendum will be released soon so we can close the books on 2021 and set our sights on 2022. Unchartered waters indeed!

Join us for our following Thompson Grants event:
Thompson Grants Workshop: Managing Key ARPA Programs, their Relation to the Uniform Guidance Addendum| Jan. 27, 2022 | Washington, D.C.
Nonprofit Legal, Finance, and Grants Conference | March 22, 2022 | Washington, D.C.