Released: July 1, 2019
Effective for audits of years ending June 30, 2019, and later
The entire compliance supplement is available to the public here.
The general format and sections of the Compliance Supplement remain consistent with prior years, but there are important changes that will affect upcoming Single Audits. Auditees expending federal funds may refer to this information to assist in administering and managing their federal award programs.
We would first like to draw your attention to Part 6 of the 2019 OMB Compliance Supplement in particular, as it has been overhauled and now contains a wealth of information related to internal controls at the entity-wide level and at the transactional level. CRI is encouraging clients to read and refer to this section for great ideas for improving and documenting organizational policies, procedures, and controls relevant to grant programs.
The 2019 OMB Compliance Supplement consists of Parts 1 through 7 and includes several appendices with additional information, including audit advisories (Appendix VII) and contact information for various federal entities (Appendix III). Below is a summary of the contents within each Part:
- Part 1: Important updates that are effective for this year, as well as general information about the supplement itself and the Single Audit process.
- Parts 2 – 5 and 7: Information used in conducting Single Audits, including the requirements that will be subject to audit this year.
- Part 3 contains general information, and Parts 4 and 5 provide program-specific guidance that grant recipients, pass-through entities, and sub-recipients may all find useful in managing funding and monitoring compliance in coordination with grant agreements, contracts, and information provided by grantors and regulatory bodies.
- Part 7 applies to programs not included separately in the compliance supplement and may be used at the grantee level as a resource for organizing and documenting controls, and determining which compliance requirements apply to federal programs.
The sections listed above are all useful for persons charged with managing and monitoring federal grant compliance.
Part 6 is undoubtedly one of the best resources for grant recipients, pass-through entities, and sub-recipients interested in understanding and strengthening internal controls related to compliance. We encourage all entities interested in the management and stewardship of federal grant funding to read and use this information. Part 6 includes:
- Basic information about the Uniform Guidance internal control requirements.
- Background information useful in understanding and adapting control principles and controls to entities of any size and complexity.
- Illustrative controls for eleven of the 12 types of compliance requirements and all 17 principles of internal control (from the Committee of Sponsoring Organizations (COSO) framework).
As always, don’t hesitate to reach out to CRI’s grant specialists with any questions!