Entities receiving over $750,000 in federal funds are required to have a Single Audit under the Uniform Guidance. The Compliance Supplement (CS) is issued every year and is effective for June 30th and later year ends. The Compliance Supplement provides important updates for both auditors and entities regarding Single Audit compliance. The auditor will follow the CS when conducting the Single Audit. In addition, organizations may wish to refer to the CS to understand what the auditor is looking for and to review which federal programs are grouped together into clusters. The Compliance Supplement had to be re-issued this August to replace the June 2019 version. Listed below are some key questions (and answers) that have arisen with respect to the latest CS that was issued.
I heard there was a correction edition of the Compliance Supplement what does that mean?
The original Compliance Supplement – June 2019 edition was more robust than the prior year and contained numerous errors. This was replaced by the August 2019 edition (issued September 20, 2019).
What if audit work was done before the August 2019 edition was available?
For reports issued on or before October 31, 2019, your auditor is permitted to use either the June or August 2019 editions. For reports issued after October 31, 2019, the August 2019 edition must be used. In all cases, the auditor will document which edition was used.
What if the audit work was done using the June 2019 edition but the report is not yet issued?
The auditor will review the Errata Page section after the Table of Contents to determine changes made. It is possible that the auditor will need to do additional work because of the changes in the CS. Fortunately, not every area had changes. In either case, the auditor will have more work to document the use of the August 2019 edition by either swapping out the June pages for August pages (with needed references) or keeping June 2019 edition but including documentation that all June copies were verified and there were no changes.
I heard the 2019 Supplement 6-requirement mandate is why certain auditor procedures have changed this year, but I am still confused?
The OMB (Office of Management and Budget) required federal agencies to limit compliance requirements to 6 per program or cluster; except the Research & Development cluster is permitted to identify 7. Also A. Activities Allowed and Unallowed, and B. Allowable Costs and Cost Principles, are counted as one requirement. This may result in certain areas such as reporting, cash management, program income, etc. not being audited for compliance. The change in audit requirements does not eliminate the need for the client to comply in all areas of the award agreement or Uniform Guidance administrative requirements or cost principles.
My auditor appears to be testing more than 6 areas, why?
There are twelve key areas for audit under the CS and if your federal program is not listed in Part 2 the auditor is required to test all areas that are direct and material, not just six. The twelve key area are:
- Activities Allowed or Unallowed
- Allowable Costs/Cost Principles
- Cash Management
- Eligibility
- Equipment Real Property Management
- Matching, Level of Effort, Earmarking
- Period of Performance
- Procurement Suspension & Debarment
- Program Income
- Reporting
- Subrecipient Monitoring
- Special Tests and Provisions
To access the August 2019 Compliance Supplement: