2018 OMB Compliance Supplement
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Common Single Audit Deficiencies
The 2018 Office of Management and Budget (OMB) Compliance Supplement was issued in a different format than prior years in that OMB only provided significant updates and changes. Therefore, auditors will need to use the 2018 and 2017 Supplements together to perform single audits of fiscal years beginning after June 30, 2017. It is important for auditors to ensure that audit teams are appropriately using the two Supplements together.
OMB has only posted a single PDF version of the 2018 Supplement on the OMB Web site. As a public service, the GAQC is posting the 2018 Supplement broken down by section below. These individual sections were excerpted from the full PDF file posted on the OMB Web site.
Additionally, to help auditors be more efficient, we have posted below the various sections of the 2017 Supplement that will still need to be used for easy reference. To further assist, we have included a watermark in the 2017 Supplement files below identifying sections that have been superseded or deleted by the 2018 Supplement. This marking of the 2017 files has been done to help auditors avoid mistakenly using a superseded or deleted section of the 2017 Supplement and is nonauthoritative.
Finally, pay close attention to the key auditor considerations in the table below which we have provided to offer auditors tips and reminders about using the 2018 and 2017 Supplements together.
2018 Supplement by Section |
2017 Supplement by Section |
Key Auditor Considerations When Using 2018 and 2017 Supplements Together |
2018 Title Page |
* |
None. |
2018 Table of Contents |
2017 Table of Contents |
The 2018 Supplement Table of Content (TOC) is a critical part of ensuing appropriate Supplement usage. It represents a roadmap of how the 2 Supplements are to be used together. The TOC from 2017 is only useful for identifying the location and content of sections that were not affected by 2018 Supplement issuance.
|
2018 Part 1 |
* |
2018 Part 1 is important as it explains in the “Purpose and Applicability” section how the 2 Supplements are to be used together.
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2018 Part 2 See Key Auditor Considerations Column for Explanation |
2017 Part 2 |
Use the compliance requirement applicability matrices found in the new/revised program sections in Parts 4 and 5 of the 2018 Supplement. Otherwise, use the 2017 Part 2 matrix for all other existing unchanged programs.
|
2017 Part 3 |
Use the 2018 updated 3.2.I, “Procurement and Suspension and Debarment” when testing this requirement for entities that have adopted the Uniform Guidance procurement requirements. 2018 Part 3.2.I. should also be considered in conjunction with 2018 Appendix VII-A guidance on procurement below. Otherwise, auditors should use the remainder of Part 3 (i.e., 3.1 and 3.2) in the 2017 Supplement for all other compliance testing. Reminder: If your clients have not adopted the Uniform Guidance procurement requirements yet, you should be using 2017 Part 3.1.I for your compliance testing of this requirement. |
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** |
No changes made to this Part 4 section. Use 2017 Supplement.
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** |
No changes made to this Part 4 section. Use 2017 Supplement. |
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** |
No changes made to this Part 4 section. Use 2017 Supplement.
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** |
No changes made to this Part 4 section. Use 2017 Supplement.
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Use the 2018 Supplement when testing the following programs: 84.000 (cross-cutting section), 84.010, 84.011, 84.282, 84.365, 84.367, and 84.424 (new program). Otherwise, use the 2017 Supplement section for Department of Education programs. NOTE 1: The 2018 TOC notes that the following Education programs are deleted: 84.377 and 84.395. NOTE 2: The cross-cutting section (84.000) in the 2018 Supplement may need to be used by the auditor when testing certain programs that were unchanged and continue to appear in the 2017 Supplement.
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** |
2017 DEPARTMENT OF ENERGY |
No changes made to this Part 4 section. Use 2017 Supplement.
|
Use the 2018 Supplement when testing the following programs: 93.224, 93.527, 93.575, 93.596, and 93.600; and the new Tribal, Maternal, Infant, and Early Childhood Home Visiting Program Cluster (93.872/93.508). Otherwise, use the 2017 Supplement section for Department of Health and Human Services.
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** |
No changes made to this Part 4 section. Use 2017 Supplement.
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** |
No changes made to this Part 4 section. Use 2017 Supplement.
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** |
No changes made to this Part 4 section. Use 2017 Supplement.
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** |
2017 DEPARTMENT OF LABOR |
No changes made to this Part 4 section. Use 2017 Supplement.
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** |
No changes made to this Part 4 section. Use 2017 Supplement.
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Use the 2018 Supplement when testing the following programs: Highway Planning and Construction Cluster (20.205, 20.219, 20.224, 23.003), 20.319, and Federal Transit Cluster (20.500, 20.507, 20.252, 20.526). NOTE: When using these 2018 DOT program sections, auditors need to also refer to the DOT Cross-Cutting Section in the 2017 Supplement. For all other DOT programs, use the 2017 Supplement section for Department of Transportation.
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** |
No changes made to this Part 4 section. Use 2017 Supplement.
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** |
No changes made to this Part 4 section. Use 2017 Supplement.
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** |
No changes made to this Part 4 section. Use 2017 Supplement.
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* |
Use the 2018 Supplement only. |
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** |
2017 TREASURY |
No changes made to this Part 4 section. Use 2017 Supplement.
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** |
No changes made to this Part 4 section. Use 2017 Supplement.
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** |
No changes made to this Part 4 section. Use 2017 Supplement.
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2018 Part 5 SFA |
2017 Part 5 |
Use 2018 Supplement when testing the Student Financial Assistance (SFA) cluster. Also use the 2018 Supplement to determine Other Clusters. When testing Research and Development, use the 2017 Supplement. |
** |
2017 Part 6 |
No changes made to this section. Use 2017 Supplement.
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** |
2017 Part 7 |
No changes made to this section. Use 2017 Supplement.
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** |
2017 Appendix I |
No changes made to this section. Use 2017 Supplement.
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** |
2017 Appendix II |
No changes made to this section. Use 2017 Supplement.
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** |
2017 Appendix III |
No changes made to this section. Use 2017 Supplement.
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** |
2017 Appendix IV |
No changes made to this section. Use 2017 Supplement.
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2018 Appendix V |
* |
Use this Appendix in conjunction with the TOC for best understanding. Review this section closely to understand changes made in the 2018 Supplement. |
** |
2017 Appendix VI |
No changes made to this section. Use 2017 Supplement.
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2018 Appendix VII-A |
2017 Appendix VII |
Use 2018 Appendix VII-A (includes new guidance on procurement and impact of hurricanes) with 2017 Appendix VII. 2018 Appendix VII-A guidance on procurement should be considered in conjunction with 2018 Part 3.2.I. above.
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** |
2017 Appendix VIII |
No changes made to this section. Use 2017 Supplement.
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** |
2017 Appendix IX |
No changes made to this section. Use 2017 Supplement.
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* 2017 Supplement section not provided since related 2018 Supplement superseded it.
** 2018 Supplement section not included because 2017 Supplement continues to apply.
