2020 OMB Compliance Supplement and Related Addendum (By Section)
December 22, 2020
IMPORTANT NOTICE: On December 22, 2020, the Office of Management and Budget (OMB) released the Addendum to the 2020 Office of Management and Budget (OMB) Compliance Supplement (the Supplement addendum). See GAQC Alert #419 and GAQC Alert #413 for more details about the Supplement addendum and the previously released August 2020 Supplement. Listen also to several GAQC archived no-CPE Web events to learn more about these OMB issuances at: https://www.aicpa.org/interestareas/governmentalauditquality/resources/single-audit-archived-events.html.
As a public service, the GAQC has posted both the Supplement addendum and the August 2020 Supplement by individual section below. Each section was excerpted from the official full PDF files which can be found on OMB’s Office of Federal Financial Management Web site at: https://www.whitehouse.gov/omb/management/office-federal-financial-management/. To assist members, the table below also includes GAQC observations about the Supplement addendum files.
August 2020 Supplement
Supplement Addendum Sections, Including Assistance Listing Numbers
GAQC Observations on the Supplement Addendum
|Table of Contents|
|Part 1 - Scope||
Key points made in updates to this section:
The effective date is same as for August 2020 Supplement (i.e., for audits of fiscal years beginning after June 30, 2019)
The addendum must be used in conjunction with August 2020 Supplement in determining the appropriate audit procedures to support the compliance opinion
A description is provided of which parts of the August 2020 Supplement are being modified, as well as which sections are new
|Part 2||The Supplement addendum matrix Identifies the requirements subject to audit for all new programs (noted with “new” after the title and bolded), as well as existing programs that are included in the addendum.|
|Part 3.L Reporting||A new reporting requirement has been added relating to Federal Funding Accountability and Transparency Act reporting (FFATA) by direct recipients who make first-tier subawards of $25,000 or more. Auditors must test FFATA reporting for all the COVID-19 programs included in the Supplement addendum (except for the Coronavirus Relief Fund program) and the audit requirement is extended to all selected major programs meeting (meeting the above described criteria) for audits of fiscal years after September 30, 2020, regardless of whether COVID-19 funding is involved.|
|84.425, Education Stabilization Fund (ESF)||This new COVID-19 program was established to prevent, prepare for, and respond to coronavirus, domestically or internationally. It is divided into grant types or subprograms designated by letters (84.425A - 84.425P). The subprograms are further grouped into two sections in the Supplement addendum. Section 1 comprises those governed by the ESF and Section 2 comprises those governed by the Higher Education Emergency Relief Fund (HEERF). For major program purposes, auditors must evaluate 84.425 in its entirety. Also, this program section notes that expenditures under 84.425 B and G are not subject to audit this year.|
|93.153, 93.461, 93.498, 93.914, 93.917, and 93.918||
NEW COVID-19 PROGRAMS INCLUDED
93.461 - Testing of the Uninsured - Provides claims reimbursements to health care providers for conducting testing and treatment for uninsured individuals with COVID-19.
93.498 - Provider Relief Fund - This very large new program provides relief funds to hospitals and other healthcare providers to support healthcare-related expenses or lost revenue attributable to COVID-19. An “Other Information” section in the PRF program section instructs that PRF expenditures and lost revenue will not be included on SEFAs until December 31, 2020, year-ends and later.
EXISTING PROGRAMS INCLUDED (Types of changes in these programs include adding an indication that the CARES Act added funding to the program, adding references to agency guidance, and/or identifying waivers relating to CARES Act funding.
93.153 - Coordinated Services and Access to Research for Women, Infants, Children, and Youth
93.914 - HIV Emergency Relief Project Grants
93.917 - HIV Care Formula Grants
93.918 - Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease
|14.862, Indian Community Development Block Grant||
This is an existing program. A new special test and provision is added titled: Special Provisions for Indian Community Development Block Grant-CARES Imminent Threat Grants.
|16.034, Coronavirus Emergency Supplemental Funding||This new COVID-19 program provides funding to assist eligible states, units of local government, and federally recognized tribal governments in preventing, preparing for, and responding to the coronavirus. Eligible recipients were those eligible for funding under the 2019 state and local Edward Byrne Memorial Justice Assistance Grant (JAG) program.|
|20.218/20.237, Federal Motor Carrier Safety Assistance Cluster||Transportation was given permission to add this cluster to the Supplement addendum even though the COVID-19 pandemic is not relevant to it. The objective of the cluster is to support a safe and efficient surface transportation system.|
FEDERAL COMMUNICATIONS COMMISSION
|32.006 - COVID-19 Telehealth Program||This new COVID-19 program was established to help healthcare entities provide telehealth services in response to the pandemic. It should be noted that the FCC has not previously had any programs in the Supplement.|
|21.019, Coronavirus Relief Fund||This very large new COVID-19 program was established to provide direct payments to state, territorial, tribal, and certain eligible local governments to cover necessary expenditures incurred due to the public health emergency with respect to COVID-19.|
|10.001, Multiple Program COVID-19 Waivers for Food and Nutrition Service Programs||This section provides specific guidance on waivers for the following Assistance Listings: 10.551, 10.553, 10.555, 10.557, 10.558, 10.559, and 10.572. It states that USDA expects instances when it is not possible for the auditor to perform certain audit steps due to COVID-19 and the subsequent closures and instructs that such instances should be documented by the auditors.|
|Student Financial Assistance Cluster||This section informs auditors that there may be requirements in the August 2020 Supplement that may have been waived or changed for certain institutions and that auditors should familiarize themselves with these changes and determine appropriate audit steps to test for compliance. It also points auditors to a comprehensive Web site of SFA-related COVID-19 issues developed by Education.|
|Appendix VII, Additional Audit Advisories||Adds three new advisories to this Appendix. The first provides a 3-month audit submission extension for single audits of 2020 year-ends through September 30, 2020, year-ends only if the recipient received COVID-19 funding. The second states that nonfederal entities that received donated PPE purchased with federal assistance funds should include the fair market value of the PPE at time of receipt in a stand-alone footnote to the SEFA that can be marked “unaudited.” The third discusses the status of agency guidance documents which are referred to in many of the agency program sections and explains how auditors should consider them.|