OMB Issues 2022 Compliance Supplement

The Office of Management and Budget (OMB) recently released the 2022 Compliance Supplement, which is effective for audits of fiscal years beginning after June 30, 2021. Appendix V of the 2022 Compliance Supplement provides a high-level overview of the detailed changes from the 2021 Compliance Supplement. Appendix IV, “Internal Reference Tables,” has been updated to include a complete list of programs with the higher risk designation.

The types of compliance requirements that apply for each federal program remains at six (with its related rules and exceptions) for 2022. The 2022 Compliance Supplement makes several program additions and deletions, as well as other changes to some programs, including:

• Adding the Shuttered Venue Operators Grant as a new program section, notwithstanding the fact that this has been in existence for well over a year. It also was noted that, when developing the audit approach in a single audit subject to the 2021 Compliance Supplement, this new program section may be used as a resource; however, this is not mandatory.
• Continuing to identify the Education Stabilization Fund (ESF) as a higher risk program, adding three subprograms to the ESF section, and making regulatory changes and other updates throughout the ESF section.
• Revising the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) section for the CSLFRF Final Rule, as well as introducing an alternative compliance examination engagement for certain recipients.
• Revising the title of the Provider Relief Fund to include the American Rescue Plan (ARP) Rural Distribution, as well as adding information and requirements for funding provided to this program from the ARP Act.
• Updating various programs for COVID-19 funding and to reflect provisions from the ARP Act.

In addition, several changes and clarifications have been made to the “Student Financial Assistance Cluster” and “Other Clusters” sections of Part 5.

Lastly, as communicated in Appendix VII, “Other Audit Advisories,” the Federal Audit Clearinghouse (FAC) is transitioning from Census to the General Services Administration (GSA). The FAC will continue to accept fiscal year 2021 single audit submissions, and the GSA will begin accepting fiscal year 2022 submissions on October 1, 2022. Guidance is provided for how the single audit submission deadline is to be addressed for fiscal year 2022 audits that are completed prior to the new GSA portal being available.

With regard to future addendums, there will not be an Addendum to the 2022 Supplement – any new programs that are established as a result of the Infrastructure Investment and Jobs Act will be included in the 2023 Supplement.