2022 Compliance Supplement Release

Not-for-profit entities are subject to a federal single audit if they expend $750,000 of federal financial assistance or more in their fiscal year. Federal funding created because of the COVID-19 pandemic has pushed many organizations over this threshold. As a result, not-for-profit organizations receiving support in the form of grants or other assistance may now find themselves with new reporting requirements.

The Compliance Supplement is an extensive federal government guide created by the Office of Management and Budget (OMB) and is used by auditors and auditees (grant recipients) alike in the preliminary preparation and auditing of federal assistance and grant programs. The Compliance Supplement was created to ensure that recipients of federal awards understand and comply with program requirements.

The 2022 OMB Compliance Supplement was released on May 11, 2022 and is effective for audits of fiscal years beginning after June 30, 2021. Unlike in previous years where additional addendums were subsequently released, the OMB has stated that there will not be any addendum for 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.

The full version of the 2022 OMB Compliance Supplement can be found here.

How to Use the Supplement

The OMB Compliance Supplement is divided into eight sections:

• Part I: Background, Purpose, and Applicability – This section outlines the general applicability and usage of the Compliance Supplement and related guidance.
• Part II: Matrix of Compliance Requirements – This section specifies the compliance requirement applicable to each program. The six-requirement mandate and its related rules and exceptions continue for 2022. In addition, new programs previously added in addendums one and two to the 2021 Compliance Supplement have been identified with one and two asterisks, respectively. We strongly recommend that each auditee review these requirements annually and put controls in place to ensure compliance with each program. These compliance requirements should be evaluated in conjunction with part IV and V of the supplement.
• Part III: Compliance Requirements – This section provides guidance and description for the types of compliance guidelines established by federal agencies, in addition to providing certain audit objectives and suggested audit procedures.
• Part IV: Agency Program Requirements – This section discusses how each compliance requirement applies to specific programs. There were several program additions and deletions, as well as many programs with significant changes. Additional new programs include the Emergency Rental Assistance Program, Coronavirus Capital Projects Fund, Family Violence Prevention and Services/Domestic Violence Shelter and Supportive Services, and the Shuttered Venue Operators Grant (SVOG). Please note that the new section for the SVOG program states that it is to be used for audits of non-federal entities with SVOG funding. However, for-profit entities who received and expended SVOG funds should be aware that the Small Business Administration (SBA) will soon be issuing separate audit requirements and guidance for this program as well.
• Part V: Clusters of Programs – This section discusses clusters of programs (i.e., grouping of closely related programs with similar compliance requirements) for Research and Development (R&D), Student Financial Aid (SFA), and other clusters. As there were several changes made to the SFA and “Other Clusters” listing this year, we strongly encourage entities to review the revisions.
• Part VI: Internal Control – This section discusses the objectives, principles, and components of internal controls based on the “Standards for Internal Control in the Federal Government,” and the “Internal Control Integrated Framework.” This section can be a very helpful tool for organizations to prepare for an upcoming audit, and to review and consider whether they have established effective controls. As auditors will be testing internal controls that relate to major program compliance, a proactive review of this section can help organizations avoid potential non-compliance issues. Illustrative examples and guidance are also provided in this section.
• Part VII: Guidance for Auditing Programs Not Included in This Compliance Supplement – This section provides overall guidance based on governmental procurement and cost principles for those programs not specifically covered in a compliance supplement.
• Part VIII: Appendices – This section includes various other information and considerations such as a summary listing changes to the prior year compliance supplement, COVID-19 awards, and program-specific audits guidance.

How We Can Help

Citrin Cooperman’s Not-for-Profit Practice professionals can assist you in further understanding the changes and impact that the new 2022 Compliance Supplement may have to your organization. If you have any questions about how the 2022 Compliance Supplement may impact your organization, please contact John Eusanio at jeusanio@citrincooperman.com.