Not-For-Profit Alert: 2019 Compliance Supplement Release

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 alike for federal assistance and grant programs. The 2019 OMB Compliance Supplement was released on July 1, 2019 and is effective for audits of fiscal years beginning after June 30, 2018.

Unlike the 2018 OMB compliance supplement, dubbed as the “skinny” supplement, which only provided for any significant updates and changes from the 2017 OMB compliance supplement, the 2019 compliance supplement is a complete version and a stand-alone document.

The 2019 OMB compliance supplement may be accessed at the following location: https://www.whitehouse.gov/wp-content/uploads/2019/07/2-CFR_Part-200_Appendix-XI_Compliance-Supplement_2019_FINAL_07.01.19.pdf

Key Changes

Appendix V of the 2019 Compliance Supplement provides a list of all changes from the 2017 and 2018 Supplements. The following is a brief synopsis of the significant changes noted:

• Programs – Several programs were added and removed for 2019, and in general many other programs experienced significant updates. In particular, entities that administer Student Financial Assistance will see additional changes regarding securing student information (Gramm-Leach-Bliley Act), among other requirements. 
  
  
• Compliance Requirements – OMB required agencies to limit the compliance requirements subject to the compliance audit from a potential Twelve to Six, for each program or cluster included in the 2019 Supplement. The only exception is the Research and Development cluster, which was permitted to identify Seven requirements. As a result, Part Two of the Compliance Supplement has been significantly revised and should be carefully read.
  
  
• Procurement – updated to discuss the effect of the 2017 and 2018 National Defense Authorization Acts (NDAA) and OMB Memorandum M-18-18, Implementing Statutory Changes to the Micro-Purchase and Simplified Acquisition Thresholds for Financial Assistance, on the simplified acquisition and micro-purchase thresholds.
  
  
• Internal Control – extensive updates and changes with revised discussion on internal controls over compliance and illustrative examples.
  
  

How We Can Help

Citrin Cooperman’s Not-for-Profit Practice professionals can assist you in further understanding the changes and impact the new 2019 Compliance Supplement may have to your organization.