The Office of Management and Budget (OMB) issued the 2024 Compliance Supplement – 2 CFR Part 200, Appendix XI (2024 Supplement) for single audit engagements. The 2024 Supplement identifies the compliance requirements for auditors to consider when performing single audits under the OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Entities subject to single audits can refer to the 2024 Supplement to familiarize themselves with the types of compliance testing that auditors may perform and reporting submission deadlines. This Snapshot highlights key changes made from the 2023 Compliance Supplement.
Effective date:
The 2024 Supplement is effective for audits of fiscal years beginning after June 30, 2023. It supersedes the 2023 Compliance Supplement (dated May 2023).
The OMB posted the 2024 Supplement by section on whitehouse.gov.
Key 2024 Supplement changes
The 2024 Supplement provides essential guidance for auditors that perform single audits as well as potential insights for auditees. The following list summarizes areas of the 2024 Supplement with key changes:
- Appendix IV, “Higher Risk Designation” (previously titled “Internal Reference Tables”), identifies programs that are designated as “higher risk” and includes guidance on how the “higher risk” designation impacts the major program determination process.
- Appendix V, “List of Changes for the 2024 Compliance Supplement,” identifies changes that could affect single audit engagements. These changes apply across many of the programs in the 2024 Supplement that affect the scope of the single audit.
- Appendix VII, “Other Audit Advisories,” provides information on the latest OMB announcements that may impact 2024 single audits, including
- The continuation of the requirement for recipients of federal awards to separately identify COVID 19-related expenditures from non-COVID 19 expenditures on the Schedule of Expenditures of Federal Awards (SEFA)
- Guidance on determining whether an auditee’s prior-year Data Collection Form was submitted to the Federal Audit 2 Clearinghouse on time for purposes of meeting the low-risk auditee criteria in the current year.
- A new section on the 2024 revisions to the OMB’s Guidance for Federal Financial Assistance, which are effective Oct. 1; federal agencies may elect to implement these revisions for new awards and amendments made to existing awards as early as June 21
- The Student Financial Assistance cluster revises several compliance requirements, including revising several requirements in Special Tests and Provisions.
- Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution (collectively referred to as PRF) adds clarifications on (a) how and when to report PRF expenditures and lost revenue on the SEFA for fiscal year-ends on or after June 30, 2024, and (b) the timing of when expenditures and lost revenue are to be reported in the PRF portal for Period 7.
- Coronavirus State and Local Fiscal Recovery Funds (SLFRF) updates the definition of “obligation,” adds three new program objectives, and continues to allow the alternative for certain recipients to elect a compliance examination in accordance with Government Auditing Standards in lieu of a full single audit or program-specific audit.
Other reminders
The terminology change from “Catalog of Federal Domestic Assistance” (CFDA) to “Assistance Listing” (AL) announced in the 2021 Compliance Supplement continues in the 2024 Supplement. The reference to AL is also reflected on the SEFA and the Data Collection Form. The AL is located at www.sam.gov.
Contacts:
Dennis J. Morrone
National Managing Partner, Not-for-Profit & Higher Education Practices
Partner, Audit Services, Grant Thornton LLP
Principal, Grant Thornton Advisors LLC
Dennis Morrone is the National Managing Partner of Grant Thornton's Not-for-Profit & Higher Education Practices.
Iselin, New Jersey
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Angelica Roiz
Partner, Audit Services, Grant Thornton LLP
Principal, Grant Thornton Advisors LLC
Angelica is an audit partner in Grant Thornton’s Not-for-Profit practice with over 15 years of experience. Angelica has specific experience managing the audits of large, complex clients including museums and membership organizations, institutions of higher education, religious organizations, private foundations, and social services organizations including those subjects to Uniform Guidance audit requirements.
Philadelphia, Pennsylvania
Industries
- Not-for-profit & higher education
Service Experience
- Audit & Assurance
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