FAC Provides Clarity on Question Regarding 2019 Compliance Supplement Versions

Jerry Ashworth
November 12, 2019 at 11:19:35 ET
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During this time of the year, our cars are becoming more subject to frost on the outside of the windshield, and a stubborn layer of condensation on the inside of windshield. Thanks to the use of the vehicle’s defogger (or defroster, as some would call it), we’re able to get the needed clarity to clear off the glass so that we can get where we need to go. Recently, we learned about an email (thanks to our friends at the American Institute of Certified Public Accountants’ (AICPA) Governmental Audit Quality Center (GAQC)) that the Federal Audit Clearinghouse (FAC) sent to auditors and auditees providing some needed clarity as to how auditors should respond to multiple versions of the Office of Management and Budget's (OMB) 2019 Compliance Supplement.

As background, OMB originally made the 2019 supplement available in early July (dated June 2019). AICPA, among others, sent comments to OMB discussing numerous errors in the supplement that the organization believed could create auditor confusion when conducting engagements, as well as other quality control issues. In response, OMB issued a revised version of the 2019 Compliance Supplement, dated August 2019, which corrects several sections of the earlier document. The revised version particularly includes a four-page “Errata Page” chart after the Table of Contents that lists (1) the particular part within the supplement that was revised, (2) the issue that needed amending and (3) the specific correction.

However, this created some confusion for auditors that had already begun conducting audits using the original version, which applies to audits of fiscal years beginning after June 30, 2018. To answer this, the FAC email instructed auditors to take the following approach:

  • Auditors would be permitted to perform the audit using either the June 2019 or August 2019 edition of the supplement if they submitted their audit reports on or before Oct. 31, 2019.
  • Auditors are now required to perform the audit using the August 2019 edition for reports dated after Oct. 31, 2019.
  • A request is made for auditors to document the version of the supplement used for the audit.

Of note, the GAQC advised auditors that have not yet performed their single audits to make sure that they are using the August 2019 version when conducting their audits. Because there were two versions, a simple online search of the 2019 Compliance Supplement may bring up the June 2019 version. To be sure they are using the correct version, auditors can link to the August version here. Hopefully, we cleared that up!

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