Sneak Preview: OMB Publishes Addendum to 2020 Compliance Supplement

Jerry Ashworth
December 30, 2020 at 08:24:21 ET
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(The following was excerpted from a recent Thompson Grants 360 article.) The Office of Management and Budget (OMB) recently issued an addendum to the 2020 Compliance Supplement that contains guidance for auditor testing of major programs under awards provided in response to the COVID-19 pandemic. It also includes a few other program updates since the August 2020 release of the Compliance Supplement.

The 2020 Compliance Supplement did not fully address COVID-19 implications other than in an initial discussion in Appendix VII, due to the limited time between the COVID-19 appropriations and the issuance of the supplement.

Auditors now must use the addendum together with the 2020 Compliance Supplement when auditing programs of fiscal years beginning after June 30, 2019. COVID-19 awards addressed in the addendum were issued under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) (Pub. L. 116-136); Paycheck Protection Program Flexibility Act of 2020 (Pub. L. 116-142); Families First Coronavirus Response Act (Pub. L. 116-127); and the Coronavirus Preparedness and Response Supplemental Appropriations Act (Pub. L. 116-123).

The 118-page addendum provides audit guidance in Part 4 for the following COVID-19-funded programs based on their Catalog of Federal Domestic Assistance (CFDA) (also known as Assistance Listing) numbers:

  • New programs — Coronavirus Emergency Supplemental Funding (CFDA 16.034); Coronavirus Relief Fund (21.019); COVID-19 Telehealth Program (32.006); Education Stabilization Fund (ESF) Under the Coronavirus Aid, Relief, and Economic Security Act (84.425); Education Stabilization Fund Under the Coronavirus Aid, Relief, and Economic Security Act Higher Education Emergency Relief Fund (HEERF) (84.425); COVID-19 Testing for the Uninsured (93.461); and the Provider Relief Fund (93.498).
  • Existing programs receiving COVID-19 relief funding — Indian Community Development Block Grant Program (CFDA 14.862); Coordinated Services and Access to Research for Women, Infants, Children, and Youth (Ryan White HIV/AIDS Program Part D Women, Infants, Children, and Youth (WICY) Program) (93.153); HIV Emergency Relief Project Grants (Ryan White HIV/AIDS Program Part A) (93.914); HIV Care Formula Grants (Ryan White HIV/AIDS Program Part B) (93.917); and Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease (Ryan White HIV/AIDS Program Part C) (93.918).

A special matrix listing the compliance requirements for each of these programs is included in Part 2 of the addendum.

The addendum, under a new CFDA 10.001, provides guidance for several U.S. Department of Agriculture programs impacted by COVID waivers including the Supplemental Nutrition Assistance Program; School Breakfast Program; National School Lunch Program; Special Supplemental Nutrition Program for Women, Infants, and Children; Child and Adult Care Food Program; Summer Food Service Program; and the Farmer’s Market Nutrition Program. It also includes information under a newly added non-COVID-related cluster — the FMCSA cluster, which includes the new Motor Carrier Safety Assistance Program (20.218) and the High Priority Grant Program (20.237). It further notes that any information in the 2020 Compliance Supplement referring to CFDA 20.000 should have been deleted and disregarded.

(The full version of this story has now been made available to all for a limited time here.)

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