OMB Issues 2020 Compliance Supplement

Did you ever take an open book test in school? It always made doing well much easier. The 2020 Compliance Supplement is a textbook for your organization’s equivalent of a compliance exam (the single audit). Its primary purpose is to assist auditors in performing single audits, but it is also a resource to help your organization comply with the requirements of your federal direct and pass-through grants and contracts.

On Aug. 18, 2020, the Office of Management and Budget (OMB) issued the 2020 Compliance Supplement (Supplement). The Supplement is effective for single audits of fiscal years beginning after June 30, 2019 – so June 30, 2020 fiscal year-ends.

The Supplement provides the information needed by auditors to perform the single audits and is updated annually for new programs and changes to existing programs. This document is extremely helpful to recipients of federal awards because in Part 2, known as the “Matrix,” the Supplement outlines the compliance requirements applicable to federal programs that are included in the Supplement. Additionally, the Supplement also provides information to assist an organization in identifying the compliance requirements that it must adhere to for those programs that are not specifically listed in the Supplement (see Part 7).

As all organizations have experienced, everything is changing because of COVID-19. The 2020 Supplement currently only provides a discussion of the general implications of the COVID-19 pandemic to single audits. The Supplement does not include the new COVID-19 related programs or information on modified compliance requirements that are unique to COVID-19 for existing programs. OMB is working with federal agencies to identify additional guidance that is needed for new COVID-19 related programs and existing programs where compliance requirements have changed due to COVID-19. OMB plans to publish an addendum to this Supplement in the fall of 2020.