By Elissa Posway, CPA, Shareholder

The U.S. Office of Management and Budget (OMB) released the 2022 OMB Compliance Supplement (Supplement) in May 2022, which will impact federal single audits beginning with fiscal years ending June 30, 2022.

Doeren Mayhew’s dedicated Governmental and Non-Profit Group provide an overview of key changes organizations should be aware of when getting ready for their single audits.

  • Part 2, Matrix of Compliance Requirements. Applicable requirements for several programs have been modified this year and those changes are highlighted in yellow in the actual section. The six-requirement mandate and its related rules and exceptions will continue for 2022. Additionally, new programs previously added in Addendums 1 and 2 to the 2021 Supplement have been identified with one and two asterisks, respectively.
  • Programmatic Changes. Part 4 included several program additions and deletions as well as significant changes to many current programs. New program sections for 2022 include:
    • 21.023 – Emergency Rental Assistance Program (ERA)
    • 21.026 – Homeowner Assistance Fund Program
    • 21.029 – Coronavirus Capital Projects Fund
    • 32.009 – Emergency Connectivity Fund Program
    • 59.075 – Shuttered Venue Operators Grant (SVOG). Please note, the SVOG has been in existence for more than a year now, but this is the first year to be included in the Supplement. This new section states that it is to be used for audits of non-federal entities with SVOG funding. The Small Business Administration is expected to issue separate audit requirements and guidance for for-profit entities with SVOG funding.
    • 93.671 – Family Violence Prevention and Services/Domestic Violence Shelter and Supportive Services
  • Education Stabilization Fund (ESF). This fund has once again been identified as a higher-risk program. Regulatory changes, as well as other updates, have been made throughout this section, which include:
    • Adding the American Rescue Plan – Emergency Assistance to Non-Public Schools (ARP EANS) Program (84.425V) to Section 1.
    • Adding the Higher Education Emergency Relief Fund (HEERF) Supplemental Support Under American Rescue Plan (SSARP) Program (84.425T) to Section 2.
    • Moving the Institutional Resilience and Expanded Postsecondary Opportunity (HEERF IREPO) (84.425P) to Section 2, whereas it was included in the listing of programs not included in either sections 1 or 2 in the prior year.
    • Identifying the cash management type of compliance requirement as subject to audit in Section 2.
  • Coronavirus State and Local Fiscal Recovery Funds (CSLFRF). This program is identified as a higher-risk program and resulted in several small entities needing a single audit for the first time. To help with the administrative cost, for certain recipients, a compliance examination was created for this program as an alternative option to a full Single Audit or program-specific audit. This alternative is only available to certain eligible participants, so be sure to work with your dedicated auditor to identify the most suitable compliance option for your organization.
  • Provider Relief Fund (PRF). The program also continues to be identified as a higher-risk program, which provides relief funds to eligible providers of healthcare services and support for healthcare-related expenses or lost revenues related to Covid-19. It also adds information and requirements for funding provided to this program from the American Rescue Plan and removes the Special Tests and Provisions audit requirement that was in the 2021 Supplement.
  • Part 5, Student Financial Assistance Cluster. This program has several changes, clarifications and updates for 2022 to reflect regulatory changes and other updates. These changes relate primarily to various Special Tests and Provisions, such as disbursements to or on behalf of students, return of Title IV funds, enrollment reporting, program eligibility and distance education.

To learn more about how these changes impact your organization and audit requirements, contact our auditors within our dedicated Governmental and Non-Profit Group today.