United States

Draft 2017 OMB Compliance Supplement available for audit planning


Because the clearance process is taking longer than expected, the Office of Management and Budget (OMB) recently provided the AICPA Governmental Audit Quality Center a draft of the 2017 OMB Compliance Supplement. Although the Supplement has been vetted by various federal agencies and stakeholders, the OMB has asked that the Supplement only be used for single audit planning purposes as it could change during the final clearance process.

This Supplement is a necessary reference source for single audits performed for periods beginning after June 30, 2016. A comprehensive list of changes to the 2017 Compliance Supplement from the 2016 Compliance Supplement can be found in Appendix V of the 2017 Compliance Supplement. The Supplement should be reviewed in its entirety to gain a full understanding of its contents. Below is a summary of some of the changes:

  • Part 3.2 was revised to recognize the extension of the procurement grace period as described in our article, Uniform Guidance: Procurement grace period extension.
  • Part 4 added, deleted and updated programs due to regulatory or other changes.
  • Part 5 made regulatory and other updates to the Student Financial Assistance (SFA) cluster, including removing the applicability of the Period of Performance compliance requirement to the Department of Education programs included in the cluster. Also, the listing of "Other Clusters" has been updated to remove a cluster, change program names, add a new program to an existing cluster and add a new cluster.
  • Appendix VII, “Other Audit Advisories,” includes the following changes, among others:
    • Guidance was inserted regarding the effect of adding a program to an "other cluster" as it relates to evaluating the two-year look-back criterion during the major program determination process. This new guidance does not apply to apply to the SFA and Research and Development clusters.
    • The Appendix removed the description of agency exceptions to the Uniform Guidance and instructs auditors that for programs included in the 2017 Supplement, they should review the program supplement and, as necessary, agency regulations for adopting/implementing the OMB Uniform Guidance to determine whether there is any exception related to the compliance requirements that apply to the program.