OMB issues 2020 Compliance Supplement


Authored by RSM US LLP

The Office of Management and Budget (OMB) recently released the 2020 Compliance Supplement, which is effective for audits of fiscal years beginning after June 30, 2019. The 2020 Compliance Supplement adds, deletes and modifies prior Supplement sections. Appendix V of the 2020 Compliance Supplement provides a list of changes from the 2019 Compliance Supplement.

Further, the 2020 Compliance Supplement continues the OMB mandate requiring each federal agency to limit the number of compliance requirements subject to the audit to six, with the exception of the Research and Development cluster, which has been permitted to identify seven compliance requirements as subject to the audit. For this purpose, the requirements relating to A., “Activities Allowed and Unallowed,” and B., “Allowable Costs and Cost Principles,” are treated as one requirement. The Part 2 matrix and the related program sections in Parts 4 and 5 reflect this OMB mandate. The six-requirement mandate does not apply to programs not included in the Supplement.

The OMB and federal awarding agencies are working to identify COVID-19 funding programs and the need for these programs to be added in an addendum to the Supplement. The soonest we expect this addendum to be published is in late September.