Time to Skim the 2018 Single Audit Compliance Supplement

There are some things that we each find to be like the homework assignments we use to hate. For me, it’s the annual Single Audit Compliance Supplement. When it came out earlier this month, I successfully managed to finish my part for a couple of Private Group training products, watch more hockey than I ever had before (Go CAPS!), consume a beach worthy novel, and make a complex breakfast for my husband’s birthday. So, thank you Office of Management and Budget (OMB) for the burst of productivity and family time. Without a book to read on our way home from the beach Monday, I settled to read the 2018 Compliance Supplement front matter and a skim through the rest.

Here are my top takeaways:

• Procurement. OMB discusses procurement issues in several places, especially with regards to the most recent National Defense Authorization Act’s changes to the micro-purchase and Simplified Acquisition Threshold (SAT) levels that will take effect in 2018 (likely July). There are also instructions to auditors to be mindful of any grantees affected by the 2017 Hurricane Season. Even more interesting, this is the only section from 3.1 that was significantly updated. Consider it a reminder for all non-Federal entities to double check that they have:
  • 2 CFR 200 compliant procurement policies in place
  • re-read the Suspension and Debarment requirements
  • prepared to adjust micro-purchase and SAT when you can and if appropriate.
• Internal Controls. The directions are to use the 2017 Compliance Supplement. All in the grants community should say an internal, “hooray,” as this was a big change last year.
• Administration. Bookmark this site: https://www.whitehouse.gov/wp-content/uploads/2018/05/2018-Compliance-Supplement.pdf. OMB published the supplement on the Office of Federal Financial Management (OFFM) page – not the Circulars page.

Make sure you review the changes and eliminations to the programs with special instructions, including those programs that are to be clustered. And finally, think about if you’re one of those people who needs to have a document like this in one source. I know some of you out there are wondering and might prefer if OMB had just swapped pages with last year’s and republished it in it’s in entirety. I’m guessing few pages to process helped speed the clearance time.

Since I was a captive audience, I continued skimming through the program specific guidance. Not every agency included changes in this supplement. This makes sense as we anticipate release of the 2019 Compliance Supplement in early 2019, and many policies, regulations, and authorizing statutes have been stable during the past two years. That said, the number of programs included in the Department of Education (ED) section is striking – and reflective of the many policy changes that have been implemented since Secretary DeVos took over. Sometimes the changes are subtle. But they are there. Read carefully, especially if you have responsibility for performance and/or ED specific program reporting.

I know it’s a beast, and easy to avoid, but if you’re working with Federal grants, make sure you do your annual homework and at least skim the Compliance Supplement. It’s easier to prepare for an audit if you know what auditors are looking for.

And maybe, just maybe, you’ll manage your grants better, too.