List of Changes for the 1998 Compliance Supplement
This Appendix provides a list of changes from the OMB Circular A-133 Compliance Supplement
(Provisional) issued in June 1997 to this 1998 Supplement.
Part 1 - Background, Purpose, and Applicability
Added a sentence in the Background to explain that a new subsection, "IV. Other Information,"
will be used to convey additional information to auditors that does not fit in the program
objectives, program procedures, or compliance requirement subsections of the individual program
sections in Parts 4 or 5.
Updated for the effective date of this Supplement.
Added paragraph clarifying the "safe harbor" status of this Supplement.
Deleted references to the interim Education supplement. The programs in the Education
supplement have been added to Part 4 of this Supplement.
Added descriptions of the two new appendices: Appendix IV, "Internal Reference Tables," and
Appendix V, "List of Changes for the 1998 Compliance Supplement."
Added a new section titled "Technical Information" which includes the page numbering scheme
plus added guidance on the Code of Federal Regulations codification.
Updated section, "How to Obtain Additional Guidance," to reflect current information.
Part 2 - Matrix of Compliance Requirements
Revised introduction to clarify the auditor's use of the matrix of compliance requirements.
Updated for new programs and changes to existing programs.
Part 3 - Compliance Requirements
Introduction - Under "Compliance Requirements, Audit Objectives, and Suggested Audit
Procedures," added guidance that the description of the compliance requirements are summaries
of the actual requirements and the referenced citations provide a more complete description.
Deleted reference to cost principles circulars which are discussed in detail under "B. Allowable
A. Activities Allowed or Unallowed - Moved suggested audit procedure "2. Allowable Activities
for Subrecipients" to "M. Subrecipient Monitoring." Made conforming changes to programs in
parts 4 and 5.
B. Allowable Costs/Cost Principles - Expanded references to the Cost Accounting Standards
Board (CASB) Standards. Added to applicability, audit objectives, and suggested audit
procedures that by contract some non-profit organizations may by subject to the CASB Standards
and Disclosure Statement (DS-1) requirements. Added "adjustments for checks not cashed" to
the list of examples of applicable credits in suggested audit procedure 1.k. Also, added a
procedure to verify that the costs included in the base are consistent with the costs that were
included in the base year in suggested audit procedure 5.c.
C. Cash Management - Clarified that programs not covered by Cash Management Improvement
Act agreements are covered by the Treasury default procedures.
D. Davis-Bacon Act - Added information on obtaining wage determinations through the Internet.
E. Eligibility - Revised the first audit objective and related suggested audit procedures for
eligibility of individuals to include testing of eligibility determination process.
G. Matching, Level of Effort, Earmarking - Clarified that matching may be in the form of "third
party" in-kind contributions. Added language to clarify that earmarking also includes
requirements specifying minimum or maximum limits on types of participants being served.
Added suggested audit procedures to tests such limits.
I. Procurement and Suspension and Debarment - Revised the first audit objective and related
suggested audit procedures to clarify that procurement requirements specific to an award are
within the scope of testing. Corrected initial statement under suggested audit procedures to read
"(Procedures 1 - 4 . . ."
L. Reporting - Added section titled Reporting Under the Payment Management System to
describe how the SF-272 report is developed for recipients using the Department of Health and
Human Services (HHS) Payment Management System (PMS). Added suggested audit procedure
3.a.(3) pertaining to discrepancies noted in amounts reported by HHS PMS. Added "interest
earned on Federal funds" to the list of examples in suggested audit procedures 4.a.
M. Subrecipient Monitoring - Added allowable activities for subrecipients and related audit
objective which were moved from "A. Activities Allowed or Unallowed."
Part 4 - Agency Program Requirements
Introduction - Added explanation of new subsection, "IV. Other Information." Clarified that
when a compliance requirement is designated "not applicable," it means either that there are no
compliance requirements or the auditor is not required to test compliance. Provided guidance
that the description of the compliance requirements are summaries of the actual requirements and
the referenced citations provide a more complete description.
Added the following new programs:
United States Department of Agriculture (USDA)
10.553 - School Breakfast Program
10.555 - National School Lunch Program
10.556 - Special Milk Program for Children
10.558 - Child and Adult Care Food Program
10.559 - Summer Food Service Program for Children
10.566 - Nutrition Assistance for Puerto Rico
10.568 - Emergency Food Assistance Program (Administrative Costs)
10.569 - Emergency Food Assistance Program (Food Commodities)
10.570 - Nutrition Program for the Elderly (Commodities)
Department of the Interior (DOI)
15.605 - Sport Fish Restoration
15.611 - Wildlife Restoration
Department of Labor (DOL)
17.207 - Employment Service
17.235 - Senior Community Service Employment Program
17.245 - Trade Adjustment Assistance--Workers
17.246 - Employment and Training Assistance--Dislocated Workers
17.247 - Migrant and Seasonal Farmworkers
17.250 - Job Training Partnership Act
17.251 - Native American Employment and Training Programs
17.801 - Disabled Veterans' Outreach Program (DVOP)
17.804 - Local Veterans' Employment Representative Program
Department of Transportation (DOT)
20.500 - Federal Transit Capital Improvement Grants
20.507 - Federal Transit Capital and Operating Assistance Formula Grants
20.600 - State and Community Highway Safety
20.601 - Alcohol Traffic Safety and Drunk Driving Prevention Incentive Grants
Environmental Protection Agency (EPA)
66.458 - Capitalization Grants for State Revolving Funds
Federal Emergency Management Agency (FEMA)
83.543 - Individual and Family Grants
83.544 - Public Assistance Grants
Department of Education (ED)
None - Cross-Cutting Section
84.002 - Adult Education--State Grant Program
84.010 - Title I Grants to Local Educational Agencies (LEAs)
84.011 - Migrant Education--Basic State Grant Program
84.027 - Special Education--Grants to States
84.041 - Impact Aid
84.126 - Rehabilitation Services--Vocational Rehabilitation Grants to States
84.173 - Special Education--Preschool Grants
84.186 - Safe and Drug-Free Schools and Communities--State Grants
None - School-to-Work Opportunities Act of 1994
84.281 - Eisenhower Professional Development State Grants
84.288 - Bilingual Education--Program Development and Implementation Grants
84.290 - Bilingual Education--Comprehensive School Grants
84.291 - Bilingual Education--Systemwide Improvement Grants
84.298 - Innovative Education Program Strategies
Department of Health and Human Services (HHS)
93.044 - Special Programs for the Aging--Title III, Part B--Grants for Supportive Services and
93.045 - Special Programs for the Aging--Title III, Part C--Nutrition Services
93.558 - Temporary Assistance for Needy Families
93.575 - Child Care and Development Block Grant (Only "IV. Other Information")
93.667 - Social Services Block Grant (Only "IV. Other Information")
93.914 - HIV Emergency Relief Project Grants
93.915 - HIV Emergency Relief Formula Grants
Corporation for National and Community Service (CNCS)
94.006 - AmeriCorps
94.011 - Foster Grandparent Program
94.016 - Senior Companion Program
Social Security Administration (SSA)
96.001 - Social Security--Disability Insurance
Revised program names where necessary to be consistent with the Catalog of Federal Domestic
CFDA 10.551 - Updated program procedures subsection and "G.1 Matching." Added
compliance requirements for "A. Activities Allowed and Unallowed."
CFDA 10.557 - Revised compliance requirements that were previously in "I. Procurement and
Suspension and Debarment" to reflect updated policy regarding equipment purchases. Moved the
revised requirements to "A. Activities Allowed or Unallowed," because they are requirements
concerning the allowability of certain purchases, not the procurement process. Revised "J.
Program Income" to reflect more precisely the requirement as stated in the regulation.
CFDA 14.182 - Added language to clarify that this Supplement is to be used for audits of Section
8 program participants other than Public and Indian Housing Authorities.
CFDA 14.218 - Deleted from "A. Activities Allowed or Unallowed" list of activities CDBG funds
are to be used for, item "(3) code enforcement in deteriorated or deteriorating areas;"
renumbered list; and added "in deteriorated or deteriorating areas" to item "(25) residential
rehabilitation." Added to "L.1 Financial Reporting" information on the change from the Grantee
Performance Report to the Consolidated Annual Performance and Evaluation Report." Deleted
reference to local codes from "Rehabilitation" of "N. Special Tests and Provisions."
CFDA 14.239 - Change to remove the requirement for the auditor to test for reporting.
CFDA 14.241 - Moved compliance requirement "Health Services" from "N. Special Tests and
Provisions" to "A. Activities Allowed or Unallowed."
CFDA 14.862 - Added guidance for "F. Equipment and Real Property Management," and "I.
Procurement." Corrected errors in "L. Reporting" regarding the SF-269 and SF-272.
CFDA 17.225 - Added to "L. Reporting" requirement to test special report titled Quarterly UI
Contingency Report. Revised "Match with IRS 940 FUTA Tax Form" under "N. Special Tests
and Provisions." Added "IV. Other Information" to describe treatment of Federal and State
portions for Type A program determination and reporting in the Schedule of Expenditures of
CFDA 20.205 - Corrected two legal citations (III.A.5 and III.A.10).
CFDA 83.516 - Moved specific requirements to new CFDA 83.543 and 83.544 as a result of the
program being split into two programs in the CFDA. Added "G. Earmarking" and "L. Financial
Reporting" requirements to Individual and Family Grants (CFDA 83.543).
CFDA 84.010 - Revised to be compatible with the new ED Cross-Cutting Section.
CFDA 93.778 - Updated web site for HHS Inspector General Fraud Alerts.
Part 5 - Clusters of Programs
Introduction - Added paragraph which describes auditor's use of Parts 2, 3, and 5 in auditing a
program and provided guidance that the description of the compliance requirements are
summaries of the actual requirements and the referenced citations provide a more complete
description, to be consistent with Part 4.
Student Financial Assistance Cluster - Corrected citation in program procedures subsection for
Student Financial Assistance Cluster - Added information on the frequency of reporting to
Student Financial Assistance Cluster - Provided more generic description of key items in the
FISAP in III.L.3, to avoid having to revise the Supplement every time the form changes. This is
not a change in the identified key items. It is only a change in how they are described.
Student Financial Assistance Cluster - Updated section, "IV. Other Information," to reflect
issuance of new guidance for claiming Pell adjustments.
Updated list of clusters to include programs now included in this Supplement.
Removed Child and Adult Care Food Program (CFDA 10.558) from the Nutrition Cluster and
renamed the cluster as the Child Nutrition Cluster. Both the Child and Adult Food Program and
the Child Nutrition Cluster (CFDA 10.553, 10.555, 10.556, and 10.559) are included as new
Part 6 - Internal Control - No substantive changes.
Part 7 - Guidance for Auditing Programs Not Included in This Compliance Supplement
Revisions to conform this Part to changes made elsewhere in this Supplement.
Updated discussion of Step "e" of Question 1, "What are the program objectives, program
procedures, and compliance requirements for a specific program," to remove reference to the
1990 and 1991 compliance supplements.
Appendix I - Federal Programs Excluded From the A-102 Common Rule - No changes.
Appendix II - Federal Agency Codification of Certain Governmentwide Grant
Updated DOD and NASA to reflect codification of OMB Circular A-110.
Appendix III - Federal Agency Contacts for A-133 Audits
Updated this list of contacts.
Appendix IV - Internal Reference Tables
Added this Appendix to provides a listing of programs in Parts 4 or 5 which include "IV. Other
Information" or were identified as higher risk by OMB pursuant to Circular A-133,
Appendix V - List of Changes for the 1998 Compliance Supplement
Added this Appendix to provide a list of changes from the OMB Circular A-133 Compliance
Supplement (Provisional) issued in June 1997 to this 1998 Supplement.
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