Appendix V

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 Costs/Cost Principles."

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:

Page No.

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 Senior Centers
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 Assistance (CFDA).

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 Federal Awards.

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 FSEOG program.

Student Financial Assistance Cluster - Added information on the frequency of reporting to III.L.1.f.

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 programs.

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 Requirements

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, §___.525(c)(2).

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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