As many organizations discuss audit planning with their auditors for fiscal years ending June 30, 2024, the Office of Management and Budget has released the 2024 Compliance Supplement (Supplement) effective for fiscal years beginning after June 30, 2023.
As stated in Part 1 of the Supplement, “The Supplement is a document that identifies existing compliance requirements that the federal government expects to be considered as part of an audit required by the 1996 Amendments to the Single Audit Act.”
Currently, any organization that expends more than $750,000 of federal financial assistance is subject to a single audit. In April 2024, this threshold was increased to $1,000,000 for fiscal years beginning on or after October 1, 2024. Organizations with fiscal years ending June 30, 2024 and 2025 are still subject to a single audit if they have more than $750,000 of federal financial assistance but will see relief in the single audits for fiscal years ending June 30, 2026 and beyond if they expend less than $1,000,000. Calendar year organizations will see relief for years ending December 31, 2025.
Organizations and auditors annually await the release of the Supplement to review for major changes. This year’s version includes a number of modifications, ranging from newly added or the removal of programs, compliance requirements subject to audit changing and changes within the “higher risk” designation. Part 2 of the Supplement contains the matrix of compliance requirements. This chart shows the new programs added or deleted in the 2024 version. Part 2 also lists the Assistance Listing Numbers of programs and which compliance requirements are subject to audit. Federal agencies select the compliance requirements subject to audit that must be tested by auditors for direct and material items related to the program(s) under audit.
For 2024, the Supplement removed the following programs from higher risk designation:
- 21.026 – Homeowner Assistance Fund
- 21.029 – Capital Projects Fund
- 84.425 – Education Stabilization Fund
- 93.498 – Provider Relief Fund
- 96.001/96.006 – Disability Insurance/Supplemental Security Income Cluster
Many federal programs established during the COVID-19 pandemic were designated as higher risk. The Infrastructure Investment and Jobs Act also created additional programs, with some also labeled as higher risk.
Programs with higher risk designations in the 2024 version include the following:
- 15.252 – Abandoned Mine Land Grants
- 21.023 – Emergency Rental Assistance
- 21.027 – Coronavirus State and Local Fiscal Recovery Funds
- 93.778/93.777/93.775 – Medicaid Cluster
One more reminder: the Federal Audit Clearinghouse has completed the transition from Census Bureau to General Services Administration. There are no current waivers, so organizations must complete their single audit submissions on time, which is the sooner of nine months after year-end or 30 calendar days after the organization receives the auditor’s report. The date the auditors signed the report is considered the date received.
Schneider Downs will continue to provide updates regarding federal funding as new information is discovered.
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