Tax & AccountingMay 30, 2024

OMB issues 2024 Compliance Supplement

By: CCH ARM Editorial

The United States Office of Management and Budget (OMB) issued the 2024 Compliance Supplement on May 29. It assists auditors of both nonprofit and for-profit entities comply with grant, contract, and federal requirements. The 2024 Compliance Supplement, like previous annual Compliance Supplements, identifies significant 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 (Single Audit). As with prior Compliance Supplements, it adds, deletes, and modifies prior Compliance Supplement sections.

In addition, the 2024 Compliance Supplement follows the OMB mandate adopted in the 2019 Compliance Supplement that requires 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 and the Child Care Disaster Fund Cluster, which may identify seven 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 the OMB’s six-requirement mandate. The six-requirement mandate does not apply to programs not included in the annual Compliance Supplement.

Key changes from 2023 Compliance Supplement

Appendix V provides a list of changes from the 2023 Compliance Supplement. However, changes in the Matrix of Compliance Requirements are reflected in Part 2 of the 2024 Compliance Supplement.

Updates include:

  • An increase in the Single Audit threshold for non-federal entities from $750,000 to $1,000,000 in federal awards expended within a fiscal year, for fiscal years beginning on or after October 1, 2024. This is the first increase in the Single Audit threshold since 2013. 
  • Only four programs are considered “higher risk” in the 2024 Supplement (down from nine in 2023): Medicaid Cluster, Emergency Rental Assistance, Coronavirus State and Local Fiscal Recovery Funds, and Abandoned Mine Land Reclamation.

Effective date

The 2024 Supplement is effective for audits of fiscal years beginning after June 30, 2023, and supersedes the 2023 Compliance Supplement dated May 19, 2023.

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