of Changes for the 1999 Compliance Supplement
provides a list of changes from the OMB Circular A-133 Compliance
Supplement issued in May 1998 to this 1999 Supplement.
Part 1 - Background,
Purpose, and Applicability
for the effective date of this Supplement.
reference to the 1990 and 1991 compliance supplements which had
been previously superseded.
reference to separate Department of Housing and Urban Development
(HUD) Supplement for Housing Authorities. The programs in the
HUD supplement have been either added to this Supplement or are
covered by Part 7, "Guidance for Auditing Programs Not Included
in this Supplement."
- Added description
of a new appendix titled "Advisory to Federal Grantees on Responsibility
to Address the Year 2000 Issue - Appendix VI."
section, "How to Obtain Additional Guidance," to reflect current
Part 2 - Matrix
of Compliance Requirements
for new programs and changes to existing programs.
Part 3 - Compliance
- B. Allowable
Costs/Cost Principles - Added in the compliance requirements,
audit objectives, and suggested audit procedures provisions for
testing large research facilities construction costs consistent
with revisions to OMB Circular A-21. Under suggested audit procedures
added advice concerning the auditor consulting with the auditee
on the most efficient alternative to audit indirect cost rate
proposals. Under "Comparison Among OMB Cost Principles Circulars"
added changes to Exhibits 1 and 2 - to reflect revision to OMB
- C. Cash
Management - Amended description of funding methods to recognize
that the Treasury-State Agreement may provide for funds to be
requested more than 3 days in advance. Added Internet reference
to the U.S. Treasury, Financial Management Service's Cash Management
Improvement Act home page. Added suggested audit procedures covering
States' determination of large programs covered by the Treasury-State
Agreement and determination of clearance patterns. Added suggested
audit procedure to test that program income was disbursed before
additional Federal funds were requested. Revised the grouping
of the suggested audit procedures to: States; States and Other
Recipients; and Other Recipients and Subrecipients.
- D. Davis-Bacon
Act - Added Internet reference to the U.S. Department of Labor,
Employment Standards Administration's Davis-Bacon Act home page.
- J. Program
Income - Added additional paragraph references to A-102 Common
Rule and OMB Circular A-110.
- L. Reporting
- Revised the address of OMB's Internet home page. Deleted reference
to OMB's FAX information line which is no longer available.
- M. Subrecipient
Monitoring - Added to suggested audit procedures examples of award
information (e.g., CFDA title and number, award name, name of
- N. Special
Tests and Provisions - Added clarification concerning the auditor's
responsibility to test for compliance with the Year 2000 problem
in computer systems.
Part 4 - Agency
- Added the
following new programs:
Agency for International Development (USAID)
None - Foreign Food Aid Donation Program
States Department of Agriculture (USDA)
None - Food for Progress Program
None - Section 416(b) Program
10.760 - Water and Waste Disposal Systems for Rural Communities
10.766 - Community Facilities Loans and Grants
of Defense (DOD)
12.401 - National Guard Military Operations and Maintenance
of Housing and Urban Development (HUD)
14.157 - Supportive Housing for the Elderly (Section 202)
14.195 - Section 8 Housing Assistance Payments Program--Special
14.850 - Public and Indian Housing
14.852 - Public Housing--Comprehensive Improvement Assistance
14.859 - Public Housing Comprehensive Grant Program
of the Interior (DOI)
15.000 - BIA Cross-Cutting Section
15.021 - Consolidated Tribal Government Program
15.022 - Tribal Self-Governance
15.030 - Indian Law Enforcement
15.042 - Indian School Equalization Program
of Justice (DOJ)
16.579 - Byrne Formula Grant Program
of Labor (DOL)
17.253 - Welfare-to-Work Grants to States and Localities
Endowment for the Humanities (NEH)
45.129 - Promotion of the Humanities--Federal/State Partnership
Protection Agency (EPA)
66.468 - Capitalization Grants for Drinking Water State
of Education (ED)
84.042 - TRIO--Student Support Services
84.044 - TRIO--Talent Search
84.047 - TRIO--Upward Bound
84.048 - Vocational Education--Basic Grants to States
84.181 - Special Education--Grants for Infants and Families
of Health and Human Services (HHS)
93.563 - Child Support Enforcement--Title IV-D
93.568 - Low-Income Home Energy Assistance
93.569 - Community Services Block Grant
93.575 - Child Care and Development Block Grant
93.596 - Child Care Mandatory and Matching Funds of the Child
93.600 - Head Start
93.658 - Foster Care--Title IV-E
93.667 - Social Services Block Grant
93.959 - Block Grant for Prevention and Treatment of Substance
93.991 - Preventive Health and Health Services Block Grant
"IV. Other Information")
93.994 - Maternal and Child Health Services Block Grants
"IV. Other Information")
Security Administration (SSA)
96.006 - Supplemental Security Income (SSI)
- CFDA 10.551
and 10.561 - Under "II. Program Procedures" moved first paragraph
to end of section under new heading "Source of Governing Requirements."
Updated description of program for Electronic Benefit Transfer
(EBT) related information. Clarified Federal offices oversight
responsibilities. Updated Food Stamp error rates. Updated "G.1
Matching" to describe reduction in Federal share due to TANF recoveries.
Clarified that private in-kind contributions are not countable
toward the matching. Added language to "I. Procurement" to clarify
that contracts for EBT systems require FNS review regardless of
cost. Clarified in "L. Reporting" that the FNS-46 must separately
identify benefit amounts issued under each type of issuance system
operated. Clarified that line 15 in the FNS 209 represents all
payments in coupons or EBT. Under "N.1 ADP Systems" moved part
of the "Note" from under the caption to the first paragraph under
"Suggested Audit Procedures." Updated "N.2 EBT Reconciliation"
for changes in proces.
- CFDA 10.553,
10.555, 10.556, 10.559 - Under "II. Program Procedures," moved
first paragraph to end of section under new heading "Source of
Governing Requirements." Updated and clarified program procedures.
Added a new special test and provision, "N.3 School Food Accounts."
Deleted "IV. Other Information" which was transitional guidance
from the 1997 to the 1998 Compliance Supplements.
- CFDA 10.557
- Under "II. Program Procedures" moved first paragraph to end
of section under new heading "Source of Governing Requirements."
Updated and clarified program procedures. Updated "A. Activities
Allowed or Unallowed," "E. Eligibility," and "H. Period of Availability
of Funds" for revised requirements.
- CFDA 10.558
- Under "II. Program Procedures" moved first paragraph to end
of section under new heading "Source of Governing Requirements."
Updated "Program Procedures" to recognize after-school at risk
programs and other changes added by the William F. Goodling Child
Nutrition Reauthorization Act of 1998 (P.L. 105-336). Revised
compliance requirements to include requirements related to after-school
at risk programs in "A.1 Activities Allowed or Unallowed, Reimbursement
for Meals," "E.1 Eligibility for Individuals", and "E.3 Eligibility
for Subrecipients." Deleted "IV. Other Information" which was
transitional guidance from the 1997 to the 1998 Compliance Supplements.
- CFDA 10.568
and 10.569 - Under "I. Program Objectives" moved end of first
paragraph to end of "II. Program Procedures" under new heading
"Source of Governing Requirements." Clarified "II. Program Procedures."
Changed EFOs (Emergency Feeding Organizations) to ERAs (Eligible
Recipient Organizations). In "A. Activities Allowed or Unallowed,"
clarified that a State or ERA can use administrative funds for
certain activities related to distributing non-USDA food and corrected
a regulatory reference. Clarified in "E.3 Eligibility of Subrecipients"
that ERAs can enter into agreements with other ERAs. In "G.1 Matching"
deleted a reference to a requirement that the State's distribution
plan address how the matching requirement will be met. Revised
"L.1 Financial Reporting" to correct applicability of SF-270,
to correct the title of form FCS-667 and to delete a reference
to State-imposed reporting requirements. Deleted report in "L.3
Special Reporting" which is no longer applicable.
- CFDA 14.182,
14.855, 14.856, and 14.857 - Split the Section 8 Cluster into
two clusters, a Section 8 Project-Based cluster (CFDA 14.182,
14.195, and 14.856) and a Section 8 Tenant-Based cluster (14.855
and 14.857). A program previously included with no CFDA number,
Section 8 Moderate Rehabilitation Program for Single Room Occupancy
Dwellings for Homeless Individuals, was deleted from the cluster
and this Supplement. Substantial revisions were made to the Supplement
sections for these programs due to including guidance for audits
of Public and Indian Housing Authorities and the cluster change.
- CFDA 14.218
- Deleted reference to activities included on reports but not
action plans in "II. Program Procedures." Clarified item 6. in
"A. Activities Allowed or Unallowed" that action plans can be
amended. Added explanation of when income is not considered "program
income" in "J. Program Income." Revised "L.1 Financial Reporting"
for performance reporting under the new Integrated Disbursement
and Information System.
- CFDA 14.231
- Clarified in "N.1 Maintenance As Homeless Shelter" that the
3 year requirement applies to buildings used for rehabilitation
and renovation and that the 10 year requirement applies when the
federally funded rehabilitation or renovation was "major."
- CFDA 14.238
- Deleted two sections of Annual Progress Report that auditor
is no longer required to test in "L.1 Financial Reporting." Revised
suggested audit procedures for "N.1 Rent Reasonableness."
- CFDA 20.106
- Updated legal reference in "F. Equipment and Real Property Management."
Under "L.1 Financial Reporting" added two new reports. Revised
"N.1 Revenue Diversion" for new policies and procedures concerning
the generation and use of airport revenue. Added "IV. Other Information"
related to audit requirements under the Federal Aviation Reauthorization
Act of 1996.
- CFDA 20.205
- Revised "II. Program Procedures" to reflect changes in policies
and procedures. In "A. Activities Allowed or Unallowed," revised
original requirement 1 and deleted prior original requirements
3, 7, 8, and 10. Added "F. Equipment and Real Property Management."
In "G.1 Matching," added language to clarify that third-party
donations of services by local governments cannot count towards
the non-Federal share of the project. Added new paragraphs "G.1.d"
and "G.1.e." Deleted "G.3 Earmarking" requirement. Clarified the
allowable use of program income in "J. Program Income." Deleted
report in "L.1. Financial Reporting." Clarified compliance requirement
in "N.4 Project Extensions." Deleted suggested audit procedure
"c." in "N.5 Sample Program." Clarified compliance requirement
in "N.7 Project Approvals."
- CFDA 20.500
and 20.507 - Revised the compliance requirement in "F. Equipment
and Real Property Management."
- CFDA 66.458
- Changed referenced title of program to Clean Water State Revolving
Fund (CWSRF) and changed Part 2, "Matrix of Compliance Requirements"
to show "I. Procurement and Suspension and Debarment" and "K.
Real Property Acquisition and Relocation Assistance" as applicable.
Added discussion in "II. Program Procedures" on the allowability
of transferring funds to CFDA 66.468. Corrected CFR reference
in "H. Period of Availability of Funds." Revised compliance requirement
in "L.3 Special Reporting" to delete reference to binding commitments.
Added suggested audit procedure to "N.2 Binding Commitments."
Added "IV. Other Information" related to loans to subrecipients.
- CFDA 83.516
- Deleted this program which was removed from the CFDA effective
October 1, 1997. It was split into two separate CFDA numbers:
CFDA 83.543, Individual and Family Grants; and CFDA 83.544, Public
Assistance Grants, which are included in this Supplement.
- CFDA 84.000
- Revised for addition of 2 new programs, Vocational Education
- State Basic Grant Program (Vocational Education) (84.048) and
Special Education - Grants for Infants and Families with Disabilities
(IDEA, Part C) (84.181). Added language to "I. Program Objectives"
and "II. Program Procedures" to recognize that additional information
on these topics can be found in the individual program sections.
Moved discussion of "School-Wide Programs" to recognize that such
programs can affect both ESEA and non-ESEA programs. Under "A.
Activities Allowed or Unallowed," revised "A.1. Consolidation
of Administrative Funds" to clarify the expenditure of such funds
are allowable if they are allowable under any of the contributing
programs. Also revised "A.4 School-Wide Programs" to reflect that
it applies to Vocational Education (84.048). Under "B. Allowable
Costs/Cost Principles," revised "B.1. Alternative Fiscal and Administrative
Requirements" to clarify that if a State adopts its own cost principles,
they must be consistent with A-87; and "B.2 Indirect Costs" to
clarify the restricted indirect cost rate guidance and add that
it is applicable to Adult Education (84.002), IDEA (84.027 and
84.173),Vocational Education (84.048), and IDEA, Part C (84.181).
Revised "H. Period of Availability of Funds" to: (1) reflect that
it applies to Vocational Education (84.048) and IDEA, Part C (84.181);
(2) show separately restriction for Title 1 (84.010); (3) add
additional restriction for SDFSC (84.186) and exception to basic
requirement for Vocational Education (84.048); and (4) add appropriate
statutory references. Revised "L.1 Financial Reporting" to correct
and update its applicability and to reflect implementation of
new Grants Administration and Payment System (GAPS). Revised "N.1.
Participation of Private School Children to indicate that how
these provisions are implemented by the individual auditee will
determine whether it is a "general cross-cutting provision." Added
Vocational Education (84.048) to programs for which "N.2 Schoolwide
Programs" is applicable. Added Vocational Education (84.048) to
programs for which "IV. Other Information C. Schoolwide Programs"
is applicable. Corrected reference in "N.3 Comparability" compliance
- CFDA 84.002
- Revised "II. Program Procedures" to recognize that this program
was reauthorized in 1998 under a new statute. Added reference
to ED cross-cutting section in "B. Allowable Costs/Cost Principles"
to reflect that the restricted indirect cost rate described in
that section is applicable to this program. Revised "L.1 Financial
Reporting" to reflect implementation of new Grants Administration
and Payment System (GAPS).
- CFDA 84.011
- Updated "L.3 Special Reporting" to reflect that the special
report was replaced by a new report.
- CFDA 84.027
and 84.173 - Added reference to ED cross-cutting section in "B.
Allowable Costs/Cost Principles" to reflect that the restricted
indirect cost rate described in that section is applicable to
- CFDA 84.032
- Updated "II. Program Procedures" for changes to law and added
a new paragraph "Source of Governing Requirements." Updated and
corrected reference in "A. Activities Allowed and Unallowed."
Revised "L.3 Special Reports" to: (1) delete the ED 704 report;
(2) clarify that in NSLDS "outstanding principal" is a key item
for all loans, not just those in default status; and (3) revise
references to special tests and provisions. Added regulatory citation
to "N.1 Current Records." Deleted prior "N.2 Transition Support."
Renumbered remaining special tests and provisions. (The following
changes are referenced to the new numbers.) Revised "N.2 Federal
Reinsurance Rate" to clarify and update for changes in the law.
Revised "N.5" to reflect the "Default Aversion Assistance" provisions
which replaced the prior "Pre-Claims and Supplemental Pre-Claims
Assistance" in the HEA. Revised suggested audit procedures, accordingly.
Updated "N.8. Federal Share of Borrower Payments" for changes
in the HEA. Clarified statutory citation in "N.9 Assignment of
Defaulted Loans to ED." Revised compliance requirements, audit
objectives and suggested audit procedures for "N.10 Federal Student
Loan Reserve Fund and Agency Operating Fund" to reflect changes
in the HEA. Revised compliance requirements, audit objectives
and suggested audit procedures for "N.11 Investments - Federal
Student Loan Reserve Fund (Reserve Fund)" to reflect changes in
- CFDA 84.126
- Updated statutory references in "E.1 Eligibility of Individuals"
and "H. Period of Availability of Federal Funds." Deleted outdated
and necessary provision in "J. Program Income." Revised "L.1 Financial
Reporting" to reflect implementation of new Grants Administration
and Payment System (GAPS). Deleted report (RSA-113, Quarterly
Cumulative Caseload Report) in "L.2 Performance Reporting."
(page 84.278) - Revised "L.1 Financial Reporting" to reflect implementation
of new Grants Administration and Payment System (GAPS).
- CFDA 84.281
- Added reference to ED cross-cutting section in "G.3 Earmarking"
related to use of unneeded program funds.
- CFDA 84.288
- Deleted reference to ED cross-cutting section in "C. Cash Management"
which was in error.
- CFDA 93.044
- Corrected error in "G.2.1 Level of Effort."
- CFDA 93.558
- Updated "II. Program Procedures" to delete transitional information.
Clarified eligibility requirement in "E.1 Eligibility of Individuals."
"Revised G.2.1 Level of Effort - Maintenance of Effort" and
"G.3 Eligibility" to provide additional explanation of the requirement.
Deleted transitional information from "L.3 Special Reporting."
Revised "N.2 Income Eligibility and Verification System" to provide
more detailed information on the compliance requirement and to
exclude Federal tax return information. Added section for transfers
into TANF in "IV. Other Information."
- CFDA 93.914
- Clarified requirement in "H. Period of Availability of Federal
- CFDA 94.006
- Revised "E.1 Eligibility for Individuals" to add the living
allowances for the 1999-2000 period.
- CFDA 94.011
and 94.016 - Revised "E.1 Eligibility for Individuals" to add
a Federal Register reference for the latest published income eligibility
- CFDA 96.001
and 96.006 - Clarified that this program as included in the 1998
Compliance Supplement was actually a cluster consisting of CFDAs
96.001 - Social Security-Disability Insurance and 96.006 - Supplemental
Security Income. Clarified "I. Program Objectives" and "II. Program
Procedures." Added language to clarify "A. Activities Allowed
or Unallowed." Added language to "B. Allowable Costs Cost Principles"
to (1) clarify that POMS applies to both programs in the cluster,
(2) clarify that indirect costs should charged at an approved
rate, and (3) provide further explanation of requirements pertaining
to non-SSA work. Revised "L.1 Financial Reporting" to reflect
changes in the applicability of standard reports and to add a
program names where necessary to be consistent with the Catalog
of Federal Domestic Assistance (CFDA).
Part 5 -
Clusters of Programs
- Added the
following new program to the Student Financial Assistance Cluster:
- 93.925 -
Scholarships for Health Professions Students From Disadvantaged
Financial Assistance Cluster - Revised "Part II Program Procedures"
to reflect enactment of the Higher Education Amendments of
1998 (P.L. 105-244) and the Health Professions Partnership
Act of 1998 (P.L. 105-392). Added a new program to the cluster,
CFDA 93.925, which will replace CFDA 93.820, as a result of
P.L. 105-392. Corrected a regulatory reference in "A. Activities
Allowed or Unallowed" for the HPSL and NSL programs. Corrected
a regulatory reference in "C. Cash Management." Revised "E.
Eligibility" to (1) reflect changes in the law pertaining
to the HPSL, NSL, HEAL, EFNS, FPL, FFEL and FDL programs,
and (2) correct regulatory citations. Updated "G. Matching"
to delete reference to the ELO program under the FPL program
and update the FWS requirements for changes in the law. Added
a description of the requirement for "J. Program Income" for
the FPL program. Revised "L.1 Financial Reporting" to reflect
implementation of new Grants Administration and Payment System
(GAPS). Revised "L.3 Special Reporting" to update example
in "L.3.a" and add a new "L.3.b FPL and Grant Overpayment
Reporting to the National Student Loan Data System (NSLDS)."
Corrected regulatory reference in "N.1 Separate Funds." Revised
"N.3 Disbursements to Students" to clarify and update for
changes in requirements. Revised "N.4 Refunds" to clarify
and update for changes in requirements and add regulatory
citations. Updated "N.5 Student Status Changes" for changes
in requirements. Updated "N.6 Student Loan Repayments" for
changes in requirements for HPSL and NSL programs. Revised
"N.7 Federal Work Study Agreements" to delete compliance requirements
that are not covered by the audit objective and suggested
audit procedures. Added a new special test and provision titled
"N.8 Borrower Data Transmission and Reconciliation."
list of other clusters for programs included in this Supplement.
- Internal Control
- In the
"Introduction," added characteristic pertaining to the establishment
of an audit committee or equivalent for entities with governing
boards to Control Environment," "Control Activities," and
- In "I.
Procurement and Suspension and Debarment," under "Information
and Communication" added control characteristic that procurement
staff are provided a current "List of Parties Excluded from
Federal Procurement or Nonprocurement Programs."
- Guidance for Auditing Programs Not Included in This Compliance
reference to separate HUD audit guide for audits of Public
and Indian Housing Authorities from "Steps for Identifying
"L. Reporting," added information concerning the Paperwork
I - Federal Programs Excluded From the A-102 Common Rule
"Differences pertaining to financial reporting" to reflect
inclusion of Child Support Enforcement--Title IV-D (CFDA 93.563)
and Foster Care--Title IV-E (CFDA 93.658) in this Supplement.
II - Federal Agency Codification of Certain Governmentwide Grant
for Department of Commerce's adoption of OMB Circular A-110.
III - Federal Agency Contacts for A-133 Audits
Federal agency contacts.
IV - Internal Reference Tables
tables for changes in the Supplement.
V - List of Changes for the 1999 Compliance Supplement
this Appendix to provide a list of changes from the OMB Circular
A-133 Compliance Supplement issued in May 1998 to this 1999
VI -Advisory to Federal Grantees on Responsibility to Address
the Year 2000 Issue
this Appendix to provide copy of March 19, 1998, advisory
from OMB to Federal agencies which is referenced in Part 3,
"N. Special Tests and Provisions."