Chris Pembrook, Manager Crawford & Associates, P.C.
The draft of the 2015 compliance supplement has been has been provided for the use of audit planning purposes with the final issuance expected late June 2015. Within the draft there are some interesting changes to make note of for both auditors and auditees. These changes include reduction of the number of compliance supplements and potential issues regarding internal control evaluation.
With regards to the compliance requirements, this draft document has removed both Davis Bacon and Real Property Acquisition and Relocation Assistance. The draft compliance matrix has replaced these requirements with reserved. This leaves the opportunity for future requirements or modifications to the requirements removed to possibly be added in the future. Another note is that “Period of Availability" has been renamed as "Period of Performance".
Another interesting note for both auditors and auditees is that language previously used in Part 6 "Internal Control" has been removed. This is due to limited time for OMB to update Part 6 to reflect updates that have occurred to COSO's updated "Internal Control Framework" and GAO's “Standards for Internal Control in the Federal Government” (Green Book). This is an area that auditees should be cognizant of as both of these documents have been referenced in the Uniform Guidance, specifically 2 CFR 200.303, as best practice documents for non-federal entity's internal control framework and are the specifically referenced in this draft of the compliance supplement.