Policy
OMB Posts 2019 Compliance Supplement
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As announced in an email to stakeholders two weeks ago, the Office of Management and Budget publicly posted the 2019 Compliance Supplement on July 1st.  The over 1,500-page document is what auditors will rely on for those audits of fiscal years beginning on or after June 30, 2018.  The new supplement supersedes the June 2017 supplement and the June 2018 amendments to the 2017 document.

The most significant change in the 2019 supplement deals with the number of compliance areas an auditor will review for each program.  The supplement directs auditors to review only a maximum of six of the most critical compliance areas, identified by agencies based on program needs, as opposed to the full 12.  The six compliance areas for review on each program were selected by the U.S. Department of Education and differ from program to program.  Some programs do have the same or similar areas selected for review, though.  For example, the Adult Education and Family Literacy program and the Carl D. Perkins Career and Technical Education program compliance factors are identical.  Other programs have some overlapping compliance areas but are not 100 percent the same, such as the Individuals with Disabilities Education Act and Title I of the Elementary and Secondary Education Act.

Education administrators should consult the 2019 supplement to determine which compliance factors will be reviewed for each ED program.  The 2019 Compliance Supplement is available here.

About the Author

Kelly Christiansen is an associate with the Washington, DC law firm of Brustein & Manasevit, PLLC. Established in 1980, the Firm is nationally recognized for its federal education regulatory and legislative practice, providing legal advice regarding compliance with all major federal education programs as well as the federal grants management requirements, including the Education Department General Administrative Regulations (EDGAR). In addition, they work with agencies on federal spending flexibility, allowability, policies and procedures, audit defense and resolution and legislative updates. The Firm provides government relations services for the National Title I Association.