OMB Publishes 2024 Compliance Supplement
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The Office of Management and Budget (OMB) published the 2024 Compliance Supplement this week – the tool that auditors are required to use when evaluating federally funded programs.


The U.S. Department of Education section of the 2024 Compliance Supplement is available here.


The Compliance Supplement includes 12 compliance areas that auditors may review: activities allowed or unallowed and allowable costs/cost principles; cash management; eligibility; equipment/real property management; matching, level of effort, earmarking; period of performance; procurement, suspension & debarment; program income; reporting; subrecipient monitoring; and special tests and provisions.  Each federal agency is required to choose six of the 12 requirements for auditors to focus on in the upcoming year for each federal program.  The compliance areas chosen by the U.S. Department of Education (ED) may vary from program to program.  However, although auditors may not be testing all 12 requirements each year, grantees must still comply with all federal program and fiscal requirements. 


Most of the compliance areas selected by ED remained similar to those included in the 2023 Compliance Supplement, but some programs saw the removal or addition of one or two of the six selected areas.  Grantees should ensure they are familiar with the compliance areas chosen for each program in the 2024 Compliance Supplement in preparation for audits.


Other changes include adding references to new or updated guidance documents released by ED over the last year, as well as removing the McKinney-Vento Homeless Assistance Act as an allowable non-Elementary and Secondary Education Act (ESEA) program for State administrative consolidation.  The program was included in prior compliance supplements despite ED guidance not explicitly designating McKinney-Vento as an allowable program for consolidation under ESEA Section 8201, but the 2024 version removes the reference.


About the Author

Kelly Christiansen is an associate with the Washington, DC law firm of The Bruman Group, 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 Association of State Program Administrators (NAESPA).