Nonprofit Resources


2024 OMB Compliance Supplement Now Available

The 2024 Compliance Supplement, which applies to entities subject to audits in accordance with 2 CFR Part 200, has been released by the U.S. Office of Management and Budget (OMB). This was announced by a Federal Register notice on June 5, 2024.

The 2024 Compliance Supplement is effective for single audits of fiscal years beginning after June 30, 2023, and supersedes the 2023 Compliance Supplement dated May 22, 2023.

The 2024 Compliance Supplement contains notable changes in the Student Financial Assistance Cluster related to a new area being tested under Special Tests and Provisions. Auditors must now look at institutional eligibility related to restrictions on the percentage of:

  • Correspondence courses offered;
  • Students enrolled in correspondence courses;
  • Incarcerated students; and
  • Students admitted without a high school diploma or recognized equivalent (ability to benefit).

Institutions are not required to provide the calculations to the U.S. Department of Education (ED), but they must maintain documentation supporting compliance with the requirements and auditors will be required to test this. ED Electronic Announcement General 23-121, released in December 2023, describes how auditors must substantiate these calculations and the related reporting as an attestation performed in accordance with the American Institute of Certified Public Accountants Statement on Standards for Attestation Engagements. However, ED does accept coverage of these calculations through an institution’s annual Title IV compliance audit or Single Audit submission.

The 2024 Compliance Supplement also requires new representations in the management representation letter related to institutional eligibility.

Another new requirement is that in order to receive a Pell Grant, incarcerated individuals must be enrolled in an eligible prison education program as defined in 34 CFR § 668.236.

Finally, Part 1 of the 2024 Compliance Supplement states that “On April 22, 2024, OMB issued revisions to 2 CFR Part 200, Subpart F, which among other things, increased the audit threshold to $1,000,000 for auditee fiscal years beginning on or after October 1, 2024” (i.e., other fiscal year-ends September 30, 2025, and later).

Further clarification is provided in Part 8 Appendix VII, pages 55 – 56, which notes that “… federal agencies may elect to implement the revisions as early as June 21, 2024 to new awards and through amendments to existing awards.” However, this decision is left up to the individual agencies and they are not required to make any changes before October 1, 2024.

Please contact us if you have questions about the new Compliance Supplement or would like to discuss a consultation.

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