| In May of 2006 the Office of Management and | | | | range from basic verbiage changes to |
| Budget issued a new revised supplement for | | | | significant compliance requirement changes. |
| OMB A-133. This revised supplement had | | | | The Following is a list of the Federal |
| several changes made to grant program | | | | Agencies that have made changes to their |
| narratives on the program requirements, which | | | | grant programs: |
| resulted in other parts of the compliance | | | | |
| supplement also being changed. The changes | | | | Department of Agriculture (CFDA# 10.XXX) |
| range from minor verbiage changes to specific | | | | |
| changes in program requirements as a result | | | | Department of Commerce (CFDA# 11.XXX) |
| of Hurricane Katrina. A brief over view of | | | | |
| the changes can be seen in Appendix V of the | | | | Department of Defense (CFDA# 12.XXX) |
| 2006 Compliance Supplement. | | | | |
| | | | Department of Housing and Urban Development |
| The major Program requirement changes were in | | | | (CFDA# 14.XXX) |
| the following parts of the supplement: | | | | |
| | | | Department of Labor (CFDA# 17.XXX) |
| Part 3 - Compliance Requirements | | | | |
| | | | Department of Transportation (CFDA# 20.XXX) |
| Part 4 - Agency Program Requirements | | | | |
| | | | Department of the Treasury (CFDA# 21.XXX) |
| Part 5 - Clusters of Programs | | | | |
| | | | National Foundation of the Arts and |
| PART 3 | | | | Humanities (CFDA# 45.XXX) |
| | | | |
| The significant change made in Part 3 was in | | | | Department of Energy (CFDA# 81.XXX) |
| Section D, which was the creation of a | | | | |
| disaster waiver for Davis Bacon requirements | | | | Department of Education (CFDA# 84.XXX) |
| as a result of Hurricane Katrina. On | | | | |
| September 8, 2005, the President of the | | | | Department of Health and Human Services |
| United States issued a proclamation | | | | (CFDA# 93.XXX) |
| suspending the Davis-Bacon Act for the | | | | |
| payment of Davis-Bacon wages in areas | | | | Department of Homeland Security (CFDA# |
| affected by Hurricane Katrina. The waiver | | | | 97.XXX) |
| was rescinded as of November 8, 2005. | | | | |
| | | | United States Agency for International |
| For further information and guidance on the | | | | Development (CFDA# 98.XXX) |
| disaster waiver refer to Appendix VI of the | | | | |
| 2006 Compliance Supplement. | | | | If you have any grant award from any of these |
| | | | agencies you should review the list of grant |
| Another notable change made in Part 3 was in | | | | programs listed in Appendix V of the 2006 |
| Section I (Procurement, Suspension and | | | | Compliance Supplement to determine if any of |
| Disbarment). This section has been changed | | | | the changes will affect the grants which have |
| to clearly state the compliance requirements | | | | been awarded to you. |
| pertaining to procurements as it applies to | | | | |
| the implementation of OMB Circular A-102 | | | | PART 5 |
| "Common Rule" and OMB Circular A-110, which | | | | |
| was effective November 26, 2003. | | | | As a result of the changes made in Part 3 and |
| | | | 4 of the Compliance Supplement the list of |
| Local governments and Indian tribal | | | | grant clusters were changed. |
| governments which are not sub-recipients of | | | | |
| States will use their own procurement | | | | Appendices |
| procedures provided that these procedures | | | | |
| conform to applicable Federal law and | | | | As a result of the changes made in Part 3 and |
| regulations as well as the standards | | | | 4 of the Compliance Supplement the various |
| identified in A-102 "Common Rule". | | | | exhibits, reference sources and explanatory |
| | | | information contained in the Appendices were |
| Institutions of higher education, hospitals, | | | | changed. |
| and other non-profit organizations shall use | | | | |
| the procurement procedures that conform to | | | | Traditionally the Office of Management and |
| applicable Federal law and regulations and | | | | Budget has reviewed OMB A-133 Compliance |
| the standards identified in OMB Circular | | | | Supplement on an annual basis to assure that |
| A-110. | | | | the information contained is as current as |
| | | | possible to assist in evaluating program |
| This section has also added procedures and | | | | compliance on federal award programs. These |
| references for identifying contractors who | | | | revisions are normally made available on |
| have been suspended and/or disbarred from | | | | their web site in May of each year. |
| participating in Federal award programs. | | | | Therefore it is advisable to become familiar |
| This verification may be accomplished by | | | | with the web site and monitor it for updates |
| checking the Excluded Parties List System | | | | and other pertinent information pertaining to |
| (EPLS), which is maintained by the General | | | | the Single Audit Act. |
| Services Administration (GSA). For further | | | | |
| information on EPLS refer to Part 3 Section I | | | | Summary : Caporicci & Larson Report - In May |
| of the 2006 Compliance Supplement. | | | | of 2006 the Office of Management and Budget |
| | | | issued a new revised supplement for OMB |
| PART 4 | | | | A-133. This revised supplement had several |
| | | | changes made to grant program narratives on |
| This part of the 2006 Compliance Supplement | | | | the program requirements… |
| mainly summarizes program requirements for | | | | |
| various grants. These requirements are | | | | About author : Brian Kelly is a Senior |
| summarized and then organized and presented | | | | Auditor with Caporicci & Larson, a |
| in the order of Federal agency and then CFDA | | | | California-based CPA firm specializing in |
| number. The changes made to these programs | | | | government compliance auditing. |