The Office of Management and Budget (OMB) recently published the 2022 Compliance Supplement, which outlines information on how to conduct Single Audits for federal programs, including American Rescue Plan Act (ARPA) Fiscal Recovery Fund (Recovery Fund) investments and the Emergency Rental Assistance (ERA) Program. Federal law requires counties that invested $750,000 or more in federal funds within its fiscal year to have an auditor conduct Single Audits of these expenditures.

Key takeaways for auditors from the Compliance Supplement related to county Recovery Fund investments include:

• Auditors must use Part 3 of the OMB Compliance Supplement (pages 27–126) and the Recovery Fund program supplement to perform the audit


• Counties must comply with the Final Rule effective as of April 1, 2022


• Auditors must audit recipients on funds they expended for their fiscal year 2022 based on requirements set forth in the American Rescue Plan as well as Treasury’s Interim Final Rule, Final Rule and Frequently Asked Questions that were in effect at the time of those expenditures.


• Treasury will not take action to enforce against uses of the Interim Final Rule if a use of funds is consistent with the terms of the Final Rule, regardless of when the funds were used

Notably, OMB also released guidance earlier this year allowing counties that received less than $10 million in Recovery Funds and spent less than $750,000 of non-ARPA federal in a single fiscal year to opt for attestation instead of audit under the Single Audit Act. This process would evaluate counties based on two compliance factors: (1) whether the county uses Recovery Funds for eligible uses and (2) whether the county properly reports costs incurred by the pandemic.

For audits associated with the ERA program, auditors must also use Part 3 of the OMB Compliance Supplement (pages 27–126) and the ERA program supplement in their evaluations.

The OMB Compliance Supplement for the American Rescue Plan Fiscal Recovery Fund program can be found here and the supplement for the Emergency Rental Assistance program can be found here.