Treasury, 2023 HAF Compliance Supplement
Summary
The 2023 Compliance Supplement section of the U.S. Department of the Treasury for the Homeowner Assistance Fund (HAF) program, Assistance Listing 21.026. It states that the program is considered a "higher risk" program for 2023 under 2 CFR section 200.519(c)(2). The supplement states that Section 3206 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2, codified as 15 USC 9058d, established HAF and provides $9.961 billion for payments to states, Indian tribes or their tribally designated housing entities and the Department of Hawaiian Home Lands. It states that at least 60 percent of participants' award funds must go to qualified expenses for eligible homeowners within a target income. A closing appendix lists changes, including an updated list of core team members for 2023.
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“Treasury, 2023 HAF Compliance Supplement.”
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2023 Homeowner Assistance Fund Program Treasury
DEPARTMENT OF THE TREASURY
ASSISTANCE LISTING 21.026 HOMEOWNER ASSISTANCE FUND PROGRAM
I. PROGRAM OBJECTIVES
Note: This program is considered a “higher risk” program for 2023, pursuant to 2 CFR section
200.519(c)(2). Refer to the “Programs with Higher Risk Designation” section of Part 8,
Appendix IV, Internal Reference Tables, for a discussion of the impact of the “higher risk”
designation on the major program determination process.
The Homeowner Assistance Fund (HAF) program provides $9.961 billion for the U.S.
Department of the Treasury (“Treasury”) to make payments to states (defined to include the
District of Columbia, Puerto Rico, US Virgin Islands, Guam, Northern Mariana Islands, and
American Samoa), Indian tribes or their tribally designated housing entities, and the Department
of Hawaiian Home Lands (collectively the “eligible entities” or “HAF Participants”) to mitigate
financial hardships associated with the coronavirus pandemic, including for the purpose of
preventing homeowner mortgage delinquencies, defaults, foreclosures, loss of utilities or home
energy services, and displacements of homeowners experiencing financial hardship after January
21, 2020, through qualified expenses related to mortgages and housing.
II. PROGRAM PROCEDURES
A. Overview
Section 3206 of the American Rescue Plan Act of 2021 (the “Act”), Pub. L. No. 117-2
(March 11, 2021), codified as 15 USC 9058d (15 USC 9058d), established the HAF
program and provides $9.961 billion for Treasury to make payments to the eligible
entities to provide the assistance to homeowners for qualified expenses related to
mortgages and housing as described in 15 USC 9058d(c)(1) and Treasury’s HAF
Guidance.
Pursuant to 15 USC 9058d(c)(2), at least 60 percent of the HAF participants’ award funds
must be used to provide assistance with mortgage payments, homeowner’s insurance,
utility payments, and other qualified expenses related to mortgages and housing to
eligible homeowners within a certain target income. The law requires HAF participants to
prioritize the remaining award funds to provide assistance to “socially disadvantaged
individuals” (see also the section on “Targeting” in the HAF Guidance).
15 USC 9058d(d) prescribes that the HAF funding must be allocated as follows:
1. $30 million for the US Virgin Islands, Guam, Northern Mariana Islands,
and American Samoa (US territories);
2. $498 million for the Department of Hawaiian Home Lands (DHHL) and
Indian tribes or their tribally designated housing entities; and
Compliance Supplement 2023 21.026-1
2023 Homeowner Assistance Fund Program Treasury
3. the remainder for the 50 states, the District of Columbia, and Puerto Rico.
Each state, the District of Columbia, and Puerto Rico will receive a
minimum payment of $50 million. Amounts that will be paid to states, the
District of Columbia, and Puerto Rico are based on homeowner need as it
relates to unemployment and mortgage delinquencies or mortgage
foreclosures in those jurisdictions.
Amounts paid to US territories are based on share of population, and amounts paid to
tribal entities are based on a formula under 15 USC 9058d(f).
Source of Governing Requirements
• Section 3206 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2 (March
11, 2021) and codified at 15 USC 9058d.
• As implemented by Treasury’s HAF guidance available on Treasury.gov,
including important version changes over time that can be found on the site.
Availability of Other Program Information
General information for the HAF program is available through the program website at
www.treasury.gov/HAF. Information includes the following documents:
• HAF Guidance (See pages 1-12)
Provides guidance on HAF program purpose, definitions, Notice of Request for
HAF payments, qualified expenses, homeowner eligibility, HAF plans, and
reporting and monitoring as required under section 15 USC 9058d.
• HAF Interim Report User Guide (See pages 1-27)
Provides guidance on using Treasury’s Portal to submit the required Homeowner
Assistance Fund (HAF) Interim Report.
• HAF Reporting Frequently Asked Questions (FAQs) (See pages 1-10)
Provided answers to frequently asked questions on HAF reports.
• HAF Quarterly Report User Guide (See pages 1-49)
The User Guide contains detailed guidance and instructions for HAF participants
in using Treasury’s Portal for submitting the HAF Quarterly Report.
• HAF Annual Report User Guide (See pages 1-31)
Compliance Supplement 2023 21.026-2
2023 Homeowner Assistance Fund Program Treasury
Provides guidance on using Treasury’s Portal to submit the required HAF Annual
Report.
• HAF Guidance on Participant Compliance and Reporting Responsibilities (See
pages 1-25)
Provides detail on HAF participants’ compliance and reporting responsibilities
under the HAF program, and should be read in concert with the HAF Financial
Assistance Agreement (See pages 1-5), the HAF authorizing statute (See pages
60-63), and the HAF Guidance (See pages 1-12).
III. COMPLIANCE REQUIREMENTS
In developing the audit procedures to test compliance with the requirements for this federal
program, the auditor must determine, from the following summary (also included in Part 2,
“Matrix of Compliance Requirements”), which of the 12 types of compliance requirements have
been identified as subject to the audit (noted with a “Y” in the summary matrix below), and then
determine which of the compliance requirements that are subject to the audit are likely to have a
direct and material effect on the federal program at the auditee. For each such compliance
requirement subject to the audit, the auditor must use Part 3 (which includes generic details about
each compliance requirement other than Special Tests and Provisions) and this program
supplement (which includes any program-specific requirements) to perform the audit. When a
compliance requirement is shown in the summary below as “N,” it has been identified as not
being subject to the audit. Auditors are not expected to test requirements that have been noted
with an “N.” See the Safe Harbor Status Discussion in Part 1 for additional information.
A B C E F G H I J L M N
Matching, Procurement and
Equipment and
Cash
Period
Activities Allowable
Level of Effort, Suspension and Subrecipient Special
Real Property
Eligibility Reporting
Allowed or Costs/Cost Of Program Tests and
Unallowed Principles Management Management Earmarking Performance Debarment Income Monitoring Provisions
Y Y N Y N Y N N N Y Y N
A. Activities Allowed or Unallowed
HAF participants may use their HAF award funds for qualified expenses related to mortgages
and housing, including for the purpose of preventing homeowner mortgage delinquencies,
homeowner mortgage defaults, homeowner mortgage foreclosures, homeowner loss of utilities or
home energy services, and displacements of homeowners experiencing financial hardship after
Compliance Supplement 2023 21.026-3
2023 Homeowner Assistance Fund Program Treasury
January 21, 2020. Please see pages 5 to 8 of the HAF Guidance for the full list of qualified
expenses.
B. Allowable Cost / Cost Principles
HAF funds are considered “other financial assistance” per 2 CFR 200.1 and are
administered by Treasury as direct payments for specified use. Refer to 2 CFR Part 200,
Subpart E regarding the Cost Principles that apply to the use of funds under this program.
1. Allowable Costs under the HAF program include the following:
a. mortgage payment assistance;
b. financial assistance to allow a homeowner to reinstate a mortgage or to
pay other housing-related costs related to a period of forbearance,
delinquency, or default;
c. mortgage principal reduction, including with respect to a second mortgage
provided by a nonprofit or government entity;
d. facilitating mortgage interest rate reductions;
e. payment assistance for: (a) homeowner’s utilities, including electric, gas,
home energy, water, and wastewater; (b) homeowner’s internet service,
including broadband internet access service, as defined in 47 CFR 8.1(b)
(or any successor regulation); (c) homeowner’s insurance, flood insurance,
and mortgage insurance; (d) homeowner’s association fees or liens,
condominium association fees, or common charges, and similar costs
payable under a unit occupancy agreement by a resident
member/shareholder in a cooperative housing development; and (e) down
payment assistance loans provided by nonprofit or government entities;
f. payment assistance for delinquent property taxes to prevent homeowner
tax foreclosures;
g. measures to prevent homeowner displacement, such as home repairs to
maintain the habitability of a home or assistance to enable households to
receive clear title to their properties;
h. reimbursement of funds expended by a state, local government, or
applicable tribal entity during the period beginning on January 21, 2020,
and ending on the date that the first funds are disbursed by the HAF
participant under the HAF, for a qualified expense (other than any
Compliance Supplement 2023 21.026-4
2023 Homeowner Assistance Fund Program Treasury
qualified expense paid directly or indirectly by another federal funding
source, or any qualified expenses described in clauses (6), (7), (8), or (10)
of this definition);
i. payment of lot rent for a manufactured home, where such payment would
promote housing stability and prevent the default of the resident of the
manufactured home; and
j. reimbursement of funds expended by a state, local government, or entity
described in clause (3) or (4) of the definition above of “eligible entity”
during the period beginning on the date the participant received its initial
HAF payment and ending on the date the participant received the balance
of funds requested in the participant’s HAF plan for a qualified expense
consistent with the participant’s approved HAF Plan (other than any
qualified expense paid directly or indirectly by another federal funding
source).
Please see the HAF Guidance on the HAF program page on Treasury.gov for the latest
guidance regarding the eligible uses of HAF funds.
E. Eligibility
1. Eligibility for Individuals
Treasury expects auditors to test the eligibility of homeowners to receive HAF assistance
and to focus on whether HAF participants established and adhered to reasonable policies
and procedures for evaluating homeowners’ applications in accordance with the HAF
Guidance which permits HAF participants to reasonably rely on self-attestation.
Testing of individual homeowner eligibility-related documentation should be limited to
material already collected by the HAF participant in the application as much as possible
to avoid imposing undue burden on homeowners that are experiencing financial
hardships.
The HAF Guidance documents the full eligibility considerations for HAF participants to
extend financial assistance to vulnerable populations without imposing undue
documentation burdens. HAF participants must require all applications for assistance to
include an attestation from the applicant homeowner that all information included is
correct and complete. In addition, HAF participants are expected to have policies and
procedures to determine homeowner eligibility in the following two criteria:
Financial Hardship: HAF participants may rely on homeowners' attestations that they
experienced financial hardship after January 21, 2020 (including a hardship that began
Compliance Supplement 2023 21.026-5
2023 Homeowner Assistance Fund Program Treasury
before January 21, 2020 but continued after that date). The attestation must describe the
nature of the financial hardship (for example, job loss, reduction in income, or increased
costs due to healthcare or the need to care for a family member).
Income Determination: HAF participants may take one of two approaches to income
verification: (1) the homeowner may provide a written attestation as to household income
together with supporting documentation such as paystubs, W2s or other wage statements,
IRS Form 1099s, tax filings, depository institution statements demonstrating regular
income, or an attestation from an employer; or (2) the homeowner may provide a written
attestation as to household income and the HAF participant may use a reasonable fact-
specific proxy for household income, such as reliance on data regarding average incomes
in the household’s geographic area. To be eligible for HAF assistance, the homeowner
must have income equal to or less than 150 percent of the area median income (AMI) or
100 percent of the median income for the United States, whichever is greater.
For additional information, please see Treasury’s HAF Guidance at:
https://home.treasury.gov/system/files/136/HAF-Guidance.pdf
2. Eligibility of Group of Individuals or Area of Service Delivery
Not Applicable
3. Eligibility for Subrecipients
Not Applicable
G. Matching, Level of Effort, Earmarking
1. Matching
Not Applicable
2. Level of Effort
Not Applicable
3. Earmarking
1. Counseling or educational efforts by housing counseling agencies
approved by HUD, tribal government (including such efforts by in-house
housing counselors who are HUD certified or tribally approved), or legal
services, targeted to households eligible to be served with funding from
the HAF related to foreclosure prevention or displacement, in an aggregate
amount up to 5 percent of the funding from the HAF received by the HAF
participant.
Compliance Supplement 2023 21.026-6
2023 Homeowner Assistance Fund Program Treasury
2. Planning, community engagement, needs assessment, and administrative
expenses related to the HAF participant’s disbursement of HAF funds for
qualified expenses, in an aggregate amount not to exceed 15 percent of the
funding from the HAF received by the HAF participant.
3. Participants are providing not less than 60% of funds to homeowners with
income less than 100% AMI or 100% of U.S. median income.
4. Participants target homeowners that are classified as Socially
Disadvantaged Individuals (SDI) and 100 percent AMI or less.
L. Reporting
1. Financial Reporting
a. SF-270, Request for Advance or Reimbursement – Not Applicable
b. SF-271, Outlay Report and Request for Reimbursement for Construction
Programs – Not Applicable
c. SF-425, Federal Financial Report – Not applicable
d. Other: Quarterly Report (PRA 1505-0269))- Quarterly
Authoritative Requirement: 2 CFR 200.328
Report Instructions:
https://home.treasury.gov/system/files/136/HAF_QuarterlyReportUserGui
de.pdf
Report Corrections: The Office of Recovery Program’s (ORP) reporting
portal has built-in functionality to reopen a report and allow recipients to
make edits after the reporting deadline. However, it is ORP’s policy that
recipients may only make revisions if authorized by Treasury staff for a
period of up to 60 days after the reporting deadline. After the revision
period ends, the report is final. A resubmitted report becomes a recipient’s
final report within ORP’s reporting portal. Recipients can generate PDFs
of this reports at any time.
Key Line Items –
1. Administrative Expenses- Quantifiable Objective Criteria: Obligations
and expenditures do not exceed 15% for admin expenses, as noted on page
4 of the HAF Guidance (See item #10).
Compliance Supplement 2023 21.026-7
2023 Homeowner Assistance Fund Program Treasury
2. Services, Counseling & Education- Quantifiable Objective Criteria:
Obligations and expenditures do not exceed 5% for legal services,
counseling, and education, as noted on page 4 of the HAF Guidance.
2. Performance Reporting
a. Title of Report: Annual Performance Report
PRA Number: 1505-0269
Reporting Cycle: Annual
Authoritative Requirement:
https://home.treasury.gov/system/files/136/HAF_GuidanceonParticipantC
omplianceandReportingResponsibilities.pdf
Blank Copy of the Report: HAF_AnnualReportUserGuide_5.23.22.docx
Report Instructions: HAF_AnnualReportUserGuide_5.23.22.docx
Key Line Item(s)
1. Socially Disadvantaged Individuals- Quantifiable Objective Criteria:
Participants are providing not less than 60% of funds to homeowners with
income less than 100% AMI or 100% of U.S. median income.
2. Area Median Income- Quantifiable Objective Criteria: Participants target
homeowners that are classified as SDI and 100 percent AMI or less. This
requirement can be found on page 6 of the HAF Guidance.
3. Special Reporting
Not Applicable
4. Special Reporting for Federal Funding Accountability and Transparency Act
Although reporting on subaward information is applicable to HAF participants
pursuant to the award term set forth in Appendix A to 2 CFR Part 170, which is
incorporated by reference in the HAF Financial Assistance Agreement, HAF
participants’ compliance with these reporting requirements is not subject to audit.
M. Subrecipient Monitoring
All HAF participants and their subrecipients must be registered in SAM.gov. HAF
participants must monitor and manage their subrecipients in accordance with 2 CFR
200.332 to ensure their subrecipients are administering the subawards in compliance with
the terms and conditions of the subawards.
Compliance Supplement 2023 21.026-8
May 2023 Federal Agency Single Audit, Key Management Liaison, and Program Contacts
APPENDIX III
FEDERAL AGENCY SINGLE AUDIT, KEY MANAGEMENT LIAISON, AND
PROGRAM CONTACTS
This appendix provides federal agency single audit contacts (starts on page 8-III-2), key
management liaisons (starts on page 8-III-10), and program contacts (starts on page 8-III-11) for
each program/cluster included in the Supplement. For the single audit contacts a table is provided
for each federal agency identifying who can answer technical audit questions. The table includes
contact information and the geographical area each federal contact is responsible for overseeing.
A list of key management liaisons, who are the contacts for questions related to the administrative
requirements applicable to an agency program(s), and their e-mail addresses follows the single
audit contact information. Last, program contacts, who can answer programmatic questions, and
their contact information, are listed by agency and Assistance Listing number.
Agency Page
United States Department of Agriculture 8-3-2
Department of Commerce 8-3-2
Department of Defense 8-3-2
Department of Education 8-3-2
Department of Energy 8-3-3
Department of Health and Human Services 8-3-3
Department of Homeland Security 8-3-3
Department of Housing and Urban Development 8-3-3
Department of the Interior 8-3-4
Department of Justice 8-3-4
Department of Labor 8-3-4
Department of State 8-3-4
Department of Transportation 8-3-5
Department of the Treasury 8-3-5
Department of Veterans Affairs 8-3-5
Agency for International Development 8-3-5
Appalachian Regional Commission 8-3-6
Corporation for National and Community Service 8-3-6
Environmental Protection Agency 8-3-6
Federal Communications Commission 8-3-6
General Services Administration 8-3-7
Gulf Coast Ecosystem Restoration Council 8-3-7
National Aeronautics and Space Administration 8-3-7
National Archives and Records Administration 8-3-7
National Endowment for the Arts 8-3-8
National Endowment for the Humanities 8-3-8
National Science Foundation 8-3-8
Nuclear Regulatory Commission 8-3-8
Social Security Administration 8-3-8
Tennessee Valley Authority 8-3-9
US Small Business Administration 8-3-9
Federal Agency Key Management Liaisons 8-3-10
Federal Agency Program Contacts 8-3-11
Compliance Supplement 2023 8-III-1 Appendix III
May 2023 Federal Agency Single Audit, Key Management Liaison, and Program Contacts
Federal Agency Single Audit Contacts
Agency Type of Audit
Department of Transportation
US Department of Transportation
Office of Inspector General
Attn: National Single Audit Coordinator
101 W. Lombard Street, Suite 2516
Baltimore, MD 21201
Phone: Voice (443) 825-1510
Additional Contact: Matthew Straw
singleauditrequest@oig.dot.gov
Department of the Treasury
Department of the Treasury All audits
Office of Inspector General
Deputy Assistant Inspector General for Audit
875 15th Street NW, Suite 300
Washington, DC 20050
Phone: Voice 202-927-5784
Fax: 202-927-5379
Department of Veterans Affairs
Director All audits
Office of Inspector General
Financial Statement Audit Division (52CF)
Department of Veterans Affairs
810 Vermont Ave. NW
Washington, DC 20420
Phone: Voice 202-565-7013
Fax: 202-565-7771
Agency for International Development
USAID For audits of all US based
Attn: OIG/A/FA not-for-profit organizations
Room 8.10-10
1300 Pennsylvania Avenue, NW
Washington, DC 20523-7802
Phone: Voice 202-712-4902
Fax: 202-216-3598
E-Mail: faudit@usaid.gov
Web site:
U.S. Agency for International Development (usaid.gov)
Compliance Supplement 2023 8-III-5 Appendix III
May 2023 Federal Agency Single Audit, Key Management Liaison, and Program Contacts
Federal Agency Key
Agency Name E-Mail Address
Department of Agriculture Samantha Coles Samantha.cole@usda.gov
Seanne Weekes Seanne.weekes@usda.gov
Department of Commerce John P. Geisen JGeisen@doc.gov
Department of Defense Jason Day jason.o.day.civ@mail.mil
Department of Education Lihong Guo Lihong.Guo@ed.gov
Department of Energy Joel Gonzalez Joel.Gonzalez@hq.doe.gov
Department of Health and Human Robin Aldridge Robin.Aldridge@hhs.gov
Services Leticia Adu Leticia.Adu@hhs.gov
Department of Homeland Security Michael Pellegrino Michael.Pellegrino@HQ.DHS.GOV
Department of Housing and Urban Shannon E. Steinbauer Shannon.E.Steinbauer@hud.gov
Development
Department of the Interior Eunice Pierre eunice_pierre@ios.doi.gov
Department of Justice Linda Taylor Linda.Taylor2@usdoj.gov
Jeff A. Haley Jeff.Haley@usdoj.gov
Department of Labor Anita Robinson Robinson.Anita@dol.gov
Latonya Torrence Torrence.Latonya@dol.gov
Department of State Thomas Kodiak Kodiakt@state.gov
Department of the Treasury Siporah Jackson Siporah.Jackson@treasury.gov
Department of Transportation Willie Smith willie.smith@dot.gov
Department of Veterans Affairs Kevin Cone Kevin.Cone@va.gov
Corporation for National and Edris Shah eshah@cns.gov
Community Service
Denali Commission Beth Flowers bflowers@denali.gov
Environmental Protection Agency Kysha Holliday Holliday.Kysha@epa.gov
Federal Communications Commission Sheela Kailasanath Sheela.Kailasanath@fcc.gov
Gulf Coast Ecosystem Restoration Steve Sigler Steve.sigler@restorethegulf.gov
Council
Institute for Museum and Library Connie Cox Bodner CBodner@imls.gov
Services
National Aeronautics and Space Antanese Crank antanese.n.crank@nasa.gov
Administration
National Archives and Records Christopher Eck Christopher.Eck@nara.gov
Administration
National Endowment for the Arts Breanna Berger bergerb@arts.gov
National Endowment for the Laura Davis ldavis@neh.gov
Humanities
National Science Foundation Rochelle D. Ray rray@nsf.gov
Office of National Drug Control Policy Lisa Newton Lisa_E_Newton@ondcp.eop.gov
Social Security Administration Trae Sommer Audit.Correspondence@ssa.gov
DCO.AUDIT@ssa.gov
DCO.ODD.AUDIT@ssa.gov
OIG.audit.kansascity@ssa.gov
Frank.Biro@ssa.gov
US Agency for International David McNeil dmcneil@usaid.gov
Development
US Small Business Administration Kimberly Butler Kimberly.Butler@sba.gov
Compliance Supplement 2023 8-III-10 Appendix III
May 2023 Federal Agency Single Audit, Key Management Liaison, and Program Contacts
Federal Agency Program
Contacts
Assistance Agency Contact(s) E-Mail Address Telephone
Listing Number
Maritime Administration
(MARAD)
John Desch John.Desch@dot.gov
Senior Contract Specialist, 202-366-4356
(MARAD)
21 Department of the Treasury
(TREAS)
21.015 Troyling Harris troyling.harris@treasury.gov 202-927-8096
21.020 Chief Compliance Officer
21.016 Siporah Jackson Siporah.Jackson@treasury.gov 202-374-1813
21.019 Nasr Fahmy, Single Audit Nasr.Fahmy@treasury.gov (202) 527-4036
Advisor
21.023 Nasr Fahmy, Single Audit Nasr.Fahmy@treasury.gov (202) 527-4036
Advisor
21.026 Nasr Fahmy, Single Audit Nasr.Fahmy@treasury.gov (202) 527-4036
Advisor
21.027 Nasr Fahmy, Single Audit Nasr.Fahmy@treasury.gov (202) 527-4036
Advisor
21.029 Nasr Fahmy, Single Audit Nasr.Fahmy@treasury.gov (202) 527-4036
Advisor
21.032 Nasr Fahmy, Single Audit Nasr.Fahmy@treasury.gov (202) 527-4036
Advisor
32 Federal Communications
Commission
32.006 Sheela Kailasanath Sheela.Kailasanath@fcc.gov 202-418-0938
32.009
45 National Endowment for the
Humanities (NEH)
45.129 Karen Kenton kkenton@neh.gov 202-606-8307
Director
Compliance Supplement 2023 8-III-19 Appendix III
May 2023 Internal Reference Tables
APPENDIX IV
INTERNAL REFERENCE TABLES
INTRODUCTION
This Appendix includes a listing of programs with a “higher risk” designation and describes how
that designation impacts the major program determination process. It also includes a list of
programs in Part 4, which have requirements defined in IV, Other Information.
PROGRAMS WITH “HIGHER RISK” DESIGNATION
Uniform Guidance section 200.519(c)(2) states that “Federal agencies, with the concurrence of
OMB, may identify Federal programs that are higher risk. It also states that OMB will provide
this identification in the Compliance Supplement.”
As a result of the COVID-19 pandemic, many new federal programs were established and
funding was added to existing federal programs from the following Acts:
• Coronavirus Preparedness and Response Supplemental Appropriations Act
• Families First Coronavirus Response Act
• Coronavirus Aid, Relief, and Economic Security Act (CARES Act)
• Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA)
• American Rescue Plan Act (ARP)
Funding arising from these sources is referred to as “COVID-19 funding,” or “COVID-19
programs”.
On November 15, 2021, the Infrastructure Investment and Jobs Act (IIJA) was signed into law.
It established new programs and provided additional funding for existing programs. Funding
arising from the IIJA is referred to as “IIJA funding” or “IIJA program”. The 2023 higher risk
list includes one program that includes IIJA funding.
The following table includes a complete list of programs that have been identified as “higher
risk” for audits subject to the 2023 Compliance Supplement either because of COVID-19
funding, IIJA funding, or because a Federal agency has identified the program to be higher risk.
Agency Assistance Listing (CFDA) Title
Number
Education* 84.425 Education Stabilization Fund
HHS* 93.498 Provider Relief Fund and American Rescue
Plan (ARP) Rural Distribution
HHS** 93.778/93.777/93.775 Medicaid Cluster
Treasury* 21.023 Emergency Rental Assistance
Compliance Supplement 2023 8-IV-1 Appendix IV
May 2023 Internal Reference Tables
Treasury* 21.026 Homeowner Assistance Fund
Treasury* 21.027 Coronavirus State and Local Fiscal
Recovery Funds
Treasury* 21.029 Coronavirus Capital Projects Fund
Interior ** 15.252 Abandoned Mine Land Reclamation
(AMLR)
Social Security 96.001/96.006 Disability Insurance/Supplemental Security
Income
Note:
* These programs were created by one of the laws cited at the beginning of this section and are
thus considered 100% COVID-19 funding.
** These programs were existing programs that received additional COVID-19 funding from one
or more of the laws cited at the beginning of this section or IIJA funding.
Impact of “Higher Risk” Status on Major Program Determination
Type A Program Considerations
A “higher risk” designation will often result in a Type A program or other cluster being audited
as a major program. However, an auditor is not precluded from determining that a “higher risk”
Type A program or other cluster qualifies as a low risk Type A program if both of the following
criteria are met:
1. the program otherwise meets the criteria for a low risk Type A program in section
200.518 of the Uniform Guidance; and
2. the percentage of COVID-19 funding or IIJA funding in the program or other cluster
during the non-federal entity’s fiscal year is not material to the program or other cluster
as a whole. For example, a recipient’s schedule of expenditures of federal awards may
include the Medicaid Cluster but the expenditures relevant to COVID-19 funding
included in the program during the June 30, 2023, fiscal year end is not material.
Alternatively, a recipient’s schedule of expenditures of federal awards may include
Education Stabilization Fund expenditures for the June 30, 2023, fiscal year end, which
would be considered material because COVID-19 funding comprises the entire program.
Note that the inclusion of COVID-19 funding or IIJA funding within the Research &
Development (R&D) cluster does not create a “higher risk” designation for the R&D cluster.
Auditors should prepare audit documentation supporting the risk considerations and conclusions
for “higher risk” programs.
Type B Program Considerations
Under section 200.518 of the Uniform Guidance, in certain circumstances the auditor must
identify Type B programs that are high risk using professional judgment and the criteria in
section 200.519 of the Uniform Guidance, which includes consideration of whether a program
has been identified as “higher risk” by a Federal agency with the concurrence of OMB. Thus,
Compliance Supplement 2023 8-IV-2 Appendix IV
May 2023 Internal Reference Tables
there are no changes to the normal risk assessment process for Type B programs identified as
“higher risk.” That is, the “higher risk” identification must be considered with the other factors in
section 200.519.
Further, the auditor is not required to prioritize the assessment of risk for “higher risk” Type B
programs over other Type B programs.
PROGRAMS WITH “OTHER INFORMATION” IN PART 4
The following is a list of programs in Part 4 that have requirements defined in IV, “Other
Information.” Other Information sections are included to communicate additional information
concerning the program. For example, when a program allows funds to be transferred to another
program, the “Other Information” section provides guidance on how those funds are to be treated
on the Schedule of Expenditures of Federal Awards and in major program determinations. Note
that if the listing is a cluster, all program numbers are shown, but only the primary program
name is presented.
10.551/10.561 Supplemental Nutrition Assistance Program (SNAP)
10.553/10.555/10.556/10.559 School Breakfast Program (SBP)
10.557 Special Supplemental Nutrition Program for Women, Infants,
and Children (WIC)
10.558 Child and Adult Care Food Program (CACFP)
10.760 Water and Waste Disposal Systems for Rural Communities
10.766/10.780 Community Facilities Loans and Grants
11.300/11.307 Investments for Public Works and Economic Development
14.157 Supportive Housing for the Elderly (Section 202)
14.181 Supportive Housing for Persons with Disabilities (Section 811)
14.218/14.225 Community Development Block Grants/Entitlement Grants and
Non-Entitlement Counties in Hawaii
14.228 Community Development Block Grants/State’s Program and
Non-Entitlement Grants in Hawaii
14.239 Home Investment Partnerships Program
14.256 Neighborhood Stabilization Program (Recovery Act Funded)
14.850 Public and Indian Housing
14.862 Indian Community Development Block Grant Program
14.867 Indian Housing Block Grants
14.871/14.879 Section 8 Housing Choice Vouchers
14.872 Public Housing Capital Fund (CFP)
14.873 Native Hawaiian Housing Block Grant
14.881 Moving to Work Demonstration Program
14.888 Lead-based Paint Capital Fund Program and Housing-Related
Hazards Capital Fund
15.022 Tribal Self-Governance
15.025/15.026/15.113/
15.114/15.130 Services to Indian Children, Elderly and Families (477 Cluster)
16.710 Public Safety Partnership and Community Policing Grants
Compliance Supplement 2023 8-IV-3 Appendix IV
May 2023 Internal Reference Tables
17.225 Unemployment Insurance (UI)
17.265 Native American Employment and Training
20.106 Airport Improvement Program
20.223 Transportation Infrastructure Finance and Innovation Act
(TIFIA) Program
21.012 Native Initiatives (New)
21.016 Equitable Sharing Program
21.020 Community Development Financial Institutions Program
21.027 Coronavirus State and Local Fiscal Recovery Funds
66.458/66.482 Capitalization Grants for Clean Water State Revolving Funds
66.468/66.483 Capitalization Grants for Drinking Water State Revolving Funds
81.041 State Energy Program
84.000 Cross-Cutting Section
84.002 Adult Education-Basic Grants to States
84.010 Title I Grants to Local Educational Agencies
84.011 Migrant Education -State Grant Program (Title I, Part C of
ESEA)
84.027/84.173 Special Education-Grants to States (IDEA, Part B)
84.032-G Federal Family Education Loans-(Guaranty Agencies)
84.032-L Federal Family Education Loans-(Lenders)
84.041 Impact Aid (Title VII of ESEA)
84.042/84.044/84.047/
84.066/84.217 Student Support Services
84.048 Career and Technical Education-Basic Grants to States (Perkins
IV)
84.181 Special Education-Grants for Infants and Families
84.282 Charter Schools
84.287 Twenty-First Century Community Learning Centers
84.367 Supporting Effective Instruction State Grants (formerly
Improving Teacher Quality State Grants)
84.424 Student Support and Academic Enrichment Program
84.938 Hurricane Education Recovery
93.044/93.045/93.053 Special Programs for the Aging-Title III, Part B-Grants for
Supportive Services and Senior Centers and CARES Act for
Supportive Services Under Title III-B of the Older Americans
Act
93.095/93.096 HHS Programs for Disaster Relief Appropriations Act-Non-
Construction
93.268 Immunization Cooperative Agreements
93.461 HRSA COVID-19 Uninsured Program
93.498 Provider Relief Fund
93.499 Low-Income Household Water Assistance Program
93.545 Consumer Operated and Oriented Plan (CO-OP) Program
93.558 Temporary Assistance for Needy Families (TANF)
93.566 Refugee and Entrant Assistance—State-Administered Programs
93.569 Community Services Block Grant
Compliance Supplement 2023 8-IV-4 Appendix IV
May 2023 Internal Reference Tables
93.575/93.596/93.489 Child Care and Development Block Grant
93.600/93.356 Head Start
93.667 Social Services Block Grant
93.778/775/777 Medical Assistance Program (Medicaid; Title XIX)
93.959 Block Grants for Prevention and Treatment of Substance Abuse
93.994 Maternal and Child Health Services Block Grant to the States
97.036 Disaster Grants-Public Assistance (Presidentially Declared
Disasters)
97.039 Hazard Mitigation Grant Program (HMGP)
97.067 Homeland Security Grant Program (HSGP)
Part 5.3 also has requirements defined in IV, “Other Information.”
Compliance Supplement 2023 8-IV-5 Appendix IV
May 2023 List of Changes for the 2022 Compliance Supplement
APPENDIX V
LIST OF CHANGES FOR THE 2023 COMPLIANCE SUPPLEMENT
This appendix provides a list of changes from the 2023 Supplement dated May 2023. Please note
that changes in the Matrix of Compliance Requirements are reflected in Part 2 of this supplement
and are not reflected in this appendix.
Table of Contents
The Table of Contents has been updated to show additions and deletions.
Part 1 – Background, Purpose, and Applicability
• Updated for the effective date of Supplement, streamlined language in
Background, Purpose, Applicability and How to Obtain Additional Guidance
sections, included information on the FAC transition and Single Audit Extensions
within the Other Audit Advisories section.
Part 2 – Matrix of Compliance Requirements
• Matrix of Compliance changes and corrections were made for 2023. Changes are
shown in yellow highlights.
Part 3 – Compliance Requirements
• Updated Introduction for the effective date of the Supplement, updated Cash
Management, and included BABAA requirement to Procurement and Suspension
and Debarment.
Part 4 – Agency Program Requirements
Changes were made to the following programs and clusters:
• 10.512-Agriculture Extension at 1890 Land-Grant Institutions Program
• 10.515-Renewable Resources Extension Act (RREA) and National Focus Funds
(RREA-NFF)
• 10.551/10.561-Supplemental Nutrition Assistance Program (SNAP) Cluster
• 10.553/10.555/10.566/10.559/10.582-Child Nutrition Cluster
• 10.606-Food for Progress Program
• 10.607-Section 416(b) Program
• 10.766/10.780-Community Facilities Loans and Grants Cluster
Compliance Supplement 2023 8-V-1 Appendix V
May 2023 List of Changes for the 2022 Compliance Supplement
• 11.300/11.307- Economic Development Cluster
• 11.611-Hollings Manufacturing Extension Partnership (NIST)
• 14.157-Supportive Housing for the Elderly (Section 202)
• 14.182/14.195/14.249/14.856-Section 8 Project-Based Cluster
• 14.269/14.272- Community Development Block Grant-Disaster Recovery Grant
(CDBG-DR) Cluster
• 14.866/14.889- HOPE VI Cluster
• 14.867-Indian Housing Block Grants
• 14.871/14.879- Housing Voucher Cluster
• 14.872-Public Housing Capital Fund (CFP)
• 14.873-Native Hawaiian Housing Block Grant
• 14.881-Moving to Work Demonstration Program
• 14.888-Lead-Based Paint & Housing-Related Hazards
• 15.252-Abandoned Mine Land Reclamation
• 15.605/15.611/15.626-Fish and Wildlife Cluster
• 16.034-Coronavirus Emergency Supplemental Funding
• 16.710-Public Safety Partnership and Community Policing Grants
• 16.738-Edward Byrne Memorial Justice Assistance Grant Program
• 16.922-Equitable Sharing Program
• 17.207/17.801-Employment Service Cluster
• 17.225-Unemployment Insurance (UI)
• 17.235-Senior Community Service Employment Program
• 17.245-Trade Adjustment Assistance
• 17.258/17.259/17.278-WIOA Cluster
• 17.264-National Farmworker Jobs Program
Compliance Supplement 2023 8-V-2 Appendix V
May 2023 List of Changes for the 2022 Compliance Supplement
• 17.265-Native American Employment and Training
• 20.001-Wage Rate Requirements Cross-Cutting Section
• 20.205-Highway Planning and Construction (Federal-Aid Highway Program)
(decoupled program)
• 20.218-Motor Carrier Safety Assistance Program
• 20.219-Recreational Trails Program (decoupled program)
• 20.223-Transportation Infrastructure Finance and Innovation Act (TIFIA)
Program
• 20.224-Federal Lands Access Program (decoupled program)
• 20.315 – National Railroad Passenger Corporation Grants
• 20.327-Railroad Crossing Elimination (new)
• 20.500/20.507/20.525/20.526-Federal Transit Cluster
• 20.509-Formula Grants for Rural Areas
• 20.532-Passenger Ferry Grant Program, Electric or Low Emitting Ferry Pilot
Program, and Ferry Service for Rural Communities Program (new)
• 20.533-All Stations Accessibility Program (new)
• 20.534-Community Project Funding Congressionally Directed Spending (new)
• 20.600/20.611/20.616- Highway Safety Cluster
• 20.708-Natural Gas Distribution Infrastructure Safety and Modernization Grant
Program(new)
• 20.816-Maritime Administration Marine Highway Grant Program
• 20.823-Maritime Administration – Port Infrastructure Development Program
• 21.011 – Capital Magnet Fund (new)
• 21.012 – Native Initiatives (new)
• 21.015-Resources and Ecosystems Sustainability, Tourist Opportunities, and
Revived Economies of the Gulf Coast States (Gulf RESTORE)
• 21.019-Coronavirus Relief Fund
Compliance Supplement 2023 8-V-3 Appendix V
May 2023 List of Changes for the 2022 Compliance Supplement
• 21.020-Community Development Financial Institutions Program
• 21.023 - Emergency Rental Assistance Program
• 21.024 – Rapid Response Program (new)
• 21.025 -Small Dollar Loan Program (new)
• 21.026 - Homeowner Assistance Fund
• 21.027 - Coronavirus State and Local Fiscal Recovery Funds
• 21.029 - Coronavirus Capital Projects Fund Program
• 21.032- Local Assistance and Tribal Consistency Fund (new)
• 23.003-Appalachian Development Highway System (decoupled)
• 32.006-COVID-19 Telehealth Program
• 32.009- Emergency Connectivity Fund Program
• 45.129-Promotion of the Humanities-Federal/State Partnership
• 81.041-State Energy Program
• 81.042-Weatherization Assistance for Low-Income Persons
• 84.000-Cross-Cutting Section
• 84.010-Title I Grants to Local Educational Agencies (Title I, Part A of the ESEA)
• 84.011-Migrant Education-State Grant Program (Title I, Part C of ESEA)
• 84.027/84.173- Special Education Cluster (IDEA)
• 84.041-Impact Aid (Title VII of ESEA)
• 84.048-Career and Technical Education-Basic Grants to States (Perkins V)
• 84.181-Special Education-Grants for Infants and Families
• 84.282-Charter Schools
• 84.365-English Language Acquisition State Grants
• 84.367-Supporting Effective Instruction State Grants (formerly Improving
Teacher Quality State Grants)
Compliance Supplement 2023 8-V-4 Appendix V
May 2023 List of Changes for the 2022 Compliance Supplement
• 84.425-Education Stabilization Fund (ESF)
• 93.044/93.045/93.053-Aging Cluster
• 93.090-Guardianship Assistance
• 93.153-Coordinated Services and Access to Research for Women, Infants,
Children, and Youth (Ryan White HIV/AIDS Program Part D Women, Infants,
Children and Youth WICY Program)
• 93.210-Tribal Self-Governance Program-IHS Compacts/Funding Agreements
• 93.217-Family Planning-Services
• 93.224/93.527-Health Center Program Cluster
• 93.423-Waivers for State Innovation for Section 1332 of the Patient Protection
and Affordable Care Act (PPACA)
• 93.461-HRSA COVID-19 Uninsured Program
• 93.498-Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution
• 93.499 – Low Income Household Water Assistance Program
• 93.545-Consumer Operated and Oriented Plan (CO-OP) Program
• 93.556-Promoting Safe and Stable Families
• 93.558-Temporary Assistance for Needy Families (TANF)
• 93.563-Child Support Enforcement
• 93.566-Refugee and Entrant Assistance-State-Administered Programs
• 93.568-Low-Income Home Energy Assistance
• 93.575/93.596/93.489- Child Care and Development Fund Cluster
• 93.600/93.356-Head Start Cluster
• 93.645-Stephanie Tubbs Jones Child Welfare Services Program
• 93.658-Foster Care-Title IV-E
• 93.659-Adoption Assistance-Title IV-E
• 93.667-Social Services Block Grant
Compliance Supplement 2023 8-V-5 Appendix V
May 2023 List of Changes for the 2022 Compliance Supplement
• 93.671-Family Violence Prevention and Services Act
• 93.686-Ending the HIV Epidemic: A Plan for America
• 93.767-Children’s Health Insurance Program (CHIP)
• 93.778/93.777/93.775-Medical Cluster
• 93.914-HIV Emergency Relief Project Grants (Ryan White HIV/AIDS Program
Part A)
• 93.917-HIV Care Formula Grants (Ryan White HIV/AIDS Program Part B)
• 93.918-Grants to Provide Outpatient Early Intervention Services with Respect to
HIV Disease (Ryan White HIV/AIDS Program Part C)
• 93.958-Block Grants for Community Mental Health Services
• 93.994-Maternal and Child Health Services Block Grant to the States
• 96.001/96.006-Disability Insurance/SSI Cluster
• 97.036-Disaster Grants-Public Assistance (Presidentially Declared Disasters)
• 97.067-Homeland Security Grant Program (HSGP)
Part 5 – Clusters of Programs
• Part 5.1 - No Change.
• Part 5.2 – No Change.
• Part 5.3 – Updated for the effective date of Supplement, changes within Activities
Allowable/Unallowed, Cash Management, Eligibility, Reporting and Special
Tests.
• Part 5.4 – Removed the Highway Planning and Construction Cluster.
Part 6 – Internal Control
• No Change.
Part 7 – Guidance for Auditing Programs Not Included in This Compliance Supplement
• No Change.
Compliance Supplement 2023 8-V-6 Appendix V
May 2023 List of Changes for the 2022 Compliance Supplement
Part 8 – Appendixes
Appendix I – Federal Programs Excluded from the A-102 Common Rule and Portions of
2 CFR Part 200
• No Change.
Appendix II – Federal Agency Codification of Governmentwide Requirements and
Guidance for Grants and Cooperative Agreements
• No Change.
Appendix III – Federal Agency Single Audit, Key Management Liaison, and Program
Contacts
• Updated for this year’s program contacts.
Appendix IV – Internal Reference Tables
• Updated the list of programs currently designated as high risk.
• Updated the list of programs with requirements defined in IV, “Other Information.”
Appendix V – List of Changes for the 2022 Compliance Supplement
• List updated with changes to the programs and appendixes for 2023.
Appendix VI – Program-Specific Audit Guides
• No Changes.
Appendix VII – Other Audit Advisories
• Updated for the effective date of the Supplement, included FAC transition information
and Single Audit Extensions.
Appendix VIII – Examinations of EBT Service Organizations
• No Change.
Appendix IX – Compliance Supplement Core Team
• Updated the list of team members for 2023.
Compliance Supplement 2023 8-V-7 Appendix V
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