**Appendix V**

**List of Changes for the 2004 Compliance Supplement**

This Appendix provides a list of changes from the OMB Circular A-133
Compliance Supplement, issued in March 2003, to this 2004 Supplement.

**Table of Contents**

-   The Table of Contents has been corrected to make the names of the
    following programs consistent with those in the *Catalog of Federal
    Domestic Assistance* and the program entries in Parts 4 and 5 of the
    Supplement.

> 66.458 - Added "Clean Water" to "Capitalization Grants for State
> Revolving Funds" so it reads "Clean Water Capitalization Grants for
> State Revolving Funds"
>
> 84.027 - Added parenthetical reference - (IDEA, Part B)
>
> 84.173 - Added parenthetical reference - (IDEA, Preschool)
>
> 84.318 - Modified title by deleting "(Enhancing Education Through
> Technology Program) and replacing it with (Ed Tech)"
>
> 93.558 - Added parenthetical abbreviation - (TANF)
>
> 84.268 - Changed title to "Federal Direct Student Loans (Direct Loan)"
>
> 93.364 - Corrected title to "Nursing Student Loans (NSL)"
>
> 93.342 - Added parenthetical abbreviation - (HPSL/PCL)

-   The Table of Contents has been changed to include page numbers under
    Part 3, B, "Allowable Costs/Cost Principles," for the beginning of
    the cost principles treatment for each individual OMB cost
    principles circular.

**Part 1 - Background, Purpose, and Applicability**

-   The "Background" section has been updated to recognize the 2003
    changes to OMB Circular A-133 and to include clarifying language
    concerning Parts 4 and 5 of the Supplement.

-   The "Purpose and Applicability" section has been updated for the
    effective date of this Supplement and to include clarifying language
    concerning implementation of the OMB Circulars by Federal agencies.

-   The "Overview of This Supplement" section has been updated to
    include clarifying language concerning the status of agency
    regulatory implementations of the A-102 Common Rule and OMB Circular
    A-110, to modify the period covered by this Supplement, and to
    eliminate the statement about inclusion of references to *Federal
    Register* notices.

-   "How to Obtain Additional Guidance" section has been modified to
    correct the name of the A-102 Common Rule.

**Part 2 - Matrix of Compliance Requirements**

-   Editorial changes have been made to correct software conversion
    errors, spacing and minor errors, and other inconsistencies in
    format.

```{=html}
<!-- -->
```
-   Updated to add and remove programs to make the matrix consistent
    with the Table of Contents, Parts 4 and 5, and applicable
    appendices. For added programs or programs adding compliance
    requirements, the matrix was updated based on the program supplement
    in Part 4. Corrected entries under CFDA 84.186 and the Research and
    Development Cluster.

**Part 3 - Compliance Requirements**

-   Editorial changes have been made throughout Part 3 to correct
    software conversion errors, spacing and minor errors, and other
    inconsistencies in format.

-   The Introduction includes clarifying language concerning the
    relationship of the OMB cost principles circulars to the A-102
    Common Rule and OMB Circular A-110 and Federal agency
    implementation. Statements have been added to the Compliance
    Requirement and Internal Control paragraphs regarding dual-purpose
    testing.

-   A, "Activities Allowed or Unallowed," has been modified to include
    clarifying language concerning the requirements contained in Parts 4
    and 5 of the Supplement.

-   B "Allowable Costs/Cost Principles," has been rewritten to increase
    its utility for auditors. The major changes include the following:

    -   A statement regarding "cognizant agency," as defined in each OMB
        cost principles circular (OMB Circulars A-87, A-21, and A-122)
        has been added to each section.

    -   The guidance under each circular---OMB Circulars A-87, A-21, and
        A-122---has been clarified and significantly expanded to include
        more specific guidance for reviewing direct and indirect costs
        and special compliance requirements.

    -   Guidance under each category includes (i) Compliance
        Requirements,\
        (ii) Audit Objectives, (iii) Suggested Internal Control Audit
        Procedures,\
        (iv) Suggested Compliance Audit Procedures, and (v) Special
        Audit Procedures and/or Compliance Requirements.

    -   The specific guidance for A-87 has been organized to address the
        different types of costs that may be incurred by State, local,
        and Indian tribal governments:

    ```{=html}
    <!-- -->
    ```
    -   State/Local Wide Central Service Costs

    -   State/Local Department or Agency Costs (direct and indirect)

    -   State Public Assistance Agency Costs

        -   The specific guidance for A-21 and A-122 has been organized
            to address the different types of circumstances under which
            indirect costs may be incurred and charged to Federal
            awards.

```{=html}
<!-- -->
```
-   C, "Cash Management," has been modified to update references to 31
    CFR part 205, which implements the Cash Management Improvement Act.

-   Under E.1.b(1), "Eligibility for Individuals - Suggested Audit
    Procedures - Split Eligibility Determination Functions," the word
    "Awards" has been added to "State's Schedule of Expenditures of
    Federal" to correct an omission.

-   In F, "Equipment and Real Property Management," the threshold at
    which equipment disposition requirements apply has been corrected.

-   I, "Procurement and Suspension and Debarment," has been updated to
    incorporate changes to the suspension and debarment common rule
    published November 26, 2003.

-   L, "Reporting," has been updated to delete a reference to Appendix I
    related to entitlement programs. (See Appendix V changes for
    elimination of HHS entitlement programs from the A-102 Common Rule
    exclusions.) This section also has been modified to reflect the fact
    that the reporting formats used by the HHS Payment Management System
    use the abbreviation PSC (for "Program Support Center" of which the
    Division of Payment Management is a component).

-   In M, "Subrecipient Monitoring," language has been added under
    "Compliance Requirements" and "Suggested Audit Procedures -
    Compliance" to clarify the responsibility of pass-through entities
    for subrecipient audits. The subsection on "During-the-Award
    Monitoring" also was revised to more clearly state the recipient's
    responsibilities. This section was updated to reflect the revised
    OMB Circular A-133 audit threshold and changes resulting from the
    revised suspension and debarment common rule published November 26,
    2003.

**Part 4 - Agency Program Requirements**

-   Deleted the following programs:

[Page No.]{.underline}

> **10 Department of Agriculture**
>
> 10.570 Nutrition Service Incentive 4-10.570-1
>
> (Note: Responsibility for this program was transferred by statute to
> the Department of Health and Human Services. The HHS program has been
> added to the Aging Cluster as 93.053.

17. **Department of Labor**

> **84 Department of Education**
>
> 84.278 School-to-Work Opportunities 4-84.278-1
>
> **83 Federal Emergency Management Agency**
>
> 83.543 Individual and Family Grants 4-83.543-1

-   Added the following programs [Page No.]{.underline}

14. **Department of Housing and Urban Development**

> 14.249 Section 8 Mod Rehab Single-Room Occupancy 4-14.182-1
>
> (Added to Section 8 Project-Based Cluster)
>
> **93 Department of Health and Human Services**
>
> 93.053 Nutrition Services Incentive Program 4-93.044-1
>
> (Added to Aging Cluster)
>
> 93.927 Health Centers Grants for Residents of Public Housing
> 4-93.224-1
>
> (Added to Consolidated Health Centers Cluster)

-   Global changes affecting multiple programs - Conformed title of
    section under\
    "Program Procedures," to "Availability of Other Program Information"
    to distinguish it from IV, "Other Information." Changed references
    to financial reporting formats required by HHS Payment Management
    System to PSC-272.

-   Editorial changes to correct software conversion errors, spacing
    errors, minor non-substantive errors, and other inconsistencies in
    format.

-   02.001 --- Updated web site under "Program Procedures - Availability
    of Other Program Information."

-   CFDA 10.500 ~~\--~~ Updated "Program Procedures - Source of
    Governing Requirements." Updated matching requirements in III.G.1.c.
    and d, "Matching - 1862 Land-Grant Institutions in the Insular Areas
    and 1890 Land-Grant Institutions," that became effective on October
    1, 2002 as a result of the Farm Security and Rural Investment Act of
    2002 (FSRIA) (Pub.L. 107-171).

-   CFDA 10.553, 10.555, 10.556, and 10.559 ~~\--~~ Updated web site in
    "Program Procedures - Availability of Other Program Information."

-   CFDA 10.557 ~~\--~~ Updated "Program Procedures" to revise the lists
    of agencies under "Food Benefit Delivery." Updated "III.E.1.
    Eligibility for Individuals," to include proof of identity. Added
    III.N.2, "Special Tests and Provisions - Compliance Investigations
    of High-Risk Vendors."

-   CFDA 10.558 ~~\--~~ Corrected web site address under "Program
    Procedures - Availability of Other Program Information."

-   CFDA 10.566 -- Updated references in III.N.1, "Special Tests and
    Provisions - EBT Reconciliation."

-   CFDA 10.568 and 10.569 -- Updated regulatory citations in III.A,
    "Activities Allowed and Unallowed," and III.G. 3, "Earmarking."
    Clarified\
    III.M, "Subrecipient Monitoring."

-   CFDA 10.760 ~~\--~~ Corrected III.G., "Matching, Earmarking, Level
    of Effort," to include all required headings.

-   CFDA 12.401 - Updated "Program Objectives," to change program
    references and supported activities. Updated "Program Procedures,"
    to change program references and to clarify the requirements related
    to transfers of funds between Army and Air National Guard-supported
    activities. Modified III.A, "Activities Allowed or Unallowed," to
    change program references and update governing requirements.
    Clarified applicability of Davis-Bacon Act under III.D, "Davis-Bacon
    Act."

-   CFDA 14.181 --- Added headings for E.2 and E.3 under III.E,
    "Eligibility."

-   CFDA 14.182, 14.195, 14.249, 14.856 -- Revised "Program
    Objectives,"\
    "Program Procedures - Source of Governing Requirements," III.E.1,
    "Eligibility - Eligibility for Individuals," and III. L.3.c,
    "Reporting - Special Reporting," to incorporate changes for the
    added program~~\--~~CFDA 14.249. Added information about the
    applicability of HUD's Uniform Financial Reporting Standards Rule to
    "Program Procedures."

-   CFDA 14.235 -- Added "Source of Governing Requirements" to "Program
    Procedures."

-   CFDA 14.239 -- Corrected program name in "Program Objectives." In\
    "Program Procedures," updated regulatory citation and corrected
    program name and telephone number.

-   CFDA 14.850 -- Added information about the applicability of HUD's
    Uniform Financial Reporting Standards Rule to "Program Procedures."

-   CFDA 14.854 -- Added citations in "Program Objectives" and "Program
    Procedures." Updated web site in "Program Procedures - Availability
    of Other Program Information." Corrected III.A.2.a, "Activities
    Allowed or Unallowed - Activities Unallowed."

-   CFDA 14.867 -- Added citations in "Program Objectives," "Program
    Procedures," and III.E.1, "Eligibility - Eligibility for
    Individuals." Corrected web site address under "Program Procedures -
    Availability of Other Program Information." Clarified language in
    III.A.2, "Activities Allowed or Unallowed." Corrected performance
    report number in III.L.2, "Reporting - Performance Reporting."

-   CFDA 14.871 -- Added information in "Program Procedures," including
    a CFR citation and information about the applicability of HUD's
    Uniform Financial Reporting Standards Rule. Included a new
    compliance requirement in III.N.6, "Special Tests and Provisions -
    Housing Assistance Payment (HAP)."

-   CFDA 14.872 -- Added information in "Program Procedures" about the
    applicability of HUD's Uniform Financial Reporting Standards Rule.
    Deleted IV, "Other Information," because the information is
    outdated.

-   CFDA 16.710 ~~\--~~ Updated "Program Procedures."

-   CFDA 17.225 ~~\--~~ Revised "Program Objectives" and "Program
    Procedures" to delineate differences among the components of the
    Unemployment Insurance Program and to add web site information in
    "Program Procedures - Availability of Other Program Information."
    Clarified III.E.1, "Eligibility - Eligibility for Individuals"
    Updated and corrected references in III.L.1, "Reporting - Financial
    Reporting."

-   CFDA 17.253 ~~\--~~ Added a new paragraph to III. H, "Period of
    Availability of Federal Funds," to indicate time limits for the WtW
    program.

-   CFDA 17.258, 17.259, 17.260 ~~\--~~ Corrected reference in III.
    E.1.c, "Eligibility for Individuals." Added transfer provision in
    III.G.3, "Matching, Level of Effort, Earmarking - Earmarking" for
    adult and dislocated workers funds. Removed reference to specific
    audit threshold in III.M, "Subrecipient Monitoring."

-   CFDA 20.106 ~~\--~~ Updated citations in "Program Procedures" and
    III.A.2.b, "Activities Allowed or Unallowed."

-   CFDA 20.205 and 23.003 ~~\--~~ Updated "Program Procedures" to
    include an expanded discussion of the Appalachian Development
    Highway System program and add a citation under "Source of Governing
    Requirements." Added a requirement to III.A, "Activities Allowed or
    Unallowed." Clarified III.J, "Program Income," III.N.4, "Special
    Tests and Provisions - Sampling Program," and III.N.6, "Special
    Tests and Provisions - Project Approvals."

-   CFDA 20.500 and 20.507 ~~\--~~ Added a compliance requirement in
    III.G.3, "Matching, Level of Effort, Earmarking - Earmarking."
    Updated III.L.1.a and L.1.b "Reporting - Financial Reporting,"
    specify the means of report submission, and updated III.L.3,
    "Reporting - Special Reporting." Added suggested audit procedures
    under "Special Tests and Provisions" in III.N.2.a, Charter Service
    and III.N.3.a, School Bus Operation."

-   CFDA 20.509 ~~\--~~ Added cross-references under III.A.2,
    "Activities Allowed or Unallowed - Activities Unallowed," to the
    corresponding sections under\
    III.N, "Special Tests and Provisions." Added suggested audit
    procedures under "Special Tests and Provisions" in III.N.1.a,
    Charter Service and N.2.a, School Bus Operation."

-   CFDA 66.458 ~~\--~~ Updated compliance requirement under "Special
    Tests and Provisions" in N.4, CWSRF as Security for Bonds."

-   CFDA 66.468 ~~\--~~ Updated compliance requirements in III. G.1.b.
    "Matching, Level of Effort, Earmarking - Matching," and III.N.4,
    "Special Tests and Provisions - DWSRF as Security for Bonds."

-   CFDA 83.544 ~~\--~~ See 97.036---Program transferred to Department
    of Homeland Security and assigned a new CFDA number. See also
    Appendix VI.

-   CFDA 83.548 ~~\--~~ See 97.039---Program transferred to Department
    of Homeland Security and assigned a new CFDA number. See also
    Appendix VI.

-   84.000 ~~\--~~ Department of Education Cross-Cutting Section ~~\--~~
    Changed names of programs and abbreviations to reflect current
    names. Updated web site in "Program Procedures - Availability of
    Other Program Information." Updated requirements and expanded
    discussion in III.B.2, "Allowable Costs/Cost Principles -
    Documentation of Employee Time and Effort." Added III.D,
    "Davis-Bacon Act." Updated citations in III.G.2.2, "Matching, Level
    of Effort, Earmarking - Level of Effort -- Supplement Not Supplant
    (SEAs/LEAs)," and III.G.3, "Earmarking." Updated III.H, "Period of
    Availability of Federal Funds." Updated compliance requirement
    in III. N.2, "Special Tests and Provisions - Schoolwide Programs."
    Added discussion of information auditors may be required to supply
    to resolve findings in IV, "Other Information."

-   CFDA 84.002 ~~\--~~ Removed the performance report under III.L.2,
    "Reporting - Performance Reporting."

-   CFDA 84.010 -- Updated information in III.E. 1, "Eligibility -
    Eligibility for Individuals," and III.E.2.b, "Eligibility for Group
    of Individuals or Area of Service Delivery." Added a new compliance
    requirement in III.G.3, "Matching, Level of Effort, Earmarking -
    Earmarking." Add two new "Special Tests and Provisions," III. N.4,
    "Quality of Data Relating to Identifying Schools and LEAs for
    Improvement - LEAs," and III.N.5, "Highly Qualified Teachers and
    Paraprofessionals."

-   CFDA 84.011 -- Corrected name of program in title and in "Program
    Objectives." Removed a report in III.L.3.b, "Reporting - Special
    Reporting." Updated III.N.4, "Special Tests and Provisions -
    Priority for Services."

-   CFDA 84.032 -- Updated data elements in III.L.3, "Reporting -
    Special Reporting." In III.N, "Special Tests and Provisions"
    clarified suggested audit procedure under N.7, "Federal Share of
    Borrowed Payments" and, in N.11, "Collection Charges," clarified how
    collection costs could be computed and assessed and when those costs
    could not be assessed the borrower. 

-   CFDA 84.041 ~~\--~~ Updated web site under "Program Procedures -
    Availability of Other Program Information." Changed language in
    III.B, "Allowable Costs/Costs Principles," to be consistent with
    Appendix I.

-   CFDA 84.042, 84.044, 84.047, 84,066, 84.217 -- Updated web site in
    "Program Procedures - Availability of Other Program Information" and
    dollar thresholds in III.E.1.a.(2), "Eligibility - Eligibility for
    Individuals - SSS Program." Corrected program coverage and modified
    reporting requirements in III.L.2.b. and 2.c, "Reporting -
    Performance Reporting."

-   CFDA 84.126 -- Updated citations in III.G.2.1.a, "Matching, Level of
    Effort, Earmarking - Level of Effort - Maintenance of Effort," and
    III.J, "Program Income."

-   CFDA 84.186 -- Deleted III.E, "Eligibility," because none of the
    subsections is applicable to this program.

-   CFDA 84.282 ~~\--~~ Changed references in "Program Objectives,"
    "Program Procedures," III.A, "Activities Allowed or Unallowed,"
    III.E.3, "Eligibility - Eligibility for Subrecipents," and III.G.3,
    "Matching, Level of Effort, Earmarking - Earmarking," to be
    consistent with name of program.

-   CFDA 84.287 -- Updated "Note" that precedes "Program Objectives."
    Added reference to Department of Education Cross-Cutting Section in
    III.G.2, "Matching, Level of Effort, Earmarking - Level of Effort -
    Supplement Not Supplant."

-   CFDA 84.298 -- Updated web site in "Program Procedures -
    Availability of Other Program Information" and updated citations in
    III.A.1.c, "Activities Allowed or Unallowed (SEAs)."

-   CFDA 84.318 -- Changed name of program and updated "Program
    Objectives" and "Program Procedures" to reflect changed name and
    eliminate references to the Improving America's Schools Act (IASA)
    version of the program. Added a web site in "Program Procedures -
    Availability of Other Program Information."\
    Eliminated references to IASA in III.A, "Activities Allowed or
    Unallowed," III.G.3, "Matching, Level of Effort, Earmarking -
    Earmarking," and III.H, "Period of Availability of Federal Funds."
    Updated III.H, "Period of Availability of Federal Funds."

-   CFDA 84.338 -- Added a report to III.L.2, "Reporting - Performance
    Reporting."

-   CFDA 84.357 ~~\--~~ Deleted reference to III.I, "Procurement and
    Suspension and Debarment," because there is no counterpart coverage
    in the ED Cross-Cutting Section.

-   CFDA 84.367 --- Updated web site under "Program Procedures -
    Availability of Other Program Information."

-   All HHS programs (93.xxx) ~~\--~~ Updated III.L.1.d, "Reporting -
    Financial Reporting - SF-272, Federal Cash Transactions Report" to
    change PMS-272 to PSC-272.

-   CFDA 93.044, 93.045, and 93.053 ~~\--~~ Updated "Program Objectives"
    and "Program Procedures" to reflect assumption of responsibility for
    and to describe Nutrition Services Incentive Program. Updated
    "Program Procedures" to better state service exclusion and to add
    "Availability of Other Program Information." In III, "Compliance
    Requirements," updated references to the Older Americans Act. Added
    language to III.A.2, "Activities Allowed or Unallowed - Area
    Agency," and A.3, - "Service Providers," for NSIP. Moved a
    compliance requirement from "Program Procedures" to III.E.3,
    "Eligibility - Eligibility for Subrecipients." Included other
    standard headings in III, "Eligibility." Clarified State earmarking
    requirements under III.G.3, "Matching, Level of Effort, Earmarking -
    Earmarking." Added III.N.1, "Special Tests and Provisions -
    Distribution of Cash" for NSIP. Add IV, "Other Information" to
    address the effect of NSIP on Type A program determinations and
    reporting on the Schedule of Expenditures of Federal Awards.

-   CFDA 93.224, 93.151, 93.246, 93.927 ~~\--~~ Updated "Program
    Objectives" and "Program Procedures." Updated III, "Compliance
    Requirements," to include changes resulting from the Health Care
    Safety Net Amendments of 2002 (Pub. L. 107-251). Those changes
    include a new section, revised language, and revised citations. The
    added section is III.E, "Eligibility, " which includes a requirement
    under E.1, "Eligibility for Individuals," and headings for the other
    components of III.E. The revised language and citations are in
    III.A, "Activities Allowed or Unallowed," III.B, "Allowable
    Costs/Cost Principles," III.J, "Program Income," and III.N.1,
    "Special Tests and Provisions - Governing Board."

-   CFDA 93.556 ~~\--~~ Updated "Program Procedures" for consistency
    with program regulations. Updated III.A, "Activities Allowed or
    Unallowed," to include changes in statutory language. Updated
    III.G.3, "Matching, Level of Effort, Earmarking - Earmarking," to
    include an additional compliance requirement.

-   CFDA 93.558 ~~\--~~ Changed "Program Procedures" to delete reference
    to Appendix I and, under "Availability of Other Program
    Information," to update web site address. Updated III.A, "Activities
    Allowed or Unallowed," to reflect changes in statutory and
    regulatory citations, and to include changes resulting from the
    final rule on Charitable Choice for this program. Updated
    III.G.2.1.a, "Matching, Level of Effort, Earmarking - Level of
    Effort- Maintenance of Effort (MOE)," and added a cross-reference to
    IV, "Other Information," which now includes a discussion of
    Territorial Matching Fund MOE. Updated III.G.3.a, "Matching, Level
    of Effort, Earmarking - Earmarking - Federal Only and Commingled
    Federal/State." Updated III.L.1, "Reporting - Financial Reporting,"
    to clarify financial reporting requirements for States, tribes, and
    territories and to add the reporting form for territories; III.L.2,
    "Reporting - Performance Reporting," to remove outdated information;
    and III.L.3, "Reporting - Special Reporting," to include the new OMB
    approval number. In IV, Other Information," added a discussion of
    territorial spending levels and territorial matching funds.

-   CFDA 93.563 - Updated "Program Procedures - Source of Governing
    Requirements" to incorporate the change resulting from the September
    8, 2003 final rule that made HHS entitlement programs subject to the
    A-102 Common Rule, and its implementation by ACF, and made
    conforming change in III.F, "Equipment and Real Property
    Management." In III.G.1, "Matching, Level of Effort, Earmarking -
    Matching," eliminated the outdated provision regarding enhanced
    funding for computer systems. Updated III.L.1, "Reporting -
    Financial Reporting," to clarify financial reporting requirements
    for States and tribes. Clarified several provisions in "Special
    Tests and Provisions," III.N.1 and III.N.2 "Establishment of
    Paternity and Support Obligations" and "Enforcement of Support
    Obligations," respectively.

-   CFDA 93.566 ~~\--~~ Revised "Program Procedures - Source of
    Governing Requirements" to incorporate the change resulting from the
    September 8, 2003 final rule that made HHS entitlement programs
    subject to the A-102 Common Rule, and its implementation by ACF.

-   CFDA 93.568 ~~\--~~ Updated "Program Procedures - Source of
    Governing Requirements."

-   CFDA 93.569 ~~\--~~ Updated "Program Procedures - Source of
    Governing Requirements," III.A.1, "Activities Allowed or Unallowed -
    Activities Allowed," and III.A.2, "Activities Allowed or Unallowed -
    Activities Unallowed," to include language related to Charitable
    Choice rules for this program. Added "Federal" in III.H, "Period of
    Availability of Federal Funds" to be specific as to applicability of
    these provisions. Added III.N, "Special Test and Provisions," to
    address requirements for subgranting.

-   CFDA 93.600 ~~\--~~ Added language under III.G.3, "Matching, Level
    of Effort, Earmarking - Earmarking," related to validating income
    eligibility under this earmarking requirement as part of the
    initiative to reduce erroneous payments.

-   CFDA 93.645 ~~\--~~ Updated "Program Procedures" for consistency
    with program regulations. Added a requirement under III.G.1,
    "Matching, Level of Effort, Earmarking - Matching." Added a new
    section, III.G.2.1, "Matching, Level of Effort, Earmarking - Level
    of Effort Maintenance of Effort."

-   CFDA 93.658 ~~\--~~ Updated "Program Procedures" to add Puerto Rico.
    Updated "Program Procedures - Source of Governing Requirements" to
    incorporate the change resulting from the September 8, 2003 final
    rule that made HHS entitlement programs subject to the A-102 Common
    Rule, and its implementation by ACF. Made conforming change in
    III.F, "Equipment and Real Property Management." Updated citations
    in III.A.1.c, "Activities Allowed or Unallowed - Activities
    Allowed," and III.E.1.a(2) and c, "Eligibility - Eligibility for
    Individuals."

-   CFDA 93.659 ~~\--~~ Updated "Program Procedures" to add Puerto Rico.
    Updated "Program Procedures - Source of Governing Requirements" to
    incorporate the change resulting from the September 8, 2003 final
    rule that made HHS entitlement programs subject to the A-102 Common
    Rule, and its implementation by ACF. Made conforming change in
    III.F, "Equipment and Real Property Management." Made corrections
    and updated citation in III.A, "Activities Allowed or Unallowed."

-   CFDA 93.667 ~~\--~~ Updated "Program Procedures - Source of
    Governing Requirements."

-   CFDA 93.767 ~~\--~~ Revised "Program Procedures - Source of
    Governing Requirements" to incorporate the change resulting from the
    September 8, 2003 final rule that made HHS entitlement programs
    subject to the A-102 Common Rule, and its implementation by CMS.
    Added provision under III.A, "Activities Allowed or Unallowed,"
    regarding allowable transfers to the Medicaid program for qualifying
    States. Updated III.H, "Period of Availability of Federal Funds," to
    include extended periods of use and to clarify requirements for
    retained and redistributed amounts. Updated III.L.1, "Reporting -
    Financial Reporting," to indicate use of the PSC-272 reports in lieu
    of the SF-272 and to reflect change of organizational acronym from
    HCFA to CMS.

-   CFDA 93.775, 93.777, and 93.778 ~~\--~~ Updated "Program
    Procedures - Source of Governing Requirements," including
    incorporating the change resulting from the September 8, 2003 final
    rule that made HHS entitlement programs subject to the A-102 Common
    Rule, and its implementation by CMS. Updated web site addresses in
    "Program Procedures - Availability of Other Program Information,"
    and in III.A.6, "Activities Allowed or Unallowed - Home and
    Community-Based Services." Deleted reference to section 1915 of the
    Social Security Act in III.A.3 (and in III.N.6) in relation to
    managed care. Updated III.L.1, "Reporting - Financial Reporting," to
    indicate use of the PSC-272 reports in lieu of the SF-272. Added IV,
    "Other Information," to specify treatment of funds that may be
    transferred from CFDA 93.767 for expenditure under CFDA 93.778.

-   CFDA. 93.958 ~~\--~~ Corrected "Program Objectives." Under "Program
    Procedures," added "Availability of Other Program Information" and
    included reference to *Federal Register* notice that details
    approval requirements for non-recurring expense exclusions from
    maintenance-of-effort calculations and cross-reference in
    III.G.2.1.a, "Matching, Level of Effort, Earmarking - Level of
    Effort-Maintenance of Effort." Updated Program Procedures - Source
    of Governing Requirements."

-   CFDA 93.959 ~~\--~~ Updated "Program Procedures." Under "Program
    Procedures," added "Availability of Other Program Information" and
    included reference to *Federal Register* notice that details
    approval requirements for non-recurring expense exclusions from
    maintenance-of-effort calculations. In III.A.9, "Activities Allowed
    or Unallowed," added language to reflect final Charitable Choice
    rules for this program. In III.G.2.1.a, "Level of Effort-Maintenance
    of Effort," included a cross-reference to the *Federal Register*
    notice cited in "Availability of Other Program Information;" in
    G.2.1. added "Maintenance of Effort" to correct heading; and
    modified headings to include all required sections under "Level of
    Effort." Deleted introductory language in III.G.3.a, "Matching,
    Level of Effort, Earmarking - Earmarking."

-   CFDA 93.991 ~~\--~~ Updated "Program Procedures - Source of
    Governing Requirements," and added "Program Procedures -
    Availability of Other Program Information."

-   CFDA 93.994 ~~\--~~ Updated "Program Procedures - Source of
    Governing Requirements."

-   CFDA 94.006 ~~\--~~ Updated III.E.1, "Eligibility - Eligibility for
    Individuals," to add the 2004-2005 limits on living allowances and
    delete outdated information.

-   CFDA 94.011 and 94.016 - Under III.E.1, "Eligibility - Eligibility
    for Individuals," updated citation for *Federal Register* notice
    showing income-eligibility levels.

-   CFDA 97.036 (previously CFDA 83.544) ~~\--~~ Updated CFDA Number and
    header to show responsible agency as Department of Homeland Security
    (DHS). Updated "Program Procedures" to reflect FEMA as part of DHS
    and to include current- and prior-year threshold amounts for
    distinguishing "small" and "large" project grants. Added IV, "Other
    Information" to explain changes resulting from creation of
    Department of Homeland Security.

-   CFDA 97.039 (previously CFDA 83.548) ~~\--~~ Updated CFDA Number and
    header to show responsible agency as Department of Homeland Security
    (DHS). Updated "Program Procedures" to reflect FEMA as part of DHS
    and, under "Availability of Other Program Information," to provide
    more complete Internet addresses. Added IV, "Other Information" to
    explain changes resulting from creation of Department of Homeland
    Security.

**Part 5 - Clusters of Programs**

-   In the title and where applicable, deleted use of abbreviation FDL
    in conjunction with CFDA 84.268 and replaced with (Direct Loan) and
    conformed program name to "Federal Direct Student Loans."

```{=html}
<!-- -->
```
-   In "Program Procedures," corrected name of FSEOG program and, under
    the Federal Direct Loan program, updated Common Origination and
    Disbursement system to the Loan Origination Center.

-   Under III.A., "Activities Allowed or Unallowed," specified criteria
    for adding programs without ED approval.

-   Under III.C, "Cash Management," updated and changed wording for
    clarity.

-   Under III.E.1, "Eligibility - Eligibility for Individuals," added
    introductory material concerning the Institutional Student
    Information Record (ISIR) and the Student Aid Report (SAR). In that
    same section, under "Calculation of Benefits," language moved for
    emphasis and clarified. Under PLUS loans, language added to clarify
    parent eligibility.

-   Under III.L. 1.e, "Reporting - Financial Reporting," deleted
    language applicable to prior fiscal year and updated to indicate
    that "just-in-time" method is no longer a pilot program.

-   In III.N.2, "Special Tests and Provisions - Verification,"
    elaborated on statement of compliance requirement included in the
    *Federal Register*. Added language to "Suggested Audit Procedures"
    to clarify the procedures to be performed.

-   In III.N.3, "Special Tests and Provisions - Disbursements To or On
    Behalf of Students-Compliance Requirement," added language based on
    changes in a November 1, 2002 *Federal Register* notice that became
    effective July 1, 2003. Deleted language relating to the exemption,
    which expired and was not renewed, and to other outdated
    requirements and language. For FWS, added another method of paying
    the student that was not previously listed. In III. N.2, "Special
    Tests and Provisions - Disbursements To or On Behalf of
    Students-Suggested Audit Procedures," added procedure to ensure that
    disbursement amounts and dates are accurate and properly recorded.

-   In III.N.4, "Special Tests and Provisions - Return of Title IV Funds
    Compliance Requirements," made changes consistent with November 1,
    2002 *Federal Register*. Conformed and clarified "Suggested Audit
    Procedures."

-   In III.N.5, "Special Tests and Provisions - Student Status Changes,"
    clarified statement of existing compliance requirement and deleted
    requirements related to HEAL.

-   In III.N, "Special Tests and Provisions," added a new N.7,
    "Transcripts for Borrower's in Default" applicable to the HEAL
    program.

-   In III.N.9, "Special Tests and Provisions - Borrower Data
    Transmission and Reconciliation (FDL)," renumbered and updated for
    Common Origination and Disbursement, deleted outdated information,
    and updated web site.

-   In III.N.10, "Special Tests and Provisions - Institutional
    Eligibility," renumbered and rewrote section on commissions and
    bonuses due to new regulations effective July 1, 2003; added
    clarifying language to describe the process so an auditor would know
    how the institution is notified of the "zone alternative; "added the
    existing requirement for satisfactory progress. Conformed "Suggested
    Audit Procedures."

-   Appendix A - Add clarifying language for Items 3, 6, 8, 17, and 20.
    Added Item 12, which is not a new requirement, but has been
    inadvertently omitted since the requirement was enacted into the
    Higher Education Act Reauthorization in 1992.

```{=html}
<!-- -->
```
-   Updated list of other clusters for programs included in this
    Supplement.

-   Corrected cluster titles where they differed from those used in Part
    4 (or conversely, where appropriate, changed the Part 4 name to
    match that used in this listing).

**Part 6 - Internal Control**

-   Editorial changes have been made to correct software conversion
    errors, spacing and other minor errors, and other inconsistencies in
    format.

-   In I, "Procurement and Suspension and Debarment," the title has been
    corrected and the section has been updated to incorporate changes to
    the suspension and debarment common rule published in the *Federal
    Register* on November 26, 2003.

**Part 7 - Guidance for Auditing Programs Not Included in This
Compliance Supplement**

-   Editorial changes have been made to correct software conversion
    errors, spacing and other minor errors, and other inconsistencies in
    format.

-   Under the discussion of Compliance Requirements, I, "Procurement and
    Suspension and Debarment," and L, "Reporting," have been revised to
    clarify their applicability.

**Appendix I - Federal Programs Excluded from the A-102 Common Rule**

-   This Appendix has been revised based on a Department of Health and
    Human Services (HHS) rule, issued September 8, 2003 (68 FR
    52843-52844), that makes the HHS entitlement programs subject to the
    A-102 Common Rule (in lieu of 45 CFR Part 74). It also has been
    updated to delete Department of Education (ED) programs no longer
    excluded from the A-102 Common Rule (CFDA 84.010 and CFDA 84.298)
    and to update the citations for the remaining ED program (CFDA
    84.041).

**Appendix II - Federal Agency Codification of Certain Governmentwide
Grant**

**Requirements**

-   This Appendix has been modified to indicate that the Federal
    Emergency Management Agency (FEMA) is no longer an independent
    agency and to add the Department of Homeland Security. The
    components of DHS will continue to use their existing
    implementations, e.g., FEMA's 44 CFR part 13, until DHS issues a
    department-wide implementation of A-110 and the common rules.

**Appendix III - Federal Agency Contacts for A-133 Audits**

-   This Appendix has been modified to indicate that the Federal
    Emergency Management Agency (FEMA) is no longer an independent
    agency, to add the Department of Homeland Security, and to update
    responsible offices and related information, as appropriate.

**Appendix IV - Internal Reference Tables**

-   Updated tables for changes in this Supplement.

**Appendix V - List of Changes for the 2004 Compliance Supplement**

-   Updated this appendix to provide a list of changes from the OMB
    Circular A‑133 Compliance Supplement issued in March 2003 to this
    2004 Supplement.

**Appendix VI - Department of Homeland Security and the Compliance
Supplement**

-   Added a new appendix to address the effect of the creation of the
    Department of Homeland Security on the Supplement.

**Appendix VII - Other OMB Circular A-133 Advisories**

-   Appendix renumbered; however, no substantive changes made.

**Appendix VIII - SAS 70 Examinations of EBT Service Organizations**

-   Appendix renumbered; however, no substantive changes made.

**Appendix IX - Compliance Supplement Core Team**

-   Appendix renumbered and updated to recognize contributions of
    current interagency team responsible for the production of this
    Supplement.