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 

ActivitiesAllowed orUnallowedAllowableCosts/CostPrinciplesCashManagementEligibilityEquipment and Real PropertyManagementMatching,Level of Effort,EarmarkingPeriodOfPerformanceProcurement and Suspension and DebarmentProgramIncomeReportingSubrecipientMonitoringSpecialTests andProvisions 

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 factspecific 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 

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 

All audits 

Department of Veterans Affairs 

Director 

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 

All audits 

Agency for International Development 

USAID 

Attn: OIG/A/FA 

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)

For audits of all US based 

not-for-profit organizations 

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 

Seanne Weekes 

Samantha.cole@usda.gov 

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 

Services 

Robin Aldridge 

Leticia Adu 

Robin.Aldridge@hhs.gov 

Leticia.Adu@hhs.gov 

Department of Homeland Security Michael Pellegrino Michael.Pellegrino@HQ.DHS.GOV 

Department of Housing and Urban 

Development 

Shannon E. Steinbauer Shannon.E.Steinbauer@hud.gov 

Department of the Interior Eunice Pierre eunice_pierre@ios.doi.gov 

Department of Justice Linda Taylor 

Jeff A. Haley 

Linda.Taylor2@usdoj.gov 

Jeff.Haley@usdoj.gov 

Department of Labor Anita Robinson 

Latonya Torrence 

Robinson.Anita@dol.gov 

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 

Community Service 

Edris Shah eshah@cns.gov 

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 

Council 

Steve Sigler Steve.sigler@restorethegulf.gov 

Institute for Museum and Library 

Services 

Connie Cox Bodner CBodner@imls.gov 

National Aeronautics and Space 

Administration 

Antanese Crank antanese.n.crank@nasa.gov 

National Archives and Records 

Administration 

Christopher Eck Christopher.Eck@nara.gov 

National Endowment for the Arts Breanna Berger bergerb@arts.gov 

National Endowment for the 

Humanities 

Laura Davis ldavis@neh.gov 

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 

Development 

David McNeil dmcneil@usaid.gov 

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 

Listing 

Agency Contact(s) E-Mail Address Telephone 

Number 

Maritime Administration 

(MARAD) 

John Desch 

Senior Contract Specialist, 

(MARAD) 

John.Desch@dot.gov 

202-366-4356

21 Department of the Treasury 

(TREAS) 

21.015 

21.020 

Troyling Harris 

Chief Compliance Officer 

troyling.harris@treasury.gov 202-927-8096

21.016 Siporah Jackson Siporah.Jackson@treasury.gov 202-374-1813

21.019 Nasr Fahmy, Single Audit 

Advisor 

Nasr.Fahmy@treasury.gov (202) 527-4036

21.023 Nasr Fahmy, Single Audit 

Advisor 

Nasr.Fahmy@treasury.gov (202) 527-4036

21.026 Nasr Fahmy, Single Audit 

Advisor 

Nasr.Fahmy@treasury.gov (202) 527-4036

21.027 Nasr Fahmy, Single Audit 

Advisor 

Nasr.Fahmy@treasury.gov (202) 527-4036

21.029 Nasr Fahmy, Single Audit 

Advisor 

Nasr.Fahmy@treasury.gov (202) 527-4036

21.032 Nasr Fahmy, Single Audit 

Advisor 

Nasr.Fahmy@treasury.gov (202) 527-4036

32 Federal Communications 

Commission 

32.006 

32.009 

Sheela Kailasanath Sheela.Kailasanath@fcc.gov 202-418-0938

45 National Endowment for the 

Humanities (NEH) 

45.129 Karen Kenton 

Director 

kkenton@neh.gov 202-606-8307

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) 

Number 

Title 

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 

17.265 

20.106 

20.223 

21.012 

21.016 

21.020 

21.027 

66.458/66.482 

66.468/66.483 

81.041 

84.000 

84.002 

84.010 

84.011 

84.027/84.173 

84.032-G 

84.032-L 

84.041 

84.042/84.044/84.047/ 

84.066/84.217 

84.048 

84.181 

84.282 

84.287 

84.367 

84.424 

84.938 

93.044/93.045/93.053 

93.095/93.096 

93.268 

93.461 

93.498 

93.499 

93.545 

93.558 

93.566 

93.569 

Unemployment Insurance (UI) 

Native American Employment and Training 

Airport Improvement Program 

Transportation Infrastructure Finance and Innovation Act 

(TIFIA) Program 

Native Initiatives (New) 

Equitable Sharing Program 

Community Development Financial Institutions Program 

Coronavirus State and Local Fiscal Recovery Funds 

Capitalization Grants for Clean Water State Revolving Funds 

Capitalization Grants for Drinking Water State Revolving Funds 

State Energy Program 

Cross-Cutting Section 

Adult Education-Basic Grants to States 

Title I Grants to Local Educational Agencies 

Migrant Education -State Grant Program (Title I, Part C of 

ESEA) 

Special Education-Grants to States (IDEA, Part B) 

Federal Family Education Loans-(Guaranty Agencies) 

Federal Family Education Loans-(Lenders) 

Impact Aid (Title VII of ESEA) 

Student Support Services 

Career and Technical Education-Basic Grants to States (Perkins 

IV) 

Special Education-Grants for Infants and Families 

Charter Schools 

Twenty-First Century Community Learning Centers 

Supporting Effective Instruction State Grants (formerly 

Improving Teacher Quality State Grants) 

Student Support and Academic Enrichment Program 

Hurricane Education Recovery 

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 

HHS Programs for Disaster Relief Appropriations Act-NonConstruction 

Immunization Cooperative Agreements 

HRSA COVID-19 Uninsured Program 

Provider Relief Fund 

Low-Income Household Water Assistance Program 

Consumer Operated and Oriented Plan (CO-OP) Program 

Temporary Assistance for Needy Families (TANF) 

Refugee and Entrant Assistance—State-Administered Programs 

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