OMB Issues Amended Guidance for Single Audits

The Office of Management and Budget (OMB) issued a Compliance Supplement Addendum in December 2020 related to guidance for COVID-19 programs. This Addendum must be used in conjunction with the August 2020 Compliance Supplement in performing single audits.

The primary objective of this Addendum is to answer questions related to new COVID-19 funding compliance requirements and suggested audit procedures. Example guidance includes the following, among others. Refer to the complete Addendum for full guidance.

• A matrix of compliance requirements identifies what is subject to audit for all new programs and any existing programs included in the Addendum, assuming the auditor determines the requirement to be direct and material to the program. If an existing program is affected by COVID-19 and it is not included in the Addendum, refer to Appendix VII of the 2020 Compliance Supplement for more guidance.  
• Provider Relief Fund (PRF) expenditures and lost revenue will not be included in the Schedule of Expenditures and Federal Awards (SEFA) until December 31, 2020 year-ends and thereafter.
• The fair market value of donated personal protective equipment (PPE) should be included at the time of receipt in a stand-alone footnote (marked “unaudited”) in the SEFA. Auditors should not include this amount when determining single audit and major program thresholds. 

Because this guidance was issued late in the year, the OMB is providing a three-month audit submission extension for single audits of 2020 year-ends through September 30, 2020 (but only if the grant recipients received some form of COVID-19 funding). For example, a June 30, 2020 year-end single audit would normally be due on March 21, 2021. Now it would be due on June 30, 2021. Note that there is no extension available for December 31, 2020 year-ends.  Pre-approval is not required for qualifying recipients or subrecipients to take advantage of this extension, but adequate documentation of the reason for delayed filings should be retained. 

The content contained in this article is for informational purposes only and is not tax advice. You should consult a tax advisor for advice applicable to your situation.

Jennifer has more than 25 years of experience in designing high-quality training programs in a variety of technical and “soft-skills” topics necessary for professional and organizational success. In 2003, she founded Emergent Solutions Group, LLC, where she focuses on designing and delivering practical and engaging accounting and auditing training. Jennifer started her career in audit for Deloitte & Touche. She graduated summa cum laude from Marymount University with a B.B.A. in Accounting.