In the Office of Management and Budget (OMB) Memo M-21-20, dated March 19, 2021, a new six-month extension to the Single Audit submission deadline was granted to all recipients and subrecipients with fiscal year-ends through June 30, 2021, effective immediately.
This deadline extension applies to any recipients/subrecipients that have yet to submit their Single Audits to the Federal Audit Clearinghouse. There is no requirement to obtain approval from awarding agencies for the extension, though recipients and subrecipients should maintain documentation why they are filing past the original deadline. Importantly, the requirement that Single Audits be submitted within 30 calendar days after receipt of the auditor’s report still applies.
The table below summarizes the extended deadlines for various fiscal year-ends:
|Fiscal Year-End ||Original Deadline ||Extended Deadline |
|6/30/2020 ||3/31/2021 ||9/30/2021 |
|9/30/2020 ||6/30/2021 ||12/31/2021 |
|12/31/2020 ||9/30/2021 ||3/31/2022 |
|3/31/2021 ||12/31/2021 ||6/30/2022 |
|6/30/2021 ||3/31/2022 ||9/30/2022 |
OMB Memo M-21-20 also addresses certain implications of the American Rescue Plan Act of 2021 (ARPA) for awarding agencies and recipients/subrecipients. ARPA was signed into law on March 11, 2021 and is a $1.9 trillion stimulus bill that is intended to assist in the economic recovery from the COVID-19 pandemic. ARPA builds upon measures that were included in the Coronavirus Aid, Relief, and Economic Security (CARES) Act from March 2020 and the Consolidated Appropriations Act of 2021 from December 2020. OMB Memo M-21-20 specifies that the Uniform Guidance (Title 2 Part 200 of the Code of Federal Regulations) should be applied to ARPA federal financial assistance and that awarding and oversight agencies shall provide the highest level of integrity in the management of ARPA funds. In addition to not-for-profit and state/local governmental entities, OMB Memo M-21-20 directs agencies to apply the provisions of the Uniform Guidance to for-profit recipients of ARPA funding to the extent authorized by law, with limited exceptions. This indicates that many for-profit recipients/subrecipients could have audit requirements attached to the awards.
Other Updates on COVID-19 Relief and the Impact on Audits
Several other notable updates occurred in March from the U.S. Small Business Administration on Shuttered Venue Operating Grants (SVOGs) and the Department of Education on the second round of Higher Education Emergency Relief Funds (HEERF II).
The SBA will provide assistance to governments, non-profits and for-profits, such as movie theaters, museums and zoos, through SVOGs beginning in the second quarter of 2021. Entities using more than $750,000 in federal funding in one fiscal year through the program are subject to audit. FAQ Application #17 of the SBA’s updated FAQ document on SVOGs clarifies that for-profit grantees above the $750,000 threshold have the option of either conducting a Single Audit or a financial audit in accordance with Government Auditing Standards for the fiscal year during the audit period. The option is not available to non-profits.
Also on March 19, 2021, the “New HEERF Guidance on Expenses Through the Pandemic and Calculating Lost Revenue” document was released by the Department of Education to address questions about HEERF II. HEERF II was authorized by the Coronavirus Response and Relief Supplemental Appropriations Act of 2021 (CRRSAA), Public Law 116-260, to provide funds for educational institutions. The new guidance document includes FAQs on how to calculate lost revenue as well as a letter that addresses grant audit requirements and examples of acceptable evidence of compliance for the Department of Education’s public reporting requirements.
For more information or questions about how the ARPA, SVOGs or HEERF II may impact your organization, please reach out to us at firstname.lastname@example.org.