Deadline for certain single audits delayed because of pandemic

By Ken Tysiac

The due date for certain single audits to be submitted to the Federal Audit Clearinghouse has been delayed six months as a result of challenges related to the coronavirus pandemic.

The Office of Management and Budget (OMB) announced the extension in a memorandum for the heads of executive departments and agencies issued this week.

The memorandum states that awarding agencies should allow recipients and subrecipients with fiscal year ends through June 30, 2021, that have not yet filed their single audits with the Federal Audit Clearinghouse to delay the completion and submission of the single audit reporting package to six months beyond the normal due date.

Awarding agencies don’t need to take further action to enact the extension.

Recipients and subrecipients don’t need to seek approval for the extension, but they should maintain documentation of the reason for the delayed filing.

The memo also requires:

  • Agencies to perform a risk analysis of American Rescue Plan Act, P.L. 117-2, programs and request OMB to designate any higher-risk programs as single audit programs that must be tested in a particular year.
  • The Uniform Guidance to be applied to federal financial assistance funded through the American Rescue Plan Act to the maximum extent authorized by law. This includes financial awards to for-profit organizations. The memo states that agencies should consider whether single audit or some other audit is most appropriate for for-profit entities.
  • Agencies to submit their proposed implementation of the Uniform Guidance to the OMB for approval prior to program administration and award issuance.

New HEERF guidance

Meanwhile, the U.S. Department of Education posted guidance this week that answers questions grant recipients and auditors have been asking related to the Higher Education Emergency Relief Fund. The guidance includes an FAQ document on calculating lost revenue, and a notice of interpretation of award dates.

For more information on these and other government auditing developments related to the coronavirus pandemic, see the AICPA Governmental Audit Quality Center’s latest alert.

Ken Tysiac (Kenneth.Tysiac@aicpa-cima.com) is the JofA’s editorial director.

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