Single audit clarity provided related to pandemic relief programs

By Ken Tysiac

Practitioners who perform single audits have more clarity about requirements and procedures related to two key federal government COVID-19 relief programs, and more information from the Office of Management and Budget (OMB) is expected this month.

OMB issued Addendum No. 1 to the 2021 Compliance Supplement in December. Addendum No. 1 provides new guidance for auditing funds received from the Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) and an update to the Education Stabilization Fund (ESF) program section.

For audits with report dates prior to the issuance of Addendum No. 1 on Dec. 3, 2021, auditors are not required to go back retroactively to review the CSLFRF or the ESF Addendum No. 1 program sections, according to the government webpage that introduces the addendum.

New CSLFRF guidance

According to an AICPA Governmental Audit Quality Center (GAQC) alert issued in December, the new CSLFRF program section in Addendum No. 1:

  • Identifies the compliance requirements subject to audit.
  • Explains that the "beneficiary" concept introduced in the Coronavirus Relief Fund also applies to the CSLFRF.
  • Discusses several issues related to revenue loss, which is a key component of this program.
  • Offers guidance on the amounts to be included on the schedule of expenditures of federal awards for this program.

ESF update

The original release of the 2021 Compliance Supplement included the ESF program. Addendum No. 1 updates Section 1 (elementary and secondary education) of the ESF program section for funding implications from the American Rescue Plan Act (ARPA), P.L. 117-2, specifically funding implications for subprograms 84.425U and 84.425X.

ARPA implications for Section 2 (Higher Education) of the ESF section were addressed in the original release of the ESF program section in the 2021 Compliance Supplement, so Section 2 is not included in Addendum No. 1.

Addendum No. 2

OMB has announced that there will be a second addendum to the 2021 Compliance Supplement. Addendum No. 2 is expected to be issued in January and will address auditing of funds related to:

  • Pandemic Electronic Benefit Transfer (EBT) funds for food benefits and administrative costs;
  • Section 8 Housing Choice Vouchers;
  • National Railroad Passenger Corporation Grants;
  • The Low Income Household Water Assistance Program;
  • Temporary Assistance for Needy Families;
  • The Child Care Development Fund Block Grant.

For the existing programs listed above, the guidance in Addendum No. 2 is expected to primarily address new funding provisions included in ARPA.

For more information on single audit best practices and requirements, visit the GAQC website.

— To comment on this article or to suggest an idea for another article, contact Ken Tysiac at (Kenneth.Tysiac@aicpa-cima.com).

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