September 19, 2020

Uniform Guidance Updates for Organizations with Federal Grants

Organizations that receive greater than $750,000 of federal grants are usually subject to additional audit requirements, commonly referred to as a single audit, or Uniform Guidance audit. The federal government’s response to the COVID-19 pandemic has created some new programs and relief packages for non-governmental agencies, and some may now be subject to the single audit requirement. Here are some guidelines and updates for Organizations that receive federal grants:

  • Paycheck Protection Program (PPP) Forgivable Loans administered by the US Small Business Administration do NOT count toward the $750,000 threshold and are NOT subject to the single audit rules.
  • Provider Relief Funds (CFDA 93.498) administered by the US Department of Health and Senior Services are subject to the single audit rules.
  • Economic Injury Disaster Loans (EIDL) administered by the US Small Business Administration are subject to the single audit rules.

The US Office of Management and Budget (“OMB”) which oversees these audits, released the 2020 Compliance Supplement on August 18, 2020. When organizations prepare the schedule of expenditures of federal awards (SEFA), they should separately present “COVID-19 Emergency Act funding”.  The OMB has indicated there will be no new clusters of programs added for Coronavirus Aid, Relief, and Economic Security (CARES) Act programs, however, the final guidance (to be issued in an Addendum) specifically addressing all federal program under the CARES Act is expected to be issued soon.

Finally, the OMB has issued two formal memos addressing single audit due dates and other administrative matters:

The first memo M-20-11, “Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly impacted by the Novel Coronavirus (COVID-19),” provided extensions specifically to  organizations who are receiving funds under H.R. 6074 for coronavirus preparation and response.

On March 19, 2020, the OMB issued memorandum M-20-17. This memo provides extensions more broadly , and applies to organizations with year-ends through June 30, 2020 that have experienced a loss of operational capacity due to the COVID-19 crisis, and have not yet filed Single Audit reports with the Federal Audit Clearinghouse (“FAC”) as of March 19, 2020. The extension allows for delayed submission of the Single Audit reporting package up to six months beyond the original due date (normally the earlier of thirty days after receipt of the auditor’s report, or nine months after the end of the fiscal year).

The Anders Not-for-Profit Group can help you navigate the evolving regulations so you can always stay in compliance. Contact an Anders advisor below to learn more.

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