On March 19, 2020, the Office of Management and Budget (OMB) issued a memorandum, M-20-17, providing further guidance on areas of administrative relief for recipients and applicants of federal financial assistance directly impacted by COVID-19 due to loss of operations. The memorandum provides short-term relief for administrative, financial management, and audit requirements under 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, without compromising federal financial assistance accountability requirements.
The memorandum provides agencies with authorization to take certain actions, including flexibility with application deadlines, ability to allow recipients to charge costs not normally chargeable to federal awards, ability to waive certain procurement requirements, and the ability to grant extensions of financial, performance, and other reporting requirements.
Among the administrative relief exceptions provided in the memorandum is a six-month extension for single audit submissions.
Among the administrative relief exceptions provided in the memorandum is a six-month extension for single audit submissions. The extension applies to any audit that hasn’t been filed as of March 19, 2020, and will include all entities with fiscal year-ends through June 30, 2020. The memo states that individual recipients and subrecipients aren’t required to seek approval for the extension but should maintain documentation that includes the reasons for the delayed filing. The extension will not impact the entity’s ability to be considered a low-risk auditee.
Key considerations related to the single audit filing exception:
- Use this delay only as a last resort. If you can continue with a scheduled audit, albeit remotely, moving forward will allow you to focus on other priorities and prevent your organization having to go through two audits in one year.
- If a delay is necessary, it’s critical that you maintain documentation that includes the reasons for the delayed filing.
Single audit submission extended due dates:
|Nonfederal entity year-end||Initial due date||Extended due date|
|June 30, 2019||March 31, 2020||Sept. 30, 2020|
|Sept. 30, 2019||June 30, 2020||Dec. 31, 2020|
|Dec. 31, 2019||Sept. 30, 2020||March 31, 2021|
|March 31, 2020||Dec. 31, 2020||June 30, 2021|
|June 30, 2020||March 31, 2021||Sept. 30, 2021|
We encourage you to read the memorandum, M-20-17, in its entirety to gain a thorough understanding. If you have any questions about the administrative relief, please reach out to us.