The US Office of Management and Budget (OMB) released memorandum M-20-17 on March 19, Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations.
This memorandum is addressed to federal awarding agencies and instructs that the federal awarding agencies are authorized to take certain actions, as they deem appropriate and to the extent permitted by law, with respect to the administrative provisions that apply to recipients affected by COVID-19 (for both recipients with COVID-19 related grants and other types of federal grants).
Amongst other things, the memorandum allows a 6-month extension of Single Audit submissions. The memorandum states the following:
Awarding agencies, in their capacity as cognizant or oversight agencies for audit, should allow recipients and subrecipients that have not yet filed their single audits with the Federal Audit Clearinghouse as of the date of the issuance of this memorandum that have fiscal year-ends through June 30, 2020, to delay the completion and submission of the Single Audit reporting package, as required under Subpart F of 2 CFR § 200.501 -Audit Requirements, to six (6) months beyond the normal due date. No further action by awarding agencies is required to enact this extension. This extension does not require individual recipients and subrecipients to seek approval for the extension by the cognizant or oversight agency for audit; however, recipients and subrecipients should maintain documentation of the reason for the delayed filing. Recipients and subrecipients taking advantage of this extension would still qualify as a “low-risk auditee” under the criteria of 2 CFR § 200.520 (a) – Criteria for a low-risk auditee.
As noted, there is no further action required of the awarding agencies for the 6-month extension to become effective. However, Organizations should be mindful of the requirement to maintain documentation on file that includes the reasons for the delayed filing.
If you have any questions, please contact us.