Single Audits Developments due to COVID 19

by: Smith and Howard

March 21, 2020

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Single Audit Deadline

The U.S. Office of Management and Budget (“OMB”) issued a memo on Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19).  The memo brought some misconceptions regarding the single audit submission deadline.  An extension has been provided; however, it was granted only to certain entities and does not apply to all recipients.

The AICPA issued an alert from the Governmental Audit Quality Center, noting the following:

“We discussed the memo with OMB staff to ensure an appropriate understanding and are providing you with a summary of that discussion to ensure the audit community is aware for purposes of discussions with your clients.”

OMB confirmed the following:

  • The memo is intended to provide guidance to federal agencies relating to areas where relief may be provided to certain recipients.
  • The memo is not instructing federal agencies to provide a blanket waiver for all recipients impacted by COVID-19. Instead, its guidance primarily relates to recipients receiving funds disbursed from the approximately $9 billion in emergency supplemental appropriations for coronavirus preparation and response (H.R.6074). Note that there could be cases where agencies may decide to apply the guidance in the memorandum for existing awards that are deemed by the agency to be for continued research and services necessary to carry out the emergency response relating to COVID-19.
  • Federal agencies are expected to issue their own guidance implementing the provisions of the OMB memo. The Department of Health and Human Services is the primary funder of awards made under H.R. 6074.
  • OMB understands that other recipients that are not receiving H.R.6074 funds may have operations that have been adversely impacted by COVID-19. OMB is working on additional guidance to address these situations, including whether any flexibility will be given on single audit submissions that are late due to these circumstances.

If entities are concerned about meeting the single audit submission deadlines to the Federal Audit Clearinghouse, they should contact the National Single Audit Coordinator at the cognizant or oversight agency for audit. Contacts are listed in Appendix III of the 2019 OMB Compliance Supplement.

Read the AICPA Reponses here.

Department of Education Update on Student Financial Aid.

The Department of Education issued a memo with the subject, Guidance for Interruption of Study Relating to Coronavirus (COVID-19). The memo addresses concerns on how institutions should comply with Title IV, Higher Education Act policies for students impacted by COVID-19.

Read the memo here.

Department of HUD Update

The U.S. Department of Housing and Urban Development (“HUD”) has issued an extension for audit submissions and other waivers for certain for-profit entities under the HUD Consolidated Audit Guide.  A 30-day extension for submissions with a due date of 3/31/20 and 4/30/20 has been granted.

Read the AICPA alert here.

If you have questions related to COVID-19’s impact on single audits please contact Kimberly Bland by completing the contact form below.

Smith and Howard is actively tracking emerging trends around COVID-19.  Please follow Smith and Howard on LinkedIn or Facebook as we will continue to provide updates on developments with the latest information.

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