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Update Regarding Entities that Receive Federal Funds

7/2/20 – Stephanie Allgeyer

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On June 23, 2020, the Governmental Audit Quality Center (GAQC) issued Alert 409 which included information about the Office of Management and Budget (OMB) issued Memorandum M-20-26. A summary of that Alert is included below.

Exhausting Other Funding Sources

The memo states that an awarding agency must inform its’ recipients to exhaust other available funding sources (including any Payroll Protection Program funds) to sustain its workforce and to save overall operational costs during the pandemic period. This will allow federal funds to be preserved for any ramp-up efforts that may occur. As a reminder from previous communications, special attention should be paid regarding double dipping.  Double dipping is not permitted.

Federal Audit Clearinghouse – Changes to Submission Extensions

In a previous memo from the OMB, a blanket six-month extension was issued for entities (fiscal year-ends through June 3, 2020) that had not filed their single audits with the Federal Audit Clearinghouse (FAC).  The new memo has made changes to the previous extensions noted.

The six-month extension continues for single audits not yet submitted on March 19, 2020 for normal due dates from March 30, 2020 through June 30, 2020 (Ex. June 30, 2019 year-ends through September 30, 2019 year-ends).

The extension for single audits with normal due dates, those from July 31, 2020 through September 30, 2020 (Ex. October 31, 2019 year-ends through December 31, 2019 year ends), has been reduced to three months.

The previous extension for single audits for year-ends after December 31, 2019 and through June 30, 2020 year-ends has been rescinded (Ex. January 31, 2020 year ends through June 30, 2020 year ends). These audits will now have to be submitted to the FAC within normal due dates.

As a reminder, organizations that take advantage of the extension can still qualify as a low-risk auditee. No further action by agencies is required to enact the extensions or seek approval, however, organizations should maintain documentation of the reason for delayed filing.

For any questions connected to this update or related guidance in general, contact VonLehman’s Nonprofit and Government Group leader, Stephanie Allgeyer, at sallgeyer@vlcpa.com or 800.887.0437.