Higher Education Institutions get an Automatic Extension for the Single Audit Filing Deadline
By: Dean Dorton | April 20, 2020
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COVID-19 | COVID-19 Industries | Higher Education | Tax
In response to the Novel Coronavirus, (COVID-19), the Office of Management and Budget issued M-20-17, “Memorandum to the Heads of Executive Departments and Agencies” on March 19, 2020. This memorandum expanded the scope of M-20-11“Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19)” that was issued on March 9, 2020. This memorandum provides flexibility to agencies and grant recipients, and provides relief from the requirements under 2 CFR Part 200, Uniform Administrative Requirements, Cost principles and Audit Requirements for Federal Awards.
This memo includes 13 various points and topics, listed below. The last point in the memo notes that awarding agencies should allow recipients and subrecipients that have fiscal year-ends through June 30, 2020, to delay submission of their Single Audit package to six months beyond the normal due date. Utilization of this extension does not compromise the auditee’s ability to qualify as low-risk. If an entity chooses to take advantage of the extension, it should be well documented.
The OMB and Dean Dorton strongly recommend that proper auditable documentation be maintained for any decisions made in response to COVID-19.
Where possible, we are recommending that institutions maintain the same audit timelines to ensure internal control and single audit findings can be corrected on a timely basis.
- Flexibility with System for Award Management (SAM) registration– provides for relaxed requirements around SAM registration and automatic one-item extensions for current registrants.
- Flexibility with Application Deadlines
- Waiver for Notice of Funding Opportunities (NOFOs) Publication– awarding agencies can post funding opportunities for less than 30 days without justification.
- No–cost extensions on expiring awards – to the extent permitted by law, agencies may automatically provide no-cost extension for up to 12-months.
- Abbreviated non-competitive continuation request
- Allowability of salaries and other project activities
- Allowability of Costs not Normally Chargeable to Award
- Prior approval requirement waivers
- Exemption of certain procurement requirements
- Extension of financial, performance, and other reporting – agencies may allow grantees to delay submission of reports up to three months beyond normal due date.
- Extension of currently approved indirect cost rates– agencies may approve requests for one additional year of indirect rate without proposal.
- Extension of closeout– agencies may allow grantee submission closeout reports to be submitted up to one year after the award expires.
- Extension of Single Audit submission– Agencies should allow recipients and subreceipients that have not yet filed their single audits with the Federal Audit Clearinghouse and those that have fiscal year-ends through June 30, 2020, to delay submission of their Single Audit package to six months beyond the normal due date.
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