Yet another deadline has been extended due to COVID-19; this time, the due date to submit certain Single Audits has been pushed back by six months. The extension affects recipients and sub-recipients with fiscal year-ends through June 30, 2021. This will be welcome news for the many organizations and healthcare entities subjected to Single Audits for the first time, or for organizations that are simply struggling to keep up with changing laws and guidelines.
Single Audit Requirements
Single Audits are a separate and distinct compliance requirement from traditional audits, reviews, or compilations. Organizations that regularly accept federal funds in excess of $750,000 per year are already aware of this; many more organizations are not. Trillions of dollars in COVID-19 relief funding means that more organizations will be subject to Single Audit requirements for 2020 and 2021. The CARES Act alone authorized more than 15 federal grants, and more funding has since become available.
If an organization spends more than $750,000 annually from federal funds, whether those funds are received directly or indirectly, it is subject to a Single Audit. See our former post for guidance on what a Single Audit is and how to tell if funding is indeed federal.
About the Delay
The Office of Management and Budget (OMB) issued a memo in March 2021 alerting agencies that award federal funding of the extension. Among other items, the memo encouraged federal agencies to provide organizations with flexibility in financial and program impact reporting, to the extent possible.
Changes in due dates for Single Audits are reflected below.
- June 30, 2020 year-end Single Audit normally due March 31, 2021
- December 31, 2020 year-end Single Audit normally due September 30, 2021
Deadline pushed back to September 30, 2021
Deadline pushed back to March 31, 2022
The extension is automatic, but recipient organizations still need to maintain appropriate documentation supporting the reason for taking the delayed deadline. An organization’s ability to receive federal funding is not tied to the extension, meaning taking the extension won’t impact federal financial awards.
Organizations are still required to submit the Single Audit reporting package Federal Audit Clearinghouse within 30 days of receiving the auditor’s report.
Despite the extension, if organizations can file their Single Audit sooner, it is better to submit it than to wait. Keep in mind that in 2020, the OMB also issued a six-month extension of due dates, that it later revised to three months for certain year-ends.