OMB Provides Relief on Single Audit Due Dates
On March 19, 2020, the U.S. Office of Management and Budget (OMB) released memorandum M-20-17, “Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations.” This memo is addressed to federal agencies and intended to provide administrative relief to federal award recipients affected by loss operational capacity and increased costs due to the COVID-19 crisis.
This is the second memorandum OMB has released providing relief related to COVID-19. M-20-11, “Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19),” issued on March 9, 2020, only provided relief to those recipients who would be receiving federal awards to address the COVID-19 crisis.
The second memo is more comprehensive and instructs that 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).” The memo directs awarding agencies to maintain records on the level of particular exceptions provided to recipients and for several actions further described below, it states that agencies must require recipients to maintain appropriate records and documentation to support certain charges to the federal awards.
Single Audit Extension
The biggest relief in the memo provides a six-month extension of the Single Audit due date for recipients and subrecipients who have not yet filed their single audits with the Federal Audit Clearinghouse as of the date of the issuance of the memorandum that have fiscal year-ends through June 30, 2020. This extension is broad and doesn’t require federal agencies to take further action for the six-month extension to become effective. However, award recipients must keep documentation on file that includes the reasoning for the delayed filing.
M-20-17 also provides relief to federal agencies in other areas, including:
- Flexibility with System for Award Management registration
- Flexibility with application deadlines
- Waiver for Notice of Funding Opportunities publication
- No-cost extensions on expiring awards
- Abbreviated noncompetitive continuation requests
- Allowability of salaries and other project activities
- Allowability of costs not normally chargeable to awards
- Prior approval requirement waivers
- Exemption of certain procurement requirements
- Extension of financial, performance and other reporting
- Extension of currently approved indirect cost rates
- Extension of closeout
Read the full memo for details on these items. The memo acknowledges that many of the operational effects and costs relating to COVID-19 are unknowable at this point, as they will depend on the spread of the virus and response dictated by public health needs. It also states the exceptions are time-limited and will be reassessed by OMB within 90 days of the memo’s issuance.
Stay tuned as further information becomes available. If you have questions about the memorandum or would like to discuss other issues facing your organization, reach out to your BKD Trusted Advisor™ or use the Contact Us form below.