The long awaited 2020 OMB Compliance Supplement addendum was released in December 2020. This addendum is to be used in conjunction with the 2020 Compliance Supplement, released in August 2020. This article summarizes the key aspects of the recently released addendum.
The addendum includes a matrix that covers 15 programs, of which the majority relate to COVID-19 programs, whether new programs, or existing programs that incurred changes as a result of COVID-19. COVID-19 programs in the matrix include but are not limited to: Coronavirus Relief Fund through the Department of the Treasury, Provider Relief Fund through the Department of Health and Human Services and the Education Stabilization Fund through the Department of Education.
As the guidance for COVID-19 programs has just recently been released through the addendum, recipients and subrecipients of COVID-19 funding are being allowed a three-month extension for submitting their Single Audit reporting package to the Federal Audit Clearinghouse. This three-month extension is applicable to recipients and subrecipients that have a standard due date between the dates of October 1, 2020 and June 30, 2021. In other words, this applies to recipients and subrecipients with year-ends ranging from January 31, 2020 through September 30, 2020. For example, the standard due date for a June 30, 2020 year-end would be March 31, 2021. As a result of the extension, the due date allowed is now June 30, 2021. In order to enact this extension, there is no requirement to seek approval from a federal awarding agency or pass-through agency. The recipient or subrecipient must simply maintain documentation to support their reason for filing by the extended due date.
A new provision was added in the addendum that relates to the compliance requirement of reporting. This requirement is in addition to the reporting requirements as identified in the August 2020 OMB Compliance Supplement. A non-federal entity that receives an award directly from a federal agency and who makes first tier subawards of $25,000 or more is now required to report this information through FSRS (Federal Funding Accountability and Transparency Act Subaward Reporting System). This information can be input in the publicly available website at USASpending.gov. This requirement first becomes applicable to all COVID-19 programs except for the Coronavirus Relief Fund. The requirement then becomes applicable for all other programs for fiscal year ends after September 30, 2020.
Lastly, the addendum speaks of donated PPE (Personal Protective Equipment) and the reporting responsibilities in relation to the Schedule of Expenditures of Federal Awards (SEFA). For any donated PPE that is received by a recipient or subrecipient and that was originally purchased with federal assistance funds, the recipient or subrecipient is required to report the fair market value of this PPE received in a footnote on the SEFA.
If you receive federal funds and have questions in relation to the most recent addendum released by the OMB, please feel free to reach out to YHB.
Since joining YHB in 2012, Katrina’s career focus has been on nonprofit organizations such as private schools, colleges, foundations, religious organizations, museums, and other nonprofit entities. Her service to those organizations include audit and attest as well as tax services.