On March 19, 2021, the Office of Management and Budget issued memorandum M-21-20 (the Memo), providing an automatic six-month extension for all single audit filings for fiscal year ends through June 30, 2021 (Appendix 3, part IX, of the Memo). For reference, here is a short list of those approaching:
As mentioned above, the extension is automatic and not conditioned upon approval for specific reasons. Therefore, if you submit your Data Collection Form by the extended due date, it is not considered late for purposes of single audit reporting testing or determination of low-risk auditee status. Also, the extension applies through fiscal year end June 30, 2021. Therefore, single audits for fiscal years ended June 30, 2021 are not due until September 30, 2022.
While approval of the extension is not needed, all organizations that do not file within the standard nine-month timeframe should maintain internal documentation for the reasons that the extension was utilized. There are no specific guidelines or criteria provided in the Memo for reasons that may be applicable or acceptable. Following are possible delay-causing issues that organizations may consider when developing internal documentation:
- Staff turnover during the fiscal year or during the standard nine-month audit period
- Program managers
- Accounting personnel
- Executive management
- Impact of COVID-19 illness on any of the above or any other personnel involved in the grant documentation or reporting process
- Operational or administrative disruptions caused by the COVID-19 pandemic.
- Recordkeeping access issues due to limited office access
- Transitions in information technology related to remote access of network
- Additional hardware needed for key personnel
- Connectivity setup issues that may have taken additional time
- Reduced communications with grantors
- Any other operational, administrative, or information technology disruptions that were unusual or nonrecurring
The Memo also provides optional relief for the following. However, these are at the discretion of the grantor and require approval.
- Pre-award costs starting March 15, 2021
- Extensions on existing awards
- Extensions on financial reporting requirements such as SF-425 reporting.
If you have questions regarding single audits for your organization, please contact your local Blue & Co. advisor for assistance.