On March 19, 2021, the Office of Management and Budget (OMB) released Memorandum M-21-20, Promoting the Public Trust in the Federal Government through Effective Implementation of the American Rescue Plan Act and Stewardship of the Taxpayer Resources. The memo is eleven pages and addresses several topics surrounding the American Rescue Plan Act (ARPA). Towards the end on page 11, the memo addresses extension of Single Audit submissions. The memo addresses the cognizant and oversight agencies and directs them to allow recipients and subrecipients of federal awards that have not yet filed their Data Collection Form with the Federal Audit Clearinghouse as of the date of the memo, and have year ends through June 30, 2021, to delay submission of the Single Audit reporting package to six months beyond the original due date. Unlike the previous extensions, this is not linked to COVID-19 related funding.
For example, a June 30, 2020, year-end single audit that has not yet been submitted will have until September 30, 2021, to submit the audit (i.e., 6-months after the normal due date of March 31, 2021). However, the requirement that the audit package be filed within 30 calendar days after the release of the audit report is still in place.
No further action is required by the agencies for this extension to be enacted and the recipients do not need to contact the agencies for approval. As with previous extensions, documentation should be maintained to support the reason for the delay in filing.
As a reminder, for-profit entities do not file their Single Audit reporting package with the Federal Audit Clearinghouse but are required to submit directly to the cognizant or oversight agency. For example, the Department of Health and Human Services requires that for-profits submit reporting packages directly to the Audit Resolution Division by email to email@example.com.
The memo also states that agencies should determine if ARPA funding will fall under Uniform Guidance regulations. This includes for-profit recipients as well as non-profit entities and would potentially require a lot of entities to obtain Single Audits that had previously not had one. The memo encourages agencies to require their ARPA programs follow the 2 CFR 200 guidance as an effort at promoting transparency and integrity in agency spending. The agencies are expected to communicate what ARPA programs are subject to Uniform Guidance and which are considered to be higher risk for audit purposes in the Compliance Supplement. In addition, the memo encourages the agencies to offer waivers and flexibilities to reduce the burden on recipients.