On March 19, 2021, the Office of Management and Budget released OMB Memo M-21-20, Promoting Public Trust in the Federal Government through Effective Implementation of the American Rescue Plan Act and Stewardship of the Taxpayer Resources. Key areas discussed are as follows:
- Extension of the single audit submission requirement to the Federal Audit Clearinghouse by six months for all fiscal year-ends through June 30, 2021, that have not previously been submitted. Approval is not required, but the auditee should maintain documentation explaining the reason for the delayed filing.
- Federal awarding agencies may allow recipients to submit financial and performance reports up to three months late and still allow draw downs on the federal funds.
- Federal awarding agencies may allow awardees to delay submission of their final financial and performance reporting requirements up to one year after the award expires.
- For-profit entities receiving American Rescue Plan Act funding are expected to be subject to 2 CFR 200. Individual agencies may consider deviations from the following requirements: audits, cost-sharing, equipment, intellectual property, and indirect costs.
Federal agencies are required to submit their implementation plans to the OMB for approval within 30 days of the OMB memorandum. Stay tuned for more information from your funding agencies.