The Latest in COVID-19 Funding Compliance Guidance

On December 22, 2020, the Office of Management and Budget (OMB) released the Addendum to the 2020 Compliance Supplement (the Supplement Addendum). 

Each year, the OMB Compliance Supplement is updated to reflect changes to compliance requirements applicable to Federal programs and required programmatic changes outlined by the Federal agencies. The Supplement was issued back in August, but due to the timing and impact of COVID-19 and the Coronavirus Aid, Relief, and Economic Security (CARES) Act, OMB has issued the Supplement Addendum.

While the Supplement Addendum provides information auditors need to perform the Single Audit, it also helps recipients of federal awards understand their compliance requirements by providing additional discussion, information and guidance on the implications of receiving COVID-19 funding.

OMB has made the Supplement Addendum available in one PDF file on the OMB's Office of Federal Financial Management website. As a public service, the AICPA Government Audit Quality Center (GAQC) has posted the addendum by individual section on their GAQC 2020 OMB Compliance Supplement webpage (where the August 2020 Supplement is also posted).

Given the timing of the audit guidance issuance for the COVID-19 programs in the Supplement Addendum, OMB is offering a three-month audit submission extension for Single Audits of 2020 year-ends through Sept. 30, 2020 year-ends only for organizations that received COVID-19 funding.
The Supplement Addendum covers the following:

  • The effective date of the Supplement Addendum and access information;

  • OMB’s three-month audit submission extension for audits of entities receiving COVID-19 funding in certain scenarios;

  • Provider Relief Fund (PRF) program section (Assistance Listing 93.498) provisions that would impact the timing of inclusion of PRF expenditures and lost revenue on the schedule of expenditures of federal awards (SEFA);

  • A new footnote to the SEFA that touches on donated personal protective equipment (PPE) from a federal source;

  • A new reporting compliance requirement that has to do with recipient reporting under the Federal Funding Accountability and Transparency Act (FFATA). At first, the requirement will only apply to audits of COVID-19 programs in the Supplement Addendum, but it will be expanded to all selected major programs for audits of fiscal year-ends after September 30, 2020;

  • A summary of key points from other parts of the Supplement Addendum.

Be sure to keep up with the latest happenings in the nonprofit industry by subscribing to our blog, and following us on Twitter @BDONonprofit.