Published: December 23, 2020
Updated: March 26, 2021
In July, we told you about changes to the single audit due dates and information required to be reported on the Schedule of Expenditures of Federal Awards (SEFA). Additional guidance was published in the 2020 Compliance Supplement Addendum on Dec. 22, 2020, and in Memorandum M-21-20 on March 19, 2021, by the U.S. Office of Management and Budget. As you read through the entire Addendum and M-21-20, here are some key items for your attention:
Single audit due dates
The Addendum contained a 3-month single audit due date extension for certain entities having a year-end in 2020 and that received COVID-19 funding.
M-21-20 contained different extension guidance that affects all entities that had not filed their single audits with the Federal Audit Clearinghouse as of March 19, 2021. This additional guidance allowed a six month extension and applies to all entities, not to only those receiving COVID-19 funding.
Affected yearends and new due dates include:
|Fiscal Year Ended||Original 9-month Due Date||Extended Due Date –Addendum (if filed before 3/19/2021)||Extended Due Date – M-21-20 (if unfiled at 3/19/2021)|
|Jan. 31, 2020||Oct. 31, 2020||Jan. 31, 2021*||April 30, 2021|
|Feb. 29, 2020||Nov. 30, 2020||Feb. 28, 2021*||May 31, 2021|
|March 31, 2020||Dec. 31, 2020||March 31, 2021*||June 30, 2021|
|April 30, 2020||Jan. 31, 2021||July 31, 2021|
|May 31, 2020||Feb. 28, 2021||August 31, 2021|
|June 30, 2020||March 31, 2021||September 30, 2021|
|July 31, 2020||April 30, 2021||October 31, 2021|
|Aug. 31, 2020||May 31, 2021||November 30, 2021|
|Sept. 30, 2020||June 30, 2021||December 31, 2021|
|October 31, 2020||July 31, 2021||January 31, 2022|
|November 30, 2020||August 31, 2021||February 28, 2022|
|December 31, 2020||September 30, 2021||March 31, 2022|
|January 31, 2021||October 31, 2021||April 30, 2022|
|February 28, 2021||November 30, 2021||May 31, 2022|
|March 31, 2021||December 31, 2021||June 30, 2022|
|April 30, 2021||January 31, 2022||July 31, 2022|
|May 31, 2021||February 28, 2022||August 31, 2022|
|June 30, 2021||March 31, 2022||September 30, 2022|
* If a single audit report for this yearend was not filed with the Federal Audit Clearinghouse as of March 19, 2021, the extended due date would be in the next column. If the single audit report was filed before this date, then the extended due date in this column would apply if the entity received COVID-19 funding.
Note: If the due date falls on a weekend or federal holiday, it changes to the next business day.
No application or approval is needed in either case to use the applicable extension. Entities that take advantage of the extension period must document the reasons for doing so, which does not jeopardize their future qualification for “low risk” status under 2 CFR §200.520.
Remember, the guidance in the Addendum and M-21-20 only affects one of the criteria for determining the actual audit submission due date. Under federal law (2 CFR §200.512), the entity’s due date for an audit submission is the earlier of 1) 30 calendar days after receipt of the audit report, or 2) nine months after the end of the audit period (plus extension).
Schedule of expenditures of federal awards (SEFA)
Additional SEFA guidance was also issued in the Addendum for:
- Provider Relief Program (CFDA 93.498) (PRF) –
- This program, including lost revenue, will be first reported on the SEFA for years ending on or after Dec. 31, 2020. No amounts related to this program are to be reported on the SEFA for fiscal years ending prior to that date.
- For fiscal years ending Dec. 31, 2020, and in 2021 on or before June 29, 2021, the footnotes to the SEFA will contain a disclosure stating that the amount reported (including lost revenue) is based on the Dec. 31, 2020, PRF report to the U.S. Department of Health and Human Services.
- Donated personal protective equipment (PPE) – Some entities received donations of PPE from federal or pass-through agencies for use in their COVID-19 response activities, without an indication of its value.
- Receiving entities should assign a value to the PPE based on its fair market value and report it in a footnote to the SEFA. The value would not be reported with federal program expenditures on the SEFA and may be marked “unaudited.”
- The value of the PPE is not counted toward the federal single audit threshold, nor will it be included in the process of selecting federal programs for the single audit.
- Education Stabilization Fund under the CARES Act (CFDA 84.425) –
- This funding was subdivided into programs as indicated by letters (84.425A – 84.425P) and some further grouped by those covered by the Education Stabilization Fund and by the Higher Education Emergency Relief Fund.
- The SEFA should list the expenditure amounts by individual program, including the letter (e.g. 84.425C, 84.425D, 84.425E, 84.425F), and include a total for the entire program (84.425).
- The program as a whole will be considered in the process of selecting federal programs for the single audit.
Further, we’ve learned that COVID-19 vaccines distributed to entities are not considered Federal financial assistance because they remain federal property until administered to an individual. Therefore, amounts related to vaccines do not need to be included on the SEFA or in the footnotes.
Finally, State Auditor Pat McCarthy has encouraged entities to “Document, Document, Document” as it relates to expenditures of COVID-19 awards. The Addendum directs auditors to consider the awarding agency guidance existing at the time of the expenditure when determining compliance with applicable requirements. Some guidance has changed over time. Therefore, it will be especially important for that documentation to demonstrate how the expenditure met the requirement at the time.
The Office of the Washington State Auditor understands all of us in government are working in extraordinary circumstances. We will continue to monitor the situation and keep you apprised of any further developments. Please also remember, we are here to help governments across Washington. Contact your audit team or submit a help desk question on the SAO website.