Single audit alert: Another change to federal single audit deadlines

In late March, we told you about flexibility in the single audit reporting deadline offered by the U.S. Office of Management and Budget (OMB) to those entities affected by the COVID-19 pandemic. OMB's memorandum
M-20-17 on March 19, 2020, contained a blanket extension for certain single audit submissions not filed as of that date. However, the information in the memorandum, including the extension, was to be reconsidered within 90 days.

OMB then issued memorandum M-20-26 on June 18, 2020, which significantly changed the single audit submission extension previously included in memorandum M-20-17 (now rescinded). The extension continues to be for submissions to the Federal Audit Clearinghouse that were not filed as of March 19, 2020. However, the focus of the new extension is different and relates directly to audit submission due dates.

The following table shows the revised single audit submission deadline under memorandum M-20-26:

Please note that the earlier memorandum's extension for fiscal year-ends happening from January 1 through June 30, 2020, has been rescinded. There are no longer any extensions for fiscal year-ends in 2020. Those audits will need to be filed with the Federal Audit Clearinghouse in accordance with the normal due dates as determined above.

No application or approval is needed to use these extensions. Entities that do take advantage of the extension period should keep records of the reasons for doing so, which does not jeopardize their future qualification for “low risk” status under 2 CFR §200.520. The Federal Audit Clearinghouse website had previously asked that entities mention the earlier memorandum in their audit submission for the information of oversight agencies. Users should check the website before completing their filing to determine if this request will continue under the new memorandum.

Even with the flexibility offered by the extension, please remember that it 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.

OMB memorandum M-20-26 also indicates that funding associated with federal COVID-19 emergency acts must be separately identified on future schedules of expenditures of federal awards (SEFA). Those who prepared these schedules in the past might remember similar treatment during the Great Recession for American Recovery and Reinvestment Act (ARRA) awards. More guidance on this will come in the future.

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.