Single audit alert: Updated guidance for due dates and items reported on the Schedule of Expenditures of Federal Awards (SEFA)

Dec 23, 2020

Updated: March 26, 2021, most recently updated: August 4, 2021

Over time, there have been a number of changes to the guidance for single audit due dates and information to be reported on the Schedule of Expenditures of Federal Awards (SEFA).

In July 2020, we told you about changes to the single audit due dates and information required to be reported on the 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. Recent updates in July 2021 by a federal agency has changed some of this information.

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 on or 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) – 7/2021 UPDATE: The original guidance for this program in the 2020 Compliance Supplement Addendum has now changed. The US Department of Health and Human Services (HHS) has opened their PRF reporting portal and issued PRF Frequently Asked Questions to provide information about when amounts will be reported there and on the SEFA.
    • This program, including lost revenue, will now be first reported on the SEFA for years ending on or after June 30, 2021. No amounts related to this program are to be reported on the SEFA for fiscal years ending prior to that date, including calendar year 2020.
    • For fiscal years ending June 30, 2021 and following, the footnotes to the SEFA should contain a disclosure stating that the amount reported (including lost revenue) is based on the PRF reported 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.