OMB Releases Long Awaited 2020 Compliance Supplement Addendum

From McKonly & Asbury

Just in time for the holiday season, the Office of Management and Budget (OMB) released the long-awaited addendum to the 2020 Compliance Supplement on December 22, 2020. This addendum provides important updates to COVID-19 related federal funding and the impact to Single Audits. This addendum, along with the original Compliance Supplement issued earlier in the year, is effective for fiscal years beginning after June 30, 2019 (i.e. June 30, 2020 fiscal years and later).

For audited entities whose Single Audits have been delayed, the addendum provides for a 3-month audit submission extension for Single Audits of 2020 year-ends through September 30, 2020. This extension is only available if the recipient entity received COVID-19 funding. There is no approval required for the extension, but documentation must be maintained for the reason of the delay. For those entities with June 30, 2020 year-ends, with COVID-19 funding, the deadline for submission of the Single Audit is now June 30, 2021 (as opposed to March 31, 2021).

Other items addressed in this addendum include:

  • An updated matrix of compliance requirements subject to audit
  • Updated agency requirements for new COVID-19 programs, existing programs impacted by COVID-19, and some non-COVID-19 additions
  • Reporting of provider relief funds (expenditures and lost revenues) on the schedule of expenditures of federal awards (SEFA)
  • Treatment of the receipt of donated personal protective equipment on the SEFA

The addendum also clarifies that for existing federal programs that received funding under the CARES Act that are not included in the addendum, auditors should perform reasonable procedures to ensure the compliance procedures included in the 2020 Compliance Supplement are current.

A copy of the full addendum can be found here.

The 2020 Compliance Supplement issued in August 2020 can be found here.

If you have any questions regarding the 2020 OMB Compliance Supplement, or this recent addendum, and how they may impact your nonprofit organization, contact Jim Shellenberger, Principal, at [email protected].