On March 19, 2021, the Office of Management and Budget (OMB) issued Memo M-20-21, which was addressed to federal agencies. The memo contains several items, but perhaps the most important is a single audit submission extension discussed below.

The memo instructs federal agencies to allow organizations with fiscal year-ends through June 30, 2021, that have not yet filed their single audits with the Federal Audit Clearinghouse as of the date of the issuance of the Memo (3/19/21), to delay the completion and submission of the single audit reporting package by six months beyond the normal due date. No further action by awarding agencies is required to enact this extension and organizations are not required to seek approval for the extension. However, as with previous extensions, organizations should maintain documentation regarding the reason for the delayed filing.

For example, a June 30, 2020 year-end single audit that has not yet been submitted will have until September 30, 2021 to submit the single audit reporting package (i.e., 6-months after the normal due date of March 31, 2021). Further, a December 31, 2020 year-end single audit that has not yet been submitted will have until March 31, 2022 to submit the single audit reporting package (i.e., 6 months after the normal due date of September 30, 2021). We caution organizations to remember that the requirement to submit the single audit package within 30 calendar days of receiving the auditor’s report continues to apply.

This new extension is longer than the previous extension provided in the OMB Compliance Supplement Addendum, which was only for 3 months. This extension also extends to later fiscal year-ends, and is not linked to the receipt of COVID-19 funding. Lastly, organizations taking advantage of this extension will still qualify as a "low-risk auditee" for the subsequent year’s major program determination, assuming the other requirements to qualify as low-risk are met.

The memo encourages the agencies to provide various waivers and flexibilities to reduce burden for federal financial assistance, so organizations should talk to their cognizant agency if circumstances prohibit the organization from meeting submission deadlines.

Read full memo here: OMB Memo M-20-21.

 

^{Readers should not act upon information presented without individual professional consultation.}

^{Any federal tax advice contained in this communication (including any attachments): (i) is intended for your use only; (ii) is based on the accuracy and completeness of the facts you have provided us; and (iii) may not be relied upon to avoid penalties.}