The New England Not-For-Profit Accounting Advisor

Not-for-profit organizations that receive federal funds are subject to the requirements of the Uniform Grant Guidance (UGG), and the Subpart F Single Audit. For several reasons, from the introduction of new federal COVID-19 relief programs to the disruption that accompanied mass shelter-in-place orders, the COVID-19 pandemic is changing what the single audit may look like in 2020 and for your organization’s fiscal year. The following provides a brief recap of what to expect for your single audit in 2020.

Topics: reporting requirements, not-for-profit, compliance, OMB, NFP, single audit, Uniform Grant Guidance, COVID-19, CARES Act, Office of Management and Budget, UGG, GAQC

Federal aid swiftly followed the disruption caused by the COVID-19 pandemic, with new programs coming from the Coronavirus Aid, Relief and Economic Security (CARES) Act and additional funding to existing programs. For-profit and not-for-profit organizations of all types received support in the form of grants and may now find themselves with new reporting requirements. For-profit organizations that received coronavirus relief funds may even be facing their first Single Audit under the Office of Management and Budget (OMB)’s Uniform Grant Guidance (UGG).

Topics: not-for-profit, compliance, OMB, NFP, single audit, Uniform Grant Guidance, COVID-19, PPP, extension, payment protection plan, Office of Management and Budget, Coronavirus Relief Fund, Education Stabilization Fund, UGG

In late July, Senate Republicans released a proposal for the fourth round of coronavirus relief legislation. The collective of bills involved are being referred to as the Health, Economic Assistance, Liability Protection and Schools (HEALS) Act. The $1 trillion proposal contains nine separate bills that cover everything from expansions of existing coronavirus relief measures to additional funding for educational institutions. Below are five key proposals that could affect not-for-profit organizations..

Topics: not-for-profit, NFP, university, tax credit, COVID-19, Paycheck Protection Program, Employee Retention Credits, PPP, PPP Loan, Heals Act, Senate Republican, Stimulus, Republican Party

Healthcare entities that are conducting research related to COVID-19 treatment should note that U.S. intelligence officials have detected possible interference from foreign actors. The Federal Bureau of Investigation (FBI) reported in early July that it detected threats from China related to U.S. COVID-19 treatment and intellectual property.

.In an interview with the Washington Post, FBI Director Christopher Wray indicated that Chinese cyber actors have attempted to steal intellectual property, public health records, and information about vaccines, treatments, and testing from U.S. medical facilities, biotech labs, and academic institutions to send to the Chinese government.

Topics: internal control, not-for-profit, NFP, cybersecurity, cyber risk assessment, cyber risks, cyber attacks, data attacks, data privacy, COVID-19, FBI

On July 17, the Federal Reserve Board officially expanded its Main Street Lending Program to make it easier for not-for-profit organizations to access its low-interest loan facilities. Organizations that do not qualify for the Paycheck Protection Program or that do not have an existing lending relationship may have been squeezed out of the federal relief efforts designed to offset the disruption from the COVID-19 pandemic. Proposed changes to the Main Street Lending Program (MSLP), announced in June, were more or less approved, with a few additional adjustments to minimum number of employees and rules surrounding donations.

Topics: not-for-profit, NFP, COVID-19, Main Street Lending Program, Nonprofit New Loans, Nonprofit Expanded Loans

New requirements will affect private college and university entities in 2020. All entities will be required this year to include in their financial statements additional supplemental information that will allow the United States Department of Education (DOE) to link the support for the various elements that go into the so-called “Composite Score,” which is used to establish the financial health of private colleges and universities. We expect most organizations to include this information in the Uniform Grant Guidance version of their reports as an additional supplemental schedule. It is expected there will be some impact on the level of detail in the footnotes of the basic financial statements to ensure that every element can be tied directly to the financial statements.

Topics: reporting requirements, not-for-profit, NFP, Department of Education, Uniform Grant Guidance, DOE, Financial Statement, COVID-19, NACUBO, higher education, private university

Thanks to a recent memo from the Office of Management and Budget (OMB), some organizations subject to the Uniform Grant Guidance will no longer be provided an extension to file their Single Audit with the Federal Audit Clearinghouse. Memo M-20-26, Extension of Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations eliminates a previous six-month extension that had been granted to organizations with fiscal year ends falling between Dec. 31, 2019, through June 30, 2020. Those Single Audits would be due within the normal due date under the Uniform Grant Guidance, nine months after the fiscal year end.

Topics: not-for-profit, compliance, OMB, NFP, single audit, Uniform Grant Guidance, COVID-19, PPP, extension, payment protection plan, Office of Management and Budget, Appendix XI

As part of its recent review of the CARES Act loan programs, the Federal Reserve is evaluating whether to expand its Main Street loan facilities to include not-for-profit organizations. The lending program is designed to provide low-interest, government-backed loans with fewer lender requirements for organizations financially affected by the COVID-19 pandemic.

Topics: not-for-profit, NFP, COVID-19, CARES Act, Main Street Lending Program, Main Street Priority Loan Facility, Main Street Expanded Loan Facility, Main Street New Loan Facility

Not-for-profit organizations faced a particularly difficult time in the wake of the COVID-19 pandemic, with many having to temporarily shutter their doors to help mitigate the spread of the coronavirus disease. Assistance contained in the Coronavirus Aid, Relief, and Economic Security (CARES) Act broadened loan programs for small businesses to include not-for-profit organizations. These loan provisions generally provide some additional financial support to organizations with 500 or fewer employees.

Topics: not-for-profit, NFP, COVID-19, CARES Act, Paycheck Protection Program, PPP, PPP Loan, asc topic 958, asc topic 470, debt

Since inception, by way of the CARES Act, the Paycheck Protection Program (PPP) has been the prime focus for American small businesses. That focus has generated many questions and concerns as such a massive program pieced together in a very short period of time is inherently subject to ambiguity and unintended outcomes.

Topics: not-for-profit, NFP, COVID-19, CARES Act, Paycheck Protection Program, PPP, PPP Loan, SBA, Small Business Administration