In August the Office of Management and Budget (OMB) released its 2021 Compliance Supplement, 2 CFR Part 200 Appendix XI (Compliance Supplement). The annual compliance document provides details and guidance on the pertinent audit areas under the Uniform Grant Guidance. Not-for-profits that receive federal grants are often subject to Uniform Grant Guidance requirements, which include an audit over their administration and controls of their federal grants. Below are some of the key takeaways from the 2021 edition.
Continued Audit Requirements for COVID-19-Related Programs
Not-for-profit organizations may have received federal funding for the first time due to the number of COVID-19 federal stimulus relief provisions rolled out in 2020. Under the guidance of the 2021 Compliance Supplement, those programs and new ones established in 2021 (such as the Shuttered Venue grant) are likely required to be audited.
Future Addendums to the Compliance Supplement to be Released
OMB has indicated there will be two addenda to the August 2021 Compliance Supplement. The first is expected to be issued in the early Fall and will likely include audit guidance on two programs – Coronavirus State and Local Fiscal Recovery Fund and an update to certain programs under the Education Stabilization Fund. Then a second addendum will be issued later in the Fall. Programs expected to be included in the second addendum are three Treasury programs: Capital Projects Fund, Homeownership Assistance Fund, and the Local Assistance and Tribal Consistency Fund. The addendum may also include additional new programs, which OMB has not yet identified.
Extension of Single Audit Due Dates
Entities with fiscal years ending on or before June 30, 2021 can delay the submission of their single audit up to six months beyond their normal due date. Entities taking advantage of this extension would still qualify as a “low-risk auditee,” which allows for a lower percentage of coverage of audited programs.
Questions on 2021 Uniform Grant Guidance Audits?
For comments, questions, or concerns about undergoing 2021 uniform grant guidance audits, please contact a member of our team.
Looking for more COVID-19 resources? Visit our resource center for expertise on impacts to expect and how your business can respond.
Michelle Sylvia Spriggs is a Shareholder in the Not-For-Profit & Education Practice. She can be reached at 774.206.8336 or firstname.lastname@example.org.
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