COVID-19 and Single Audits
COVID-19 and Single Audits
Between business interruptions and new federal funding, COVID-19 will impact Single Audit requirements in several ways. Below are some highlights of how COVID-19 is impacting Single Audit requirements.
This page will be updated as new guidance is made available.
Have Federal single audit submission deadlines been extended?
Yes. The U. S. Office of Management and Budget provided a six-month extension beyond the normal due date for submission of single audit reports to the Federal Audit Clearinghouse for organizations that have fiscal year ends through June 30, 2020. This extension does not require individual recipients or subrecipients to seek approval for the extension. However, documentation should be maintained of the reason for the delayed filing. Recipients and subrecipients taking advantage of this extension would still qualify as a “low-risk auditee” if all other requirements for “low-risk auditee” designation are met.
Have state single audit submission deadlines been extended?
The Texas Comptroller’s office has confirmed that they have not granted a blanket extension for state single audits. Organizations will need to request extensions from their individual state grantors.
Are PPP loans subject to single audit requirements of the Uniform Guidance?
No. The SBA has stated that PPP loans are not subject to single audit under the Uniform Guidance.
Are Economic Disaster Loans (EIDL) subject to single audit requirements of the Uniform Guidance?
Yes. The SBA has stated that EIDLs awarded by the SBA are subject to single audit under the Uniform Guidance.
Can expenses that are reimbursed by a federal or state grant as allowable costs also be used as qualifying expenses for applying for PPP loan forgiveness?
No. The same costs may not be used both as qualifying expenses for PPP loan forgiveness and as allowable expenditures under federal or state grant programs.
What happens to unused budgeted grant funds if costs that are normally funded under a federal or state grant program are instead used as qualifying expenses for PPP loan forgiveness?
An NFP should contact their granting agency as soon as practical to discuss the possibility of obtaining approval to re-allocate unused budget funds to other categories.
Will an NFP lose budgeted grant funds if COVID-19 prevents full program operation and complete use of funds prior to the end of the grant period?
An NFP may apply for a no-cost extension with the granting agency for grants that were active as of March 31, 2020 and are scheduled to expire on or before December 31, 2020.
Are PPP loans subject to audit by the SBA?
Companies receiving PPP loans of $2 million or more will be audited by the SBA. Those receiving less than $2 million may be audited by the SBA.