OMB发布节日礼物

12月22日, the Office of 管理 and Budget (OMB) released its long-awaited 2020 Compliance Supplement Addendum (Addendum), intended to be used in conjunction with the 2020 Compliance Supplement to provide additional guidance on COVID-19 expenditures. The Addendum includes guidance on fourteen COVID-19 funded programs and identifies compliance requirements that are subject to audit.

There are four changes to that are important to be aware of in the Addendum:

• There will be an automatic three-month extension for submissions of single audits for those organizations with fiscal year-ends through September 30, 2020年获得COVID-19资金. The extension is tacked on to the traditional nine-month due date. 不需要正式批准, but the organization will need to document why the single audit was not 提交ted by the original date. If it thought its COVID-19 program would be subject to single audit, it could document that as the reason it’s 提交ting with the extension. Note that the extension does not apply to organizations that did not receive COVID funds, 预计不会再批准其他延期.
• An additional reporting requirement has been added to the Compliance Supplement relating to the Federal Funding Accountability and Transparency Act (FFATA) that necessitates direct recipients of grants who make first-tier subawards of $25,000 or more to report that data through the FFATA Subaward Reporting System. The auditor must test FFATA for all COVID-19 programs in the Addendum when the reporting compliance requirement is subject to audit. This requirement is phasing in for all major programs testing for single audits of fiscal year-ends after September 30, 2020.
• Organizations that received donated Personal Protective Equipment (PPE) should include a footnote to the Schedule of Federal Awards (SEFA) to indicate the fair market value of the PPE at the time of receipt. 脚注可以标记为“未经审计”.” Donated PPE should not be counted for purposes of determining the threshold for a single audit or determining type A/B program threshold for major programs and is not required to be audited as a major program. 也, organizations should also be aware of whether they received donated PPE from a state agency that may have originally come from a federal source and should consider this as part of their disclosure.
• The Addendum clarifies when Provider Relief Funds (PRF) expenditures and lost revenues should be reported on the SEFA (December 31, 2020). 如果一个组织有6月30日, 2020年年终, 不会记录任何金额, 哪些可能会改变审计阈值. 如果一个组织有12月31日, 2020年年终, the amounts will be included and will continue to report expenditures after this period. 这一调整是为了更好地与美国对齐.S. Department of Health and Human bet9平台游戏 reporting requirements.

最后, 在SEFA上展示的所有新项目和现有项目, all COVID-19-related awards are required to be separately identified with the leading “COVID-19” before the name. Organizations will need to override the program title and present a separate line on the Data Collection Form.