The American Institute of Certified Public Accountant’s Governmental Audit Quality Center (GAQC) has issued a document that summarizes the applicability of Federal Programs established due to the COVID-19 pandemic to the Single Audit requirements established in the Uniform Guidance. A Single Audit is required when a non-federal entity expends more than $750,000 in federal awards during its fiscal year. The Summary includes the following information:
- The Assistance Listing number (commonly referred to as the CFDA number)
- An indication of whether the program is subject to a Single Audit and what specific sections of the Uniform Guidance are applicable
- Links to any related federal agency or other relevant guidance
- A section documenting any other pertinent information the GAQC is aware of that might affect the program
Determinations for two of the largest programs included in the Summary are as follows:
Paycheck Protection Program (PPP) administered by the Small Business Administration
The PPP provides loans to eligible entities to cover payroll and other costs that have the potential to be forgiven if certain criteria are met. The Summary indicates that although some not-for-profit (NFP) entities received loans under the PPP, they will not be subject to a Single Audit.
Provider Relief Funds administered by Health and Human Services (HHS)
Provider Relief Funds were distributed to hospitals and other healthcare providers to help battle the effects of COVID-19. The Summary indicates that HHS has determined that certain subparts of the Uniform Guidance apply to non-federal entities receiving the funds and, as such, those entities will be subject to a Single Audit. However, the GAQC indicates that HHS is still discussing this decision and what audit requirements, if any, may be applicable to for-profit entities.
For additional information relating to the PPP and Provider Relief Funds, please visit the PYA COVID-19 Information Hub.
The GAQC plans on updating the Summary as additional information surfaces. To ensure users are working with the most recent version of the PDF document, the GAQC will provide an “as of” date on the first page.
2020 Compliance Supplement: The GAQC also provided an update on the status of the 2020 Compliance Supplement (the Supplement) that is yet to be issued by the Office of Management and Budget (OMB). It is anticipated that the Supplement will be issued in two parts. The first part will primarily address programs that existed prior to the COVID-19 pandemic, and the OMB is hoping to release it in late June or early July. The second part will be an addendum, will specifically address COVID-19 programs, and is expected to arrive in late summer or early fall.
For further assistance in determining how Provider Relief Funds and other COVID-19-related funding factor into your entity’s need for a Single Audit and what controls your entity should have in place to ensure compliance, contact one of our PYA executives below at (800) 270-9629.