Staying up to date with the myriad of ever-changing Single Audit requirements seems like an endless task for recipients of federal funding. Keeping these updates front of mind allows for improved planning and usage of funds received, reduced strain on the finance team, and a smooth Single Audit season. Consider the updates below, as identified by the Office of Management and Budget (OMB), when preparing for Single Audits this year.
Single Audit Extensions for Certain States
In general, non-federal entities submit their Single Audit reporting packages 30 days after receipt of the auditor’s report(s) or nine months after the end of the fiscal year, whichever comes first. Due to various weather-related events this year in certain states and territories, the OMB announced a Single Audit extension for the latter half of 2022 for non-federal entities and for-profit recipients.
Non-Federal Entity Recipients
OMB has announced on the Federal Audit Clearinghouse website that this six-month Single Audit submission extension is for non-federal entity recipients in Puerto Rico, Alaska, Florida, South Carolina, and North Carolina that have due dates between September 18, 2022 and December 31, 2022, due to the complications created by various weather-related events and declarations of significant areas of these states as major disaster areas under the Stafford Act. The American Institute of CPAs’ (AICPA) Governmental Audit Quality Center (GAQC) confirmed with OMB staff that the extension is available to all recipients in each of the states and not just those located in certain areas of the states most significantly impacted. The OMB extension posting encourages recipients in the less-affected areas to submit their reports as soon as possible.
For-Profit Recipients
As it relates to for-profit recipients, the U.S. Department of Health & Human Services (HHS) deputy secretary of grants has issued an internal memorandum to the 13 HHS awarding agencies, e.g., Health Resources and Services Administration (HRSA), National Institutes of Health, Centers for Disease Control and Prevention, etc., extending the same six-month extension as provided by OMB for Single Audits to HHS for-profit recipients. That is, the HHS extension applies to for-profit recipients in the same states as noted above with report due dates between September 18, 2022 and December 31, 2022. HHS awarding agencies are expected to communicate this development with their recipients directly and also are expected to encourage recipients in the less-affected areas within each state to submit their audits as soon as possible. This should be of particular interest to for-profit recipients in the affected states with funding from the Provider Relief Fund program, as September 30, 2022 was a significant audit submission deadline for many for-profit entities. The U.S. Department of Housing and Urban Development (HUD) has not yet communicated whether it will offer any similar extensions for their for-profit recipients in affected states.
Guidance on Duplication of Benefits for Healthcare Entities
FEMA recently issued final guidance on duplication of benefits as it relates to healthcare entities. It’s currently unclear whether this relates to existing or future FEMA awards. Healthcare entities receiving or applying for FEMA funding should take note and reach out to FEMA for further information.
Student Financial Assistance (SFA) Update
Beginning in July 2022, the National Student Loan Data System (NSLDS) recognized delays in timely enrollment reporting due to system upgrades to NSLDS. This outage prevented many institutions from timely reporting enrollment information and pulling system reports as part of the SFA enrollment reporting compliance requirement.
The U.S. Department of Education (ED) released Electronic Announcement 22-76 on the NSLDS transition of systems. Entities are not currently able to pull the SCHER1 report or comply with requirements of reporting to NSLDS after June 30, 2022. Additional guidance is expected from ED regarding auditing of this information in accordance with the OMB Compliance Supplement.
HUD Surplus Cash Calculation
There is a new HUD Mortgagee Letter 2022-16 regarding the surplus cash calculation for multifamily housing projects. The letter permits new owners to take distributions of surplus cash monthly rather than annually or semiannually and then calculate the YE amount; if there's a deficit, they have 60 days to cure the deficit. There are precedent conditions listed in the Letter, which must be satisfied by the owners who take the monthly distributions. Chapter 3 of the HUD Consolidated Audit Guide has not yet been updated to reflect these changes.
New AICPA GAQC Resources for Auditees
To help further the AICPA goal for promoting the highest-quality Single Audits, the GAQC has released several new and updated resources to help organizations subject to these types of audits, as follows:
- A refreshed practice aid, Procuring Governmental Audit Services
- An explainer titled, Importance of Selecting a Qualified Auditor
- A brochure titled, Tips for Organizations Subject to Single Audit Requirements
- A checklist for auditees on getting ready for a Single Audit
- An archived on-demand webcast: Preparing for Your First Single Audit
- A document titled, FAQs for Organizations Needing a Single Audit
These resources and others are free and available to the public. To access them, users must register for an online AICPA account, which anyone can establish.
Conclusion
If you have any questions or need assistance with Single Audit updates, please reach out to a professional at FORVIS or submit the Contact Us form below.