NOT-FOR-PROFIT: COVID-19 impacts on not-for-profit recipients of federal funds

As the COVID-19 crisis continues, many organizations have applied for relief under the Coronavirus Aid, Relief, and Economic Security (CARES) Act. However, there continue to be many questions as to whether these funds will be subject to a Federal Single Audit in accordance with Uniform Guidance, and the impact of the pandemic on filing deadlines. Read on for some of the latest information available. 

• According to the AICPA Governmental Audit Quality Center (GAQC), loans received by not-for-profit organizations (NFPs) under the Small Business Administration (SBA) Paycheck Protection Program (PPP) will not be subject to the Uniform Guidance Single Audit requirements.
• Loans received by NFPs under the SBA Economic Injury Disaster Loan (EIDL) program are subject to Single Audit requirements, the GAQC says.
• We are awaiting additional guidance from the Office of Management and Budget (OMB) regarding the appropriate presentation of EIDL loans and other CARES Act funding on the Schedule of Expenditures of Federal Awards, the Catalog of Federal Domestic Assistance (CFDA) numbers, and the impact this additional guidance will have on major program determination.
• On March 19, 2020, OMB issued M-20-17, which provides a six-month extension of time to file a Federal Single Audit for NFPs with year-ends through June 30, 2020. For example, a Single Audit report for a Dec. 31, 2019, year-end that normally would be due on Sept. 30, 2020, will now be due on March 31, 2021. The extension is provided to NFPs affected by the loss of operational capacity or increased costs due to the COVID-19 crisis that had not filed their Federal Single Audits as of March 19, 2020. No action is required to receive the extension. However, it is important that NFPs document the reason for the delay and reference this documentation in the audit reporting package when filed. 
• The U.S Department of Housing and Urban Development (HUD) Real Estate Assessment Center (REAC) has extended filing deadlines for Multifamily Housing Entities audit submissions that are due April 30 and May 31. Audits are now due June 30. HUD has also prepared an FAQ document, “Questions and Answers for Office of Multifamily Housing Stakeholders.”