SVOG closeout process: What companies should do now

Many companies that received the Shuttered Venue Operator Grant (SVOG) are already in the midst of completing their audit requirements and the remaining steps in their closeout process for the SVOG program based on the type of entity.

• Not-for-profit organizations should be following the Uniform Guidance compliance requirements.
• For-profit companies that received SVOG funding should refer to the Small Business Administration’s (SBA) specific guidance issued on July 22, 2022.

With deadlines for the for-profit audit requirements fast approaching, it is important to gather and analyze supporting documentation for your company’s SVOG spending and make sure you have completed all requirements of the closeout process, including:

• One of the last steps in the closeout process is to upload the final expense report on the SBA’s SVOG portal. This is due for all organizations 120 days after the final budget period end date. The final budget period end date is 18 months after the SVOG supplemental award date, and this information should be listed for companies on the SBA portal. Prior to uploading the final expense report, you should review the information provided by the SBA for the Expense Report Action Item within the post-award FAQ’s published in July 2022.
• Another step in the closeout process relates to the audit requirement. For-profit companies should have analyzed their total expenses for SVOG funding to determine if the award was fully spent on allowable costs. If not fully spent on allowable costs, the unspent funds likely will need to be returned to the SBA.
• For fully spent awards, companies should document which period the amounts were spent in. If spending in separate periods was below the $750,000 federal audit requirement, companies should make sure to have this well documented just in case there are any questions in the future or the company becomes subject to a desk review by the SBA.
• If a company determines that they are in need of an audit or examination for the company’s tax year-end in 2021 and they still have not been able to engage an auditor to perform the audit or examination, they should reach out to their SBA contact to discuss the possibility of filing late. Even with the compliance examination report option, which is generally the least time-consuming option, it will still take considerable time and effort to perform the examination and issue the auditor’s report. If you have determined that you only need a 2022 audit, the report will be due Sept. 30, 2023 (or nine months after your company’s fiscal year end if it is not a Dec. 31 calendar year end).

Don’t delay in finding an auditor to assist you with completing the necessary audit work, as many auditors have already been engaged to perform a significant number of these engagements and their resources are likely to be limited this time of year.

CohnReznick has a team dedicated to performing these audits and examinations.