Trending AskRegs Q&A: Has OMB Extended the March 31, 2020 Single Audit Act Submission Deadline Due to Coronavirus?

Trending AskRegs Q&A: Has OMB Extended the March 31, 2020 Single Audit Act Submission Deadline Due to Coronavirus?

Yes. The Office of Management and Budget (OMB) has extended the March 31, 2020 audit submission deadline under the Single Audit Act by six months.

On March 19, 2020, the OMB released a memo allowing a six-month extension for Single Audit Act auditees, although individual awarding agencies such as the U.S. Department of Education (ED) appeared to retain some discretion. The memo reads in part:

  • “Awarding agencies, in their capacity as cognizant or oversight agencies for audit, should allow recipients and subrecipients that have not yet filed their single audits with the Federal Audit Clearinghouse as of the date of the issuance of this memorandum that have fiscal year-ends through June 30, 2020, to delay the completion and submission of the Single Audit reporting package, as required under Subpart F of 2 CFR § 200.501—Audit Requirements, to six (6) months beyond the normal due date. No further action by awarding agencies is required to enact this extension. This extension does not require individual recipients and subrecipients to seek approval for the extension by the cognizant or oversight agency for audit; however, recipients and subrecipients should maintain documentation of the reason for the delayed filing. Recipients and subrecipients taking advantage of this extension would still qualify as a "low-risk auditee" under the criteria of 2 CFR § 200.520 (a)-Criteria for a low-risk auditee.”

NASFAA has confirmed with ED's Office of Inspector General (OIG) Non-Federal Audit Team that this is an automatic six-month extension for Single Audit Act auditees; it does not require approval from ED.

ED has not yet issued guidance regarding audit due dates for proprietary schools and foreign schools not covered by the Single Audit Act. The OIG Non-Federal Audit Team indicated that it has reached out to ED to see if ED is planning extend those deadlines, but the Team had not heard back from ED. Stay tuned to NASFAA'sToday's News for additional guidance if/when it is received from ED.

Refer to Volume 2, Chapter 4 of the FSA Handbook for more on audit submission deadlines.


Publication Date: 3/24/2020

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