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OMB Issues M-20-26 Extension of Administrative Relief for Those Directly Impacted by COVID-19

On June 18, 2020, the Office of Management and Budget (OMB) issued Memorandum M-20-26, Extension of Administrative Relief for Recipient and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations. This memorandum provides additional guidance to previously issued memoranda (M-20-11, M-20-17, and M-20-20). The flexibilities provided in the three memoranda were meant to provide short-term administrative, financial, and audit requirements under the Uniform Guidance without compromising Federal financial assistance accountability requirements. Memorandum M-20-26 extends two flexibilities and provides updated Single Audit submission dates, and well as other clarifications related to COVID-19 Emergency Act funding.

 

Audit Extensions
Previously Memorandum M-20-17 provided a blanket six month extension for filing of Single Audits for entities with a fiscal year end through June 30, 2020. This has been revised as follows:
  • FYEs of June 30, 2019 through September 30, 2019 still have an additional 6 month extension (originally due March 31, 2020 through June 30, 2020, now due September 30, 2020 through December 31, 2020)
  • FYEs of October 31, 2019 through December 31, 2019 now only have a 3 month extension (originally due July 31, 2020 through September 30, 2020 now due November 2, 2020 through December 31, 2020).
  • FYEs after 12/31/19 have no extension and will now be due on the normal 9 month due dates.
No formal action is required to exercise the allowable extension and entities can still qualify as low risk auditees in subsequent years (assuming other requirements are met). However, entities must maintain documentation to support the reason for the delayed filings.

 

Allowability of Salaries and Other Project Activities
Awarding agencies may allow recipients to continue to charge salaries and benefits to active Federal awards consistent with the recipients’ policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, Federal and non-Federal. Awarding agencies may allow other costs to be charged to Federal awards necessary to resume activities supported by the award, consistent with applicable Federal cost principles and the benefit to the project.

 

No “Double-Dipping”
Entities receiving funding under the Payroll Protection Program (PPP) or other CARES Act programs may not charge costs paid for with PPP funds to other federal awards as it would result in the Federal government paying for the same expenditures twice.
Reporting on the Schedule of Expenditures of Federal Awards (SEFA)
Recipients and subrecipients should identify expenditures of awards provided by COVID-19 Emergency Acts separately on the SEFA and in audit report findings. Memorandum M-20-26 did not provide further information on what the presentation should look like, but it is possible that clarification will be included in the 2020 Compliance Supplement. Please note that PPP funds are NOT to be included on the SEFA and are NOT subject to Single Audit.
Questions or Need More Info?
If you need additional information or have any questions related to M-20-26 or other implications of COVID-19 Emergency Act funding, please reach out to us. We are happy to help!
To view M-20-26 and other OMB Memoranda in their entirety, please visit