2020 OMB Compliance Supplement Addendum Released

After much anticipation, the Office of Management and Budget (OMB) issued the 2020 Compliance Supplement Addendum (the Supplement Addendum) on December 22, 2020; with an effective date the same as the August 2020 Compliance Supplement for audits of fiscal years beginning on or after June 30, 2019. Due to the late release of the Supplement Addendum, recipients of COVID-19 funding are granted an extension of up to three months beyond the normal due date to submit the single audit reporting package. 

The key Supplement Addendum provisions are as follows:

New COVID-19 Programs

The Supplement Addendum adds the following newly created COVID-19 programs:

  • 16.034 Coronavirus Emergency Supplemental Funding
  • 21.019 Coronavirus Relief Fund
  • 32.006 Telehealth Program
  • 84.425 Education Stabilization Fund
  • 93.461 COVID-19 Testing for the Uninsured
  • 93.498 Provider Relief Fund

Part 2 – Matrix of Compliance Requirements

Part 2 – The Supplement Addendum matrix of compliance requirements identifies the requirements subject to audit for specific COVID-19 related programs, both existing programs and newly created programs. New programs include “new” in bold print after the title.

FFATA Reporting

Federal Funding Accountability and Transparency Act (FFATA) reports are required to be filed for subrecipients receiving direct awards in excess of $25,000 through the FFATA Subaward Reporting System (FSRS). Organizations receiving federal funding had to comply with this requirement prior to the issuance of the Supplement Addendum, however, the FFATA reporting requirement was not previously included in the August 2020 Compliance Supplement.

Federal Programs Impacted by COVID-19 Funding

New compliance requirements, as a result of COVID-19 funding, for new or existing federal programs, are included in Part 4 of the Supplement Addendum. Part 4 of the Supplement Addendum must be used in conjunction with Part 3 to determine if the compliance requirement is subject to audit. For other existing federal programs that received funding under the Coronavirus Aid, Relief, and Economic Security (CARES) Act that are not included in the Supplement Addendum, users should refer to the Appendix VII of the Supplement for guidance.

Footnote Requirement for Personal Protective Equipment

Donated personal protective equipment (PPE) from federal sources are required to be reported at fair value and included in a footnote accompanying the Schedule of Expenditures of Federal Awards (SEFA). 

Final Takeaway

This Supplement Addendum is what we have all been waiting for – guidance on the impact of COVID-19 related funding, including the CARES Act funding, on single audits.

Contact us with questions related to the Supplement Addendum and the impact on your organization.

Hediyeh Sadeghein
Hediyeh Sadeghein | Manager
Paul Preziotti
Paul Preziotti | Partner