Single Audit Submission Extension

OMB issued Memo 20-21 to Federal agencies instruction allowing recipients and sub-recipients that have not yet filed their single audits with the Federal Audit Clearinghouse as of the date of the issuance of OMB Memo M-20-21 (i.e., 3/19/21) that have fiscal year-ends through June 30, 2021, to delay the completion and submission of the single audit reporting package to six months beyond the normal due date. No further action by awarding agencies is required to enact this extension and individual recipients and sub-recipients are not required to seek approval for the extension. However, as with previous extensions, recipients and sub-recipients should maintain documentation of the reason for the delayed filing. Recipients and sub-recipients taking advantage of this extension would still qualify as a “low-risk auditee.”

So, for example, a June 30, 2020, year-end single audit that has not yet been submitted will have until September 30, 2021, to submit the audit (i.e., 6-months after the normal due date of March 31, 2021). Further, a December 31, 2020, single audit that has not yet been submitted will have until March 31, 2022, to submit the audit (i.e., 6 months after the normal due date of September 30, 2021). This new extension is longer than the previous extension provided in the OMB Compliance Supplement Addendum, which was only for 3 months, extends to later fiscal year-ends, and is not linked to the receipt of COVID-19 funding. OMB also reminds auditees and auditors that the “30 calendar days after receipt of the auditor’s report” aspect of the single audit due date continues to apply. Finally, on a cautionary note, last year OMB originally provided a 6-month extension that was later reduced to 3-months for certain year-ends. So, there is a precedent for OMB to revise its current position in the future.