Changes are everywhere due to COVID-19 including regularly scheduled filing deadlines which are now being adjusted by the government.
One of the most significant for nonprofits with federal funding is a six-month submission extension on any OMB compliance audits that are not yet submitted, including audits through the upcoming June 30, 2020 fiscal year-end. The good news is this extension is broad and does not require the recipient agencies to take any other action for the six-month extension to become effective. However, organizations should be mindful of the requirement they maintain documentation on file that includes the reasons for the delayed filing.
The following summary provided by the AICPA provides an overview of the COVID-19 Related Deadline Extensions of Audited Financial Statements and Other Reports:
| Federal Agency |
Entity Type |
Reporting Due |
Original Due Date | Extended Due Date | Notes | Links |
| Office of Management and Budget (OMB) – Single Audit | Recipients subject to the Uniform Guidance that have experienced a loss of operational capacity and increased costs due to COVID-19. | Single audit submission (i.e., reporting package described in section 200.512(c) and data collection form) including the financial statement audit under Government Auditing Standards and the compliance audit. | Fiscal year ends through June 30, 2020. | 6 months beyond the normal due date. The normal due date is the earlier of 30 calendar days after receipt of the auditor’s report(s), or nine months after the end of the audit period. | This is a broad extension and 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. OMB Memo M-20-17 does note that the delayed completion and submission would still qualify the grantee as a “low-risk auditee.” |
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| OMB – Single Audit | Recipients subject to the Uniform Guidance receiving funds for coronavirus preparation and response under H.R. 6074. Note that per OMB Memo M-20-11, there could be cases where agencies may decide to apply the guidance in the memo to existing awards that are deemed by the agency to be for continued research and services necessary to carry out the emergency response relating to COVID-19. | Single audit submission (i.e., reporting package described in section 200.512(c) and data collection form), including the financial statement audit under Government Auditing Standards reporting and the compliance audit. | 12 months beyond the normal due date. The normal due date is the earlier of 30 calendar days after receipt of the auditor’s report(s), or nine months after the end of the audit period. | M-20-11 instructs “awarding agencies” that they can extend the submission deadline. It is still unclear how an awarding agency can authorize an extension when the recipient has awards from various federal agencies. We have submitted this question to OMB. OMB Memo M-20-11 does note that the delayed completion and submission would still qualify the grantee as a “low-risk auditee.” |
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| U. S. Department of Housing and Urban Development (HUD) | Multifamily Housing (entities subject to the audit requirements in chapter 3 of the HUD Consolidated Audit Guide) | Audited Financial Statements, Compliance Audit, Agreed-Upon Procedures (AUP) engagement | 3/31/2020 or 4/30/2020 | 6/30/2020 | HUD’s Real Estate Assessment Center had previously provided a 30-day extension for multifamily audit submissions having due dates of 3/31/20 and 4/30/20 (requiring them to be submitted by April 30th and May 31st respectively). In early May, HUD further extended these submission deadlines to June 30, 2020. | A new user alert announcing the June 30, 2020, revised deadline has been posted by HUD. To view, log into the Financial Assessment Subsystem – Multifamily Housing site. |
| HUD | Lenders – Single Family Housing (lenders subject to chapter 7 of the HUD Consolidated Audit Guide) | Audited Financial Statements, Compliance Audit, AUP Engagement | 3/31/2020 | 4/30/2020 | See Question 4 of the Questions and Answers document. Although this question refers to an extension of the annual recertification, FHA staff confirmed the extension applies to the engagements referred to in the “Reports Due” column. |
COVID-19 Questions and Answers
See also FHA’s Single Family COVID-19 Web site
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| HUD | Ginnie Mae (lenders subject to the audit requirements in chapter 6 of the HUD Consolidated Audit Guide) | Annual Audited Financial Statements | 3/31/2020 | 4/30/2020 | The deadline extension document encourages lenders that can complete the Annual Audited Financial Statements within 90 days after the end of the fiscal year to do so. | Annual Audited Financial Statement Deadline Extension (APM 20-02) |
| HUD | Public Housing Agencies (PHAs) | Unaudited submissions by PHAs with 12/31/2019 and 3/31/2020 year ends | 2/29/2020 & 5/31/2020 | 8/31/2020 & 11/30/2020 | QC14 of the PHA FAQs extends the submission deadline for unaudited submissions. PHAs are not required to seek HUD approval for these extensions. |
COVID-19 FAQs for Public Housing Agencies
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| U.S. Department of Agriculture (USDA) | Electric and telecommunications borrowers | Annual audit required under 7 CFR 1773, Rural Utilities Service Policy on Audits of RUS Borrowers and Grantees. | See 7 CFR 1773 for reporting deadlines. | 60-day extension for audits due to USDA in March or April 2020 | A USDA letter sent to electric and telecommunications borrowers and grantees specifies that the 60-day extension applies to audits due to USDA in March or April 2020. |
USDA Rural Development COVID-19 Resources
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| USDA | Multifamily Housing | Section 515 Annual Financial Statements | 3/31/2020 | 4/30/2020 | USDA is exploring whether a longer extension is appropriate and will provide further guidance. |
USDA Rural Development COVID-19 Resources
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| U.S. Department of Energy – NNSA (National Nuclear Security Administration) | For-profit entities | Compliance audits required under 2 CFR § 910.501 Audit Requirements | Fiscal year-ends through June 30, 2020 | 6 months beyond the normal due date | No formal approval for this extension is required; however, recipients and sub-recipients must maintain documentation of the reason for the delayed filing. |
COVID-19 Attachment 2: DOE-NNSA Implementation of OMB Memo M-20-17
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