By Allison M. Henry, CPA, CGMA, PICPA vice president – professional and technical standards

The PICPA has have been actively reaching out to practitioners to raise awareness that many organizations that received more than $750,000 in COVID relief funds could be required to have a single audit or a program audit. This may result in about 10,000 new single audits nationally; many among for-profit entities that may not have previously had a financial statement audit. If your clients received relief funds, it is important to research the applicable compliance requirements.

The best source of information on compliance requirements can be found on SAM.gov under Assistance Listings. The assistance listings change periodically, so be sure to check directly with the relevant agency information. This resource can be used to determine if the program requires a single audit and which Uniform Guidance subparts apply. The final Office of Management and Budget (OMB) compliance supplement should be referred to for authoritative guidance on COVID-19 programs. The AICPA Governmental Audit Quality Center (GAQC) maintains for Quality Center members a nonauthoritative list of programs and the related audit requirements.  

Funds received from the Paycheck Protection Program and the Economic Injury Disaster Loan Emergency Advance are not subject to single audit requirements. Here are links to the relevant guidelines within SAM.gov for a couple frequently researched programs: Restaurant Revitalization Fund and Shuttered Venue Operators Grant Program.

Single audits are generally considered to be high-risk engagements. If you never performed a single audit and are considering performing one, it is important to make sure that you obtain the relevant competencies before providing these services. There are many ongoing challenges in auditing pandemic relief funds. The GAQC continues to work with federal agencies to clarify the single audit requirements related to pandemic assistance (e.g., the timing of when that funding should be included on the Schedule of Expenditures of Federal Awards, new guidance for auditing funds received from the Coronavirus State and Local Fiscal Recovery Fund, and an update to the Education Stabilization Fund program section of the compliance supplement). If you should decide to take on a single audit, GAQC membership is an important and valuable resource.

If you have specific questions regarding this guidance, please reach out to me at ahenry@picpa.org.

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