On March 19, 2021 the Office of Management and Budget (OMB) issued Memorandum M-21-20 that includes a six-month extension (beyond the normal due date) for single audit submissions of organizations with fiscal year-ends through June 30, 2021. The extension applies to organizations that have not yet submitted their single audit submission to the Federal Audit Clearinghouse as of March 19, 2021.
As an example, a December 31, 2020 year-end single audit would normally be due September 30, 2021, but under the current extension, it is now due March 31, 2022.
A few items to keep in mind:
- Organizations should maintain documentation of the reason for the delayed filing.
- Organizations taking advantage of this extension may still qualify as a “low-risk auditee” and this extension is not linked to the receipt of COVID-19 funding.
On a cautionary note, last year the OMB originally provided a six-month extension that was later reduced to a three-month extension for organizations with certain year-ends. So, there is precedent for OMB to revise its current position in the future. We will monitor and communicate any changes in the current guidance.
If you have questions or concerns regarding this Client Alert, please contact Jim Quaid at firstname.lastname@example.org or your ORBA advisor.