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New Alternative for NEUs to the Single Audit Report for American Rescue Plan Funds

Posted on April 8, 2022 by John LaMacchia

The Office of Management and Budget released an Addendum 3 to the 2021 Single Audit Compliance Supplement. Addendum 3 includes a simplified Single Audit process designed for entities that would otherwise not be required to undergo an audit pursuant to 2 CFR Part 200, Subpart F, if it was not for the expenditures of State and Local Fiscal Relief Funds (SLFRF) directly awarded by Treasury.

As described in Addendum 3, Part IV. Other Information, SLFRF recipients that expend $750,000 or more during their fiscal year in Federal awards and meet both criteria listed below have the option for their auditor or practitioner to follow the Alternative Compliance Examination Engagement guidance. The criteria are:

  1. The recipient’s total SLFRF award received directly from Treasury or received (through states) as a non-entitlement unit of local government is at or below $10 million; and
  2. Other Federal award funds the recipient expended (not including their SLFRF award funds) are less than $750,000 during the recipient’s fiscal year.

This is an addendum to the 2021 Single Audit Compliance Supplement and, specifically, the revision is Addendum 3.

Addendum 3 includes a simplified Single Audit process (an “Attestation”) for those direct recipients that are considered exempt from the Single Audit if it was not for the expenditures of SLFRF funds. This alternative is intended to reduce the burden of a full Single Audit on eligible recipients. This alternative applies to fiscal year audits beginning after June 30, 2020.

Attestation would result in an auditor’s opinion on compliance which includes an assessment of two activities, specifically “activities allowed” and “unallowed/allowable cost.”

Finally, Uniform Guidance (UG) still applies to ALL expended funds, whether the recipient performs an Attestation or a Single Audit.

John LaMacchia is the League’s director of state & federal affairs. He can be reached at jlamacchia@mml.org or 517-908-0303.

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