Related to The American Rescue Plan Act
In March, the American Rescue Plan Act (ARP) was signed into law to provide additional funding resources, resulting in significant implications to both new and existing federal programs. These new funds must be added to an organization’s single audit, and include:
Coronavirus State and Local Fiscal Recovery Fund provides over $350 billion to states, tribal entities, U.S. territories, and local governments with more direct funding to local governments. The determination whether this fund will be subject to single audit requirements is still to be determined as well as if this fund is one program or multiple programs.
Emergency Stabilization Fund (ESF) provides funding of $165 billion. This fund gives $120 billion to the Elementary and Secondary School Emergency Relief subprogram and $40 billion to the HEERF subprogram.
Emergency Rental Assistance Program is an existing program that will receive an additional $21 billion in new funding.
A Memorandum for the Heads of Executive Departments and Agencies is providing guidance on ensuring robust and transparent reporting from organizations that are requesting funding from the federal government. A key item is on the single audit submission extension which provides a submission extension, encourages application of Uniform Guidance to ARP funding, an OMB approval process, for-profit recipient guidance, and higher risk recipient guidance.
This includes allowing recipients and sub-recipients that have not yet filed their single audits with the Federal Audit Clearinghouse as of March 19, 2021, that have fiscal years ending through June 30, 2021, to delay the completion and submission of the Single Audit reporting package to six months beyond the normal due date. It also encourages applying the requirements of Title 2, Code of Federal Regulations (CFR) to the Grant and Agreements in Uniform Guidance and submitting proposed implementation of 2 CFR part 200 to OMB for approval prior to program administration and award issuance. The memo encourages the application of 2 CFR Part 200 toward for-profit entities and states that ARP programs may be considered and identified as higher risk programs and therefore would be required to be tested as a Single Audit major program.
For the latest information on single audits, or to ask questions, please reach out to BPM’s Nonprofit Industry Group Co-leader Shannon Winter, CPA.