OMB Issues New Guidance on Single Auditing for Pandemic Relief Programs

January 6, 2022

The Office of Management and Budget (OMB) recently issued Addendum No. 1 to the 2021 Compliance Supplement, providing guidance for auditing funds received from the Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) and an update to the Education Stabilization Fund (ESF) program section. More guidance is expected later this month.

For audits with report dates prior to the Dec. 3, 2021, issuance of Addendum No. 1, auditors are not required to go back retroactively to review the CSLFRF or the ESF Addendum No. 1 program sections.

AICPA Governmental Audit Quality Center (GAQC) Alert No. 435 states that the CSLFRF program section in Addendum No. 1:

  • Names the compliance requirements subject to audit
  • Clarifies that the "beneficiary" concept presented in the Coronavirus Relief Fund also applies to the CSLFRF
  • Examines revenue loss-related issues
  • Provides guidance on the amounts to be included on the schedule of expenditures of federal awards for the program

The original release of the 2021 Compliance Supplement included the ESF program. Addendum No. 1 updates Section 1 (elementary and secondary education) of the ESF program for funding implications for subprograms 84.425U and 84.425X related to the American Rescue Plan Act (ARPA). Because ARPA implications for Section 2 (higher education) were addressed in the original release of the ESF program section in the 2021 Compliance Supplement, Section 2 is not included in Addendum No. 1.

The OMB stated that there will be a second addendum to the 2021 Compliance Supplement, which is expected to be issued later this month. Addendum No. 2 will primarily address new funding provisions in the ARPA related to the following programs:

  • Pandemic Electronic Benefit Transfer (EBT) funds
  • Section 8 Housing Choice Vouchers
  • National Railroad Passenger Corporation Grants
  • Low Income Household Water Assistance Program
  • Temporary Assistance for Needy Families
  • Child Care Development Fund Block Grant

For more information on single audit best practices and requirements, visit the GAQC website.