Something to be aware of if you are a nonprofit organization is the potential effect of COVID-19 relief funding on single audits. A nonprofit organization which expends $750,000 or more in federal financial assistance within one year must have a single audit. Grants, cost reimbursement contracts and loans, among other sources of funding, can be included in determining whether the $750,000 threshold is achieved. The Uniform Guidance is the authoritative set of rules and requirements for Federal awards.

The AIPCA has asked the U.S. Office of Management and Budget (OMB) a series of questions about the impact of relief funding on the need to have a single audit which you can download here.

Here is what the AICPA has said regarding whether Paycheck Protection Program (PPP) loans and Economic Injury Disaster Loans (EIDL) are subject to single audit:

One of the most common questions we have received is whether SBA PPP loans obtained by NFPs are subject to the Uniform Guidance single audit requirements. The good news is that we have recently received an answer to this question. Based on recent discussions with SBA staff, we have been informed that PPP loans made to NFPs will not be subject to single audit.

On the other hand, SBA informed us that loans made to NFPs under the EIDL program are considered a direct loan program disbursed from SBA to loan recipients. Therefore, these loans are considered federal financial assistance and are subject to the Uniform Guidance single audit requirements.

On March 19, 2020, the OMB released a memo apparently allowing a six-month extension for auditees to submit their single audit. Although according to the AICPA the memo has caused confusion:

The memo is not [emphasis added] instructing federal agencies to provide a blanket waiver for all recipients impacted by COVID-19. Instead, its guidance primarily relates to recipients receiving funds disbursed from the approximately $9 billion in emergency supplemental appropriations for coronavirus preparation and response (H.R.6074). Note that there could be cases where agencies may decide to apply the guidance in the memorandum for existing awards that are deemed by the agency to be for continued research and services necessary to carry out the emergency response relating to COVID-19.

Guidance is expected soon.