OMB Issues Guidance to Federal Agencies, Including Single Audit Due Date Extension

Posted on Mar 20, 2020

This article was updated on 4/1 to address further clarification from OMB leadership. 

As a follow up to Office of Management and Budget (OMB) Memo M-20-11, the OMB has recently issued Memo M-20-17. The Memo addresses Federal awarding agencies and provides more flexibility to an expanded scope of recipients who have experienced loss of capacity and increased costs as a result of the COVID-19 pandemic.

The purpose of the Memo is to communicate additional flexibilities federal awarding agencies may provide to federal award grantees. Using the Memo, federal awarding agencies are tasked with communicating these additional flexibilities via grants policy statements, or other communications, directly to their federal award grantees. Be on the lookout for information from your federal awarding agency on the specific flexibilities that may be available to your organization and what you will need to do to take advantage of them.

Appendix A to OMB Memo M-20-17 provides a six-month extension of the Single Audit for impacted recipients with fiscal year ends through June 30, 2020; this includes December 31, 2019. The Memo specifically mentions that no approval from awarding agencies is needed to extend the Single Audit deadline as long as recipients and subrecipients document the reason for the delayed filing.

In a recent OMB grants webinar, Senior Policy Analyst Gil Tran indicated that the Single Audit extension would be available for June 30, 2019 year end Single Audits currently due March 31, 2020. However, Mr. Tran indicated that the OMB would reassess the extension after 90 days to determine how the extension would be applied, for example, by entities having a June 30, 2020 year end where the Single Audit is not due until March 31, 2021. Questions on your particular situation can be directed toward your Single Audit team and/or the OMB via email at:

In addition to the Single Audit extension, Appendix A of the Memo provides a summary of other exceptions being made available to grant recipients upon approval of awarding agencies. These exceptions include flexibilities with application deadlines, allowability of salaries charged to federal awards with paused activities, allowability of certain costs not normally charged to federal awards, and extension of currently approved indirect cost rates, among others. Again, individual federal agencies will need to communicate directly to their grant recipients on which of these flexibilities will be provided and what actions, if any, are needed by the grant recipients to take advantage.

The Memo states that these exceptions are time limited and will be reassessed by the OMB within 90 days of the Memo.

If you have any questions regarding M-20-17, or the impacts of the coronavirus pandemic on your organization, please contact your Clark Nuber advisor.

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