On March 20, 2021, the Office of Management and Budget (OMB) issued a Memorandum (M-21-20), Promoting Public Trust in the Federal Government through Effective Implementation of the American Rescue Plan Act and Stewardship of the Taxpayer Resources, that included information about how agencies should apply certain flexibilities provided in Appendix 3, Disaster Relief Flexibilities to Reduce Burden for Financial Assistance, as well as other flexibilities as permitted by law. The purpose of these flexibilities is to identify synergies across programs and agencies that alleviate burden for recipients.
Some of the flexibilities listed include:
- A waiver of certain procurement requirements contained in 2 CFR § 200.319(b) regarding geographical preferences and 2 CFR § 200.321 regarding contracting small and minority businesses, women's business enterprises, and labor surplus area firms.
- An extension of federal and other required reports up to three months beyond the normal due date.
- A 6-month single audit submission extension for single audits that have not yet been submitted. This extension is applicable to all recipients and subrecipients that have not yet filed their single audits with the Federal Audit Clearinghouse as of March 19, 2021 and have fiscal year-ends through June 30, 2021. This extension will allow recipients to delay the completion and submission of the Single Audit reporting package, as required under Subpart F of 2 CFR § 200.501 to six months beyond the normal due date. No further action or approval is required to receive the extension, however, recipients and subrecipients should maintain documentation of the reason for the delayed filing.
A summary of the extended deadlines for some common fiscal year-ends:
| Fiscal Year End |
Original Due Date |
Extended Due Date |
| June 30, 2020 |
March 31, 2021 |
September 30, 2021 |
| September 30, 2020 |
June 30, 2021 |
December 31, 2021 |
| December 31, 2020 |
September 30, 2021 |
March 31, 2022 |
| March 31, 2021 |
December 31, 2021 |
June 30, 2022 |
| June 30, 2021 |
March 31, 2022 |
September 30, 2022 |
We are encouraging all Not-for Profit organizations that apply or have received federal assistance to review this memo, and specifically, Appendix 3 to determine if they can apply any of the other flexibilities listed. If you have any questions regarding these new changes or reporting requirements for Single Audits, please don’t hesitate to contact Ryan Lindsay at rlindsay@ggmcpa.net.