US Treasury allows audit flexibility for smaller counties for ARPA funds
Under current guidance, recipients and subrecipients that expend more than $750,000 in federal awards during their fiscal year will be subject to an audit under the Single Audit Act and its implementing regulation at 2 CFR Part 200, Subpart F regarding audit requirements. Addendum 3 changed this requirement for counties that received less than $10 million in Recovery Funds.
This will help our rural counties significantly.
Top ten things you should know about Addendum 3 to the 2021 Single Audit Compliance Supplement
If a county is eligible, you should discuss this with your Auditor
- This is an addendum to the 2021 Single Audit Compliance Supplement and, specifically, the revision is Addendum 3
- Addendum 3 includes a simplified Single Audit process (an “Attestation”) for those direct recipients that are considered exempt from the Single Audit if it was not for the expenditures of SLFRF funds
- This alternative is intended to reduce the burden of a full Single Audit or Program-Specific Audit on eligible recipients and practitioners
- This alternative applies to fiscal year audits beginning after June 30, 2020
- Attestation would result in an auditor’s opinion on compliance which includes an assessment of two activities, specifically “activities allowed” and “unallowed/allowable cost”
- Attestation is optional – any SLFRF direct recipient can decide to perform a Single Audit instead even if they are eligible for attestation
- Eligibility is limited:
- Attestation (instead of SA) eligibility would only apply to direct recipients from Treasury receiving under $10M in total
- Attestation (instead of SA) eligibility would apply to direct recipients only if other Federal award funds the recipient expended are less than $750,000 during the recipient’s fiscal year – not including their SLFRF award funds
- Single Audit would still apply if the recipient spends over $750K in ANY OTHER federal funds
- Uniform Guidance (UG) still applies to ALL expended funds, whether the recipient performs an Attestation or a Single Audit
Additionally, Treasury also just notified NACo that there are some phishing emails being send to ARPA recipients (mostly Non-Entitlement Cities, but may include counties) asking them to pay money for SAM.gov renewal. SAM.gov DOES NOT charge any fee for renewal. If a county receives this email, they should notify SLFRP@treasury.gov.