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

1. This is an addendum to the 2021 Single Audit Compliance Supplement and, specifically, the revision is Addendum 3
2. 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
3. This alternative is intended to reduce the burden of a full Single Audit or Program-Specific Audit on eligible recipients and practitioners
4. This alternative applies to fiscal year audits beginning after June 30, 2020
5. Attestation would result in an auditor’s opinion on compliance which includes an assessment of two activities, specifically “activities allowed” and “unallowed/allowable cost”
6. Attestation is optional – any SLFRF direct recipient can decide to perform a Single Audit instead even if they are eligible for attestation
7. Eligibility is limited:
1. Attestation (instead of SA) eligibility would only apply to direct recipients from Treasury receiving under $10M in total
2. 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
8. Single Audit would still apply if the recipient spends over $750K in ANY OTHER federal funds
9. 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.