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The information below has been updated as of March 24, 2021, and reflects the most recent guidance provided by OMB Memo M-21-20.

Due to COVID-19, the federal government has significantly increased its federal funding. This increase has caused many entities to surpass the Office of Management and Budget’s (OMB) $750,000 threshold that requires a single audit and, by extension, filing of a Data Collection Forms (DCF) with the Federal Audit Clearinghouse (FAC).

FAQ 1:

Answer 1:

FAQ 2:

Answer 2:

FAQ 3:

Answer 3:

FAQ 4:

Answer 4:

Given the increased volume, has the OMB granted extensions?

Yes. The OMB granted multiple extensions related to the DCF filing deadlines. However, some of those extensions were later rescinded. The extensions and recensions have occurred quickly, so keeping up-to-date is difficult.

Were extensions granted for all entities receiving federal funding?

Yes. However, there are caveats that exist. While extensions were granted to all entities, those with fiscal years ending subsequent to December 31, 2019, that did not expend COVID-19 funding, do not qualify for the OMB’s extensions, unless the DCF had not been filed as of March 19, 2021. On March 19, 2021, OMB Memo M-21-20 provided for an extension six months beyond the normal filing date for all entities with a year end of June 30, 2021. Below, the extensions have been categorized into three groups. You may refer to the following FAQs for more information regarding each group.

  • FAQ 4: Organizations that expended COVID-19 funding and filed prior to March 19, 2021
  • FAQ 5: Organizations that did not expend COVID-19 funding and filed prior to March 19, 2021
  • FAQ 6: All organizations that did not file prior to March 19, 2021

If my organization qualifies, then where and how do we file the extension?

The described extensions are automatic. This means that no action is required by the auditee or auditor.

What are the due dates for entities that have expended COVID-19 funding and filed prior to March 19, 2021?

The following table applies only to entities that expended COVID-19 funding during the year under audit and are not covered by the extensions effective on March 19, 2021:

Fiscal Year End Date Original Due Date Current Due Date
January 31, 2020 October 31, 2020 November 2, 2021* January 31, 2021 February 1, 2021*
February 29, 2020 November 30, 2020 February 28, 2021 March 1, 2021*
March 31, 2020 December 31, 2020 March 31, 2021
April 30, 2020 January 31, 2021 February 1, 2021* April 30, 2021
May 31, 2020 February 28, 2021 March 1, 2021* May 31, 2021 June 1, 2021*
June 30, 2020 March 31, 2021 June 30, 2021
July 31, 2020 April 30, 2021 July 31, 2021 August 2, 2021*
August 31, 2020 May 20, 2021 June 1, 2021* August 31, 2021
September 30, 2020 June 30, 2021 September 30, 2021

*Note: The dates in italics have been adjusted for weekends and Federal holidays.
Source: Addendum to the 2020 OMB Compliance Supplement – Appendix VII

FAQ 5:

Answer 5:

What are the due dates for entities that did not expend COVID-19 funding and are not covered by the extensions effective on March 19, 2021?

The following table applies only to entities that did not expend COVID-19 funding during the year under audit and are not covered by the extensions effective on March 19, 2021:

Fiscal Year End Date Original Due Date Current Due Date
June 30, 2019 March 31, 2020 September 30, 2020
July 31, 2019 April 30, 2020 October 31, 2020 November 2, 2021*
August 31, 2019 May 31, 2020 June 1, 2020* November 30, 2020
September 30, 2019 June 30, 2020 December 31, 2020
October 31, 2019 July 31, 2020 January 31, 2021 February 1, 2021*
November 30, 2019 August 31, 2020 February 28, 2021 March 1, 2021*
December 31, 2019 September 30, 2020 March 31, 2021

*Note: The dates in italics have been adjusted for weekends and Federal holidays.
Source: OMB Memo M-20-26

FAQ 6:

Answer 6:

What are the due dates for all entities that did not file prior to March 19, 2021?

The following table applies to all entities required to file with the Federal Audit Clearinghouse and have not as of March 19, 2021:

Fiscal Year End Date Original Due Date Current Due Date
January 31, 2020 October 31, 2020 November 2, 2021* April 30, 2021
February 29, 2020 November 30, 2020 May 31, 2021
March 31, 2020 December 31, 2020 June 30, 2021
April 30, 2020 January 31, 2021 July 31, 2021 August 2, 2021*
May 31, 2020 February 28, 2021 March 1, 2021* August 31, 2021
June 30, 2020 March 31, 2021 September 30, 2021
July 31, 2020 April 30, 2021 October 31, 2021
August 31, 2020 May 31, 2021 November 30, 2021 November 1, 2021*
September 30, 2020 June 30, 2021 December 31, 2021
October 31, 2020 July 31, 2021 August 2, 2021* January 31, 2022
November 30, 2020 August 31, 2021 February 28 2022
December 31, 2020 September 30, 2021 March 31, 2022
January 31, 2020 October 31, 2021 November 1, 2021* April 30, 2022 May 2, 2022*
February 28, 2021 November 30, 2021 May 31, 2022
March 21, 2021 December 31, 2021 June 30, 2022
April 30, 2021 January 31, 2022 July 31, 2022 August 1, 2022*
May 31, 2021 February 28 2022 August 31, 2022
June 30, 2021 March 31, 2022 September 30, 2022

*Note: The dates in italics have been adjusted for weekends and Federal holidays.
Source: OMB Memo M-21-20

FAQ 7:

Answer 7:

What are the consequences of late filings?

If you have not filed by the date applicable in the aforementioned tables, the FAC precludes the auditee from being a low-risk auditee for the Single Audit for two subsequent years, which means that more audit work may be required.