On March 22, 2010, the Office of Management and Budget (OMB) issued a memorandum titled “Updated Guidance on the American Recovery and Reinvestment Act”. Although the title relates specifically to Recovery funds, the guidance contained in the memorandum is effective for all Single Audits. Here are a few of the more significant highlights from the memorandum:

• Requires federal awarding agencies to review Single Audit reports submitted to the federal clearinghouse and summarize audit findings by type of non compliance. The memorandum defines minimum actions which should be taken by federal agencies when non compliance is noted.
• Eliminates extensions for filing the Data Collection Form and related reporting package with the Federal Audit Clearinghouse. Entities with audits submitted after the nine month due date will no longer meet the criteria for a low-risk auditee for a two year period following a late submission.
• Implements a “continuous corrections” period for correcting data to FederalReporting.gov. The continuous corrections period allows recipients to correct reported data for the immediately preceding reporting period after the quarter has ended and after the data is published on FederalReporting.gov. Prior to this memorandum no corrections could be made to data once the data was published on Recovery.gov. Under the new process the Recovery.gov data will be updated approximately every two weeks to reflect corrections made.
• Establishes quality reviews of corrections made by recipients. Federal agencies are now required to establish procedures to review data which has been corrected during the continuous corrections period. The procedures are not defined in the memorandum but the Federal agency must focus on “significant reporting errors, material omissions and administrative/technical problems”. At a minimum the Federal agency must conduct a final review of the data upon the close of the continuous corrections period.
• Provides guidance to federal agencies to help eliminate common administrative/technical matters in reporting. The memorandum also defines administrative/technical matters and separates them from significant errors or material omissions data quality issues.
• Allows federal agencies to post their own program-specific guidance for recipient reports as long as the guidance does not conflict with OMB guidance. The memorandum also requires all program-specific guidance to be reviewed by the OMB prior to issuance by the federal agency.
• Federal agencies are required to compile a comprehensive list of all awards subject to the Recovery Act, Section 1512 reporting requirements which will be compared to the Section 1512 data provided by grantees. A list of known exclusions is also included in the memorandum.
• Defines when a recipient is no longer required to submit Section 1512 reports. A recipient will indicate a “Y” in the final report date field in FederalReporting.gov if the report is considered final and there will be no future reports submitted. Final reporting requirements may be met if the award period has ended AND all recovery funds are received and the project status is complete OR the award has been terminated or cancelled.

Click here for the full memorandum. For further information, contact Lewis, Hooper & Dick, LLC at (620)275-9267.

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