Are my stimulus dollars subject to the Uniform Guidance?
By Stefanie Cohn, Partner-in-Charge, Assurance, Washington, DC
The stimulus dollars have been very appreciated in the non-profit community. Since the announcement about the Paycheck Protection Program and the Economic Injury Disaster Loans (EIDL), Marcum’s phones and emails have been filled with questions on these programs. My favorite emails have been the ones where my clients have reached out to say they have been approved for a PPP loan and the funds are on the way.
One of the most common questions I have gotten is whether these loan funds will be subject to a Uniform Guidance audit. Some of these clients have never had a Uniform Guidance audit before, and this would just be one more thing to deal with in the sea of uncertainty that we are all facing.
On April 10, 2020, the AICPA Government Audit Quality Center sent a seven-page letter to the U.S. Office of Management and Budget Office of Federal Financial Management and shared it with several Offices of Inspector Generals of various federal agencies, asking this as well as many other questions. Although many of the questions are still unanswered, yesterday we received an alert from the AICPA Government Audit Quality Center which, based on recent discussions with the Small Business Association (SBA) staff, offered the following answers:
- PPP loans made to nonprofits will not be subject to a single audit under the Uniform Guidance.
- EIDL loans are considered direct lending from the SBA. As such, they are classified as federal financial assistance and are therefore subject to the single audit requirements under the Uniform Guidance.
- If you received money under the Education Stabilization Fund, CFDA #84.425B through CFDA #84.425M, these funds are also subject to the single audit requirements under the Uniform Guidance.
- If you received an EIDL loan, the amount subject to the single audit will be the value of the new loans made or received during the audit period plus the beginning of the audit period balance of loans from previous years for which the federal government imposes continuing compliance requirements, plus any interest subsidy, cash, or administrative costs allowed received. The rules for loans at institutions of higher education are slightly different.
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