For-Profit SVOG Recipients
In February 2022, the Small Business Administration (SBA) issued updated Post-Application Guidance for Shuttered Venue Operators Grant (SVOG) applicants, as well as Post-Award Frequently Asked Questions (FAQs). The SBA also issued a new set of Post-Award FAQs, which contain answers to many common compliance-related questions for the program.
The Post-Application Guidance, among other items, states that a for-profit entity may have either a financial statement audit or a single audit or program-specific audit to meet the SBA audit requirements. The guidance also clarifies that the due date for submission of the audit reporting package is nine months from the end of the entity’s fiscal year end.
The AICPA Governmental Audit Quality Center (GAQC) is continuing to work with the SBA SVOG team related to the compliance requirements related to the SVOG program for for-profit entities with SVOG funding. Once finalized, the SBA will post this guidance to the SVOG section of its website. SBA is in the process of developing a 2022 OMB Compliance Supplement section for this program. The GAQC is also involved in discussions with the SBA SVOG team on the nuances related to this program and for-profit entities.
CSLFRF Alternative Engagement for Certain Recipients
The U.S. Treasury issued $350 billion to over 30,000 recipients. Many of these recipients are small entities that were not previously required to have a single audit. A collaborative effort was undertaken between Treasury, the Office of Management and Budget (OMB) and the AICPA GAQC, and the national Association of State Auditors, Comptrollers and Treasurers to develop an alternative to a full single audit or program-specific audit under the Uniform Guidance for certain recipients that would be less burdensome but still uphold Treasury’s responsibility to be good stewards of federal funds.
The result of this collaboration was the Federal Register notice and the related update of the 2021 OMB Compliance Supplement. This information is also included in the 2022 OMB Compliance Supplement in Part 4 for the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) program.
The alternative engagement is a compliance examination engagement which is to be performed in accordance with the AICPA Statements on Standards for Attestation Engagements and Government Auditing Standards. The engagement will focus on two narrowly scoped compliance requirements related to Activities Allowed and Unallowed and Allowable Costs/Cost Principles.
This alternative engagement will only be available to certain eligible recipients as follows:
CSLFRF recipients that expend $750,000 or more during the recipient’s fiscal year in federal awards, and who meet both criteria listed below will have the option to follow the alternative CSLFRF compliance examination engagement:
- The recipient’s total CSLFRF award received directly from Treasury or received through states as a non-entitlement unit of local government is at or below $10 million; and
- Other federal award funds the recipient expended (not including its CSLFRF award funds) are less than $750,000 during the recipient’s fiscal year.
