The Office of Management and Budget (OMB) recently released new guidance that allows streamlined financial review for some recipients of Fiscal Recovery Funds under the American Rescue Plan Act (ARPA). 

Previous guidance subjected all recipients and subrecipients of federal funds to audit under the Single Audit Act if they expended more than $750,000 in federal awards during a single fiscal year. OMB’s new guidance, Addendum 3, creates an alternative to the single audit requirement. This alternative will allow some counties to opt for attestation instead, which will greatly help rural counties and other counties for whom a full audit is too burdensome. 

While audits require financial statements, internal control testing, and many separate compliance requirements, the attestation would evaluate counties based on two compliance factors: whether the county uses Recovery Funds for eligible uses, and whether the county properly reports costs incurred by the pandemic. 

Only counties that received less than $10 million in Fiscal Recovery Funds and that spent less than $750,000 of non-ARPA federal funds in a single fiscal year are eligible for attestation. OMB’s guidance aims to give the attestation option to counties that would otherwise be exempt from the Single Audit if not for expenditure of Recovery Funds. 

The attestation alternative applies to fiscal year audits beginning after June 30, 2020. Even if eligible for attestation, counties must opt into attestation. Any direct recipient of Recovery Funds may choose to perform an audit even if they are eligible for attestation. Additionally, regardless of whether a recipient performs an attestation or a single audit, all uses of Recovery Funds must follow the Uniform Guidance.