Institutions have swiftly shifted sponsored program administration practices in response to the COVID-19 pandemic, most especially to account for the administrative flexibilities authorized by Office of Management and Budget (OMB) Memorandums M-20-11, M-20-17 and M-20-26 and new CARES ACT funding. However, with flexibility comes accountability, and institutions can expect that their adapted practices and internal controls will be reviewed as part of their annual Single Audit, or potential sponsor or award-specific audits, to provide assurance of compliance with the administrative flexibilities in conjunction with the standard Uniform Guidance regulations and award-specific terms and conditions.
The Uniform Guidance's emphasis of internal controls as a critical component of federal program administration has resulted in the evaluation and testing of internal controls as a part of an institution’s annual Single Audit, and since the Uniform Guidance went into effect in 2014, many institutions have taken steps to centrally document and evaluate internal controls to facilitate the Single Audit process. Considering the potential impact of the OMB administrative flexibilities on internal controls, it is advisable for institutions to proactively ensure that new or changed controls are well documented prior to the onset of the fiscal year 2020 Single Audit. Released in December 2020, the OMB 2020 Compliance Supplement specifically provides supplementary guidance on the Single Audit focus and procedures applicable to COVID-19 awards.
To help institutions document updated controls and prepare for the upcoming Single Audit covering CARES Act spending as well as the period of the COVID-19 slowdown and subsequent reentry, Huron has designed a COVID-19-focused internal controls pre-audit questionnaire. Use this questionnaire as a starting point to assist in documenting and evaluating institutional controls related to the OMB administrative flexibilities and COVID-19 funding so that the information can be easily provided to auditors and enable a smooth Single Audit and positive outcomes.
Huron has extensive experience helping institutions assess and implement effective controls and successfully navigate the Single Audit process. Our experts partner with research and higher education institutions to implement effective compliance programs, effectively manage federal funding in line with regulatory requirements and respond to sponsored programs audits to minimize findings and achieve positive results. If you have concerns about your institution’s preparedness for the Single Audit encompassing the pandemic period, contact one of our leaders today.