PRAC Chart Lists CARES Act Programs Subject to Uniform Guidance, Single Audits

Jerry Ashworth
June 24, 2020 at 09:11:58 ET
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They say a picture is worth a thousand words. Well, sometimes a chart can be just as worthy. Leave it to the Pandemic Response Accountability Committee (PRAC) to develop a comprehensive assistance listing chart that lists all of the federal programs affected by the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) (Pub. L. 116-136) and other related supplemental relief packages and denotes whether they are subject to the Office of Management and Budget’s uniform guidance and whether funding under these programs are subject to a single audit.

Along with that particular information, the chart also lists the federal agency and subagency, the statutory reference, Assistance Listing (formerly the CFDA) number and whether this number is new, the associated Treasury Account Symbols, the name of the program, the type of program (i.e., grant, loan, direct payment), and a link for additional guidance.

For example, the chart denotes that because the Department of Agriculture’s Coronavirus Food Assistance Program provides direct payments with unrestricted use, it is neither subject to the uniform guidance nor is it subject to a single audit. This case is the same for payments under the Small Business Administration’s Paycheck Protection Program (PPP), which may come as a relief to many PPP recipients that have questioned whether they would be required to meet these grant and audit rules.

The chart notes that some current grant programs that received CARES Act supplemental funding, such as the Department of Veterans Affairs Veterans State Nursing Home Care program, are required to following the uniform guidance, but recipients will not be required to obtain a Subpart F single audit. Conversely, several current tribal grant programs overseen by the Department of the Treasury that received CARES Act supplemental funding, such as the Indian Employment Assistance program and the Indian Postsecondary Schools program, are not required to follow the provisions in the uniform guidance, but they are subject to a Subpart F single audit.

The chart lists over 200 federal programs. Recipients, as well as auditors conducting single audits, should take a look at this chart to determine that the program for which they are receiving relief funding is covered under the uniform guidance and Subpart F. The links for additional guidance also could prove especially helpful in ensuring that this funding is administered properly, and that they are up-to-date on the latest agency requirements. This chart truly will be needed for those small entities that have never met the $750,000 single audit threshold who now may wind up expending that much in new emergency relief funding.

Thanks to our friends at the National Association of State Accountants, Comptrollers and Treasurers for providing a link to the chart. Go here and scroll down to the Pandemic Response Accountability Committee subhead to find the chart in an Excel file.

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