On March 19^th, 2021 The Office of Management and Budget issued memo M-21-20 Promoting Public Trust in the Federal Government through Effective Implementation of the American Rescue Plan Act and Stewardship of the Taxpayer Resources. There are many important impacts for Federal grants. The full document may be found on the GAO website under Federal/Cost Accounting. Below are some highlights:

Appendix 3-Disaster Relief Flexibilities to Reduce Burden for Financial Assistance

Note- these exceptions apply to both COVID-19 related assistance and non-COVID-19 related assistance

• Current registrants in SAM with active registrations expiring between April 1, 2021 and September 30, 2021 will have an automatic one time extension of 180 days.
• Awarding agencies may extend awards that were active as of March 31, 2021, automatically at no cost for a period of up to 12 months.
• For non-competitive continuation requests scheduled between April 1, 2021 and December 31, 2021, awarding agencies may accept a brief statement from recipients to verify they are in a position to: (i) resume or restore their project activities and (ii) accept a planned continuation award. Federal agencies must post instructions on their website.
• Awarding agencies are authorized to waive prior approval requirements. All costs charged to Federal awards must be consistent with Federal cost policy guidelines and the terms of the award, except where specified in the memo.
• Awarding agencies may allow recipients to delay submittal of financial, performance or other reports up to the three months beyond normal due date. If an agency allows such a delay the recipient may continue to draw down Federal funds without the timely submission of these reports. However the reports must be submitted at the end of the extension period.
• The Single Audit has been extended six months past its normal due date for recipients and subrecipients that have not submitted as of March 19^th 2021 and have fiscal year ends through June 30, 2021.  Recipients and subrecipients are required to maintain documentation of the reason for the delayed filing.
• Awarding agencies may allow the grantee to delay the submission of any pending financial, performance or other reports as required by the terms of the award for closeout of expired projects, provided that proper notice is given by the grantee to the agency.
• Awarding agencies may provide grantees up to a 12-month extension for the biennial physical inventory of equipment purchased under a Federal award.

Please contact Amanda Compton at 602-542-5611, [email protected] or [email protected] with any questions or concerns.