The Governmental Audit Quality Center (GAQC) was provided draft sections of the 2020 OMB Compliance Supplement addendum for review and comment. The review comprised a total of 14 programs (some new and some existing), including drafts of the Coronavirus Relief Fund (CRF), the Provider Relief Fund (PRF), and the Education Stabilization Fund. We are not able to share the drafts of programs reviewed.
On September 29, 2020, we submitted comments on each program that were substantial. As a result, we developed a comment letter containing overarching comments and concerns that accompanied our detailed comments. We encourage members to review the letter. Our major concerns include significant issues with the PRF program (see next section for more on this program); a lack of guidance on donated personal protective equipment; and an overall approach taken that shifts the onus of understanding and implementing requirements for new COVID-19-related programs and compliance requirement changes for existing programs to recipients and auditors without proper direction from the relevant federal agencies. We encourage auditors and auditees to read our AICPA-GAQC comment letter.