The Council on Governmental Relations (COGR), representing over 190 member institutions, submitted comments to the Office of Management and Budget (OMB) regarding the 2021 Compliance Supplement for 2 CFR Part 200, Subpart F. The correspondence, addressed to Mr. Gilbert Tran, thanks OMB for its efforts and highlights several concerns centered on audit requirements for federal grants, particularly in the context of COVID-19 relief programs such as the Higher Education Emergency Relief Fund (HEERF). COGR requests explicit guidance clarifying that institutions can report retroactive reimbursements for lost revenue in the fiscal year a claim is made, rather than restating prior year financial statements. They also urge OMB to clarify that institutions may request reimbursement after an expense is recorded in their accounting systems, aligning with existing federal cash management regulations, to reduce unnecessary audit burdens.
Furthermore, COGR emphasizes the need for "audit reasonableness" in single audits, especially given the rapidly evolving guidance and the exceptional challenges brought on by pandemic-related relief measures. The organization advocates for consistent and pragmatic interpretations of audit requirements, active engagement among stakeholders, and the prioritization of efficiency and quality in audits. COGR expresses its readiness to collaborate further with OMB to advance these objectives and ensure sound oversight of federal funds during this unprecedented period.
