COVID-19 Related Filing Changes

The COVID-19 pandemic has led to several changes in financial reporting deadlines as detailed below:

Single Audit Filing Extension: The U.S. Office of Management and Budget (OMB) has issued a memorandum providing short term relief for administrative, financial management, and audit requirements under 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards. For recipients and sub-recipients of federal funds that have not yet filed their Single Audits with the Federal Audit Clearinghouse as of March 19, 2020 that have fiscal year-ends through June 30, 2020, there is an extension of 6 months beyond the normal due date. This extension does not require individual recipients and sub-recipients to seek approval for the extension by the cognizant or oversight agency for audit; however, your organization is required to maintain documentation on file for the reason for the delayed filing.

There have been numerous questions about payroll costs being allowed when recipients' operations have been affected by COVID-19. The memorandum instructs federal agencies to allow recipients to continue to charge salaries and benefits to currently active federal awards consistent with the recipients’ policy of paying salaries under unexpected/extraordinary circumstances from all federal and non-federal funding sources. Your organization should maintain appropriate records and cost documentation to substantiate the charging of any salaries/other project activity costs related to the interruption of your operations and services. Awarding agencies may allow recipients who incur costs related to the cancellation of events, travel, or other activities necessary for award performance. Again, you should maintain appropriate records and cost documentation to substantiate the charging of any cancellation or other fees related to interruption of operations or services. Other areas of guidance in the memo include exemptions of certain procurement requirements, extensions of currently approved indirect cost rates, and other various application and reporting waivers and extensions.

PA DCED Filings: The legislative due date of April 1st to submit the DCED Annual Audit and Financial Report has not changed. However, municipalities and authorities will not be penalized if they have not submitted their reports by April 1st.

IRS Form 990/990T Filings: The IRS has extended the deadline of IRS Form 990 filings to July 15th.

PA BCO-1O Filings: The Pennsylvania Bureau of Corporations and Charitable Organizations is accepting PA BCO-10 Filings online in addition to mailed registrations delivered by the U.S. Postal Service. The State is in the process of sending out emails to all registrants regarding the filing changes. The email includes a unique code to allow the organization to link their Keystone Login profile to the BCO registration and requires those without a Keystone Login to get one. Please refer to the online portal for additional information which contains a link to register/log-in. On April 1, the Bureau announced a 3 month extension of renewal deadlines for organizations whose deadlines fall between April 30 and July 31. The renewal of each registration is required to be postmarked by the 15th day of the 14th month following the close of the organization’s fiscal year. Listed below are the updated deadlines:

1. Charitable Organization Fiscal Year End: May 31, 2019
Charitable Organization Renewal Date and Registration Expiration: April 15, 2020
New Deadline: July 15, 2020

2. Charitable Organization Fiscal Year End: June 30, 2019
Charitable Organization Renewal Date and Registration Expiration: May 15, 2020
New Deadline: August 17, 2020*

*If the renewal due date falls on a weekend or holiday, the actual date will be the next business day. August 15, 2020 is a Saturday. Therefore, the renewal date is extended to Monday, August 17, 2020.

3. Charitable Organization Fiscal Year End: July 31, 2020
Charitable Organization Renewal Date and Registration Expiration: June 15, 2020
New Deadline: September 15, 2020

The Bureau will refund late fees paid by charities who file online and pay late fees, when they utilize the three-month extension. Please refer to page 2 of this guidance for instructions.

IRS Form 5500 Filings: The IRS has extended the deadline of IRS Form 5500 filings (Annual Return/Report of Employee Benefit Plan) to July 15th.

GFOA Certificate of Excellence in Financial Reporting Program (CAFR) - The Government Finance Officers Association (GFOA) will be granting extensions as needed. GFOA has asked that any entity that anticipates a delay to apply for an extension online.

HUD Extension: HUD announced a blanket 30-day extension for the filing of all Real Estate Assessment Center (REAC) financial statements. That extension is automatic and does not require any action by the project. However, REAC has clarified that the extension does not extend the 60-day residual receipts deposit requirement.

Individual Tax Filings: Due to the COVID-19 response effort, the IRS has extended the tax payment deadline from April 15th to July 15, 2020. In addition, the PA Department of Revenue has extended the personal tax payment deadline to July 15^th. This extension applies to estimated payments for the first and second quarters of 2020 as well. All taxpayers will have this additional time to file and make payments without interest or penalties. Note that the definition of ‘life sustaining businesses’ has been expanded by Pennsylvania Governor Tom Wolf to include accounting, tax preparation, bookkeeping, and payroll services. The PA Department of Revenue (DOR) has confirmed they will continue to process electronically filed tax returns and payments. Monitor the DOR’s page for updates.

Local Government Tax Filings: The deadline for local earned income tax filings has been extended to July 15, 2020. Refer to the PICPA web-site for additional information.