In response to the COVID-19 pandemic, Small Business Administration (SBA) Paycheck Protection Program (PPP) loans, administered under the 7(a) guaranty loan program, are being provided through local financial institutions. While these loans have been made primarily to for-profit entities, some not-for-profit entities (NFPs) also have received PPP loans, and such entities have been asking whether PPP loans will be subject to the Uniform Guidance Single Audit requirements. The Government Audit Quality Center (GAQC) of the AICPA recently informed us that they contacted SBA staff, who indicated that PPP loans made to NFPs will not be subject to the Single Audit requirements.
On the other hand, SBA staff indicated to the GAQC that loans made to NFPs under the Economic Injury Disaster Loan Assistance program are considered a direct loan program disbursed from SBA to loan recipients. Therefore, such loans are considered federal financial assistance and are subject to the Uniform Guidance Single Audit requirements.