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Post-Application Guidance — SBA SVOG

Filed February 16, 2022 in SBA SVOG; one of 2 filings from this case.

Record facts

CourtU.S. Small Business Administration
Filed2022-02-16

Full text

Shuttered Venue Operators Grant 
Post-Application Guidance | February 16, 2022 
The Shuttered Venue Operators Grant (SVOG) program was established in Section 324 of the Economic 
Aid to Hard-Hit Small Businesses, Nonprofits and Venues Act (Economic Aid Act) signed into law on Dec. 
27, 2020, as part of H.R. 133 Consolidated Appropriations Act, 2021 (Public Law No. 116-260). Section 324 
of the Economic Aid Act was amended by Section 5005 of the American Rescue Plan Act (Public Law No. 
117-2) signed into law on March 11, 2021.
This guidance document answers common questions about the SVOG program for applicants, and is 
current as of February 16, 2022. 
Contents 
Application and Award Decision Process ...................................................................................................... 2 
Application Review Update and Applicant Responses ............................................................................. 2 
Applicant Action Items During "In Review" Stage .................................................................................... 3 
Other Special Circumstances .................................................................................................................... 4 
Post-Approval Stage .................................................................................................................................. 4 
Award & Disbursement Stage .................................................................................................................... 6 
Declined Applications ................................................................................................................................ 6 
Appeals, Award Amount Reconsiderations & Supplemental Awards ...................................................... 6 
Active Grantee Phase ...................................................................................................................................... 8 
SVOG Active Grantee Process Overview .................................................................................................... 8 
Finalize Budget Action Item ...................................................................................................................... 9 
Communication with the SBA ................................................................................................................... 9 
SVOG Award Timeline and Related Notice of Award Terminology .......................................................... 9 
Permissible Spending of SVOG Award Funds .............................................................................................. 10 
Assessing Cost Eligibility and Allowability .............................................................................................. 10 
Demonstrating Costs Allocability ............................................................................................................ 11 
Maintaining Supporting Documentation and Record Retention ........................................................... 11 
Closeout ........................................................................................................................................................ 11 
Closeout Timeline .................................................................................................................................... 11 
SVOG Closeout Process Overview ........................................................................................................... 12 
Barriers to Closeout ................................................................................................................................. 13 
Monitoring .................................................................................................................................................... 13 
What is Monitoring? ................................................................................................................................. 13 
SVOG Monitoring Process ........................................................................................................................ 13 

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Grantee Role and Responsibilities in Monitoring Process ..................................................................... 13 
Monitoring Event Conclusions, Corrective Actions and Closure ............................................................ 14 
Audit .............................................................................................................................................................. 14 
What is Auditing? ..................................................................................................................................... 14 
Audit Requirements ................................................................................................................................. 14 
Which one: Single or Program-Specific Audit? ....................................................................................... 15 
Audit Reporting Requirements ................................................................................................................ 15 
Other SVOG Program Audit Activities ...................................................................................................... 16 
Application and Award Decision Process 
Application Review Update and Applicant Responses 
The SBA began processing applications in order of priority in April 2021 and issuing grant award 
decisions in late May 2021.  
As of February 10, 2022, the SBA has issued decisions on 100% of all initial 17,637 applications. 
SVOG Applicants receive communications from the SBA via the contact information provided on their 
application. Changes or updates to the contact information on file with SVOG must be made by 
contacting customer service via svogrant@sba.gov or by calling 1-800-659-2955. Maintaining up-to-date 
contact information for your current authorized representative is crucial, as only the authorized 
representative will receive notifications about information requests and available documents. These 
communications are time sensitive, so please review carefully for the applicable deadlines.  
Official SVOG communications are sent from an @sba.gov email address, typically noresponse@sba.gov 
or svogrant@sba.gov. For some email applications, the email address will show as coming from 
“noreply@salesforce.com; on behalf of noresponse@sba.gov.” In some circumstances SVOG Customer 
Service will follow up on an email or action item via phone. These legitimate calls are made from official 
SBA phone numbers, and can be verified via an email from an @sba.gov address. To verify further, you 
can log in to your SBA account on the SVOG Application Portal to view any required action items and 
contact svogrant@sba.gov for more information. 
The SBA provides status updates throughout the decision-making process. You may receive email 
status updates for several reasons, including that your:   
o
award is finalized and you need to execute your pre-award documents;
o
application has been reviewed and additional documentation or information is required;
o
application has been reviewed and declined (see below for appeal information);
o
award amount is being reconsidered and additional documentation or information is
required;
o
application is eligible for appeal and additional documentation or information is required;
o
supplemental award is ready and you need to execute your pre-award documents.
When you receive a status update from the SBA, log in to the SVOG Application Portal to complete 
all required action items.  

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You may click the link in the email or enter https://www.svograntportal.sba.gov/s/ directly into your 
browser.  
After logging in, click the “Funding Request Name” to open your application. 
-
Status Update will appear in the top left of the page.
-
Action Items are at the top right of the page.
o
Click there and follow the instructions provided.
o
Action Items are time sensitive, please review carefully for your applicable deadlines.
If you have questions about completing Action Items, please contact the SBA. 
For general assistance, call the Office of Disaster Assistance’s Customer Service Center: 
Phone: 1-800-659-2955; Monday through Friday, 8 am to 8 pm ET 
Email: svogrant@sba.gov 
For in-depth assistance, contact SBA’s resource partners: 
You can identify partners in your area by visiting www.sba.gov/local-assistance.  
You may request to withdraw an application by emailing svogrant@sba.gov. 
The request must be sent from the email address used to create the SVOG application, and must include: 
1.
Subject Line: “Request to Withdraw SVOG Application”
2.
Email Message:
-
SVOG application number
-
Email address used to create the application
-
Entity name, address, and phone number
-
Name of person making the request
o
Request must be made by applicant or authorized representative named in the
application
-
Reason the applicant is requesting to withdraw the application
Applicant Action Items During "In Review" Stage 
After review and prior to approval or decline, you may need to complete an Action Item. Possible 
Action Items include: 
1.
Technical Corrections: Your application has been reviewed, but additional information or
documentation of specific requirements is needed.
-
You will receive an email advising you of the Action Item
-
After logging in to the portal, you will see a checklist advising you of the additional
information or documentation to provide
-
Follow the instructions provided in the portal to upload and submit the requested
information
-
You have 14 days to complete this Action Item
2.
4506T: The IRS could not process your 4506T for various reasons.
-
You will receive an email advising you of the Action Item
-
After logging in to the portal, you will see a new 4506T checklist. You may make corrections, if
needed
-
Review and sign the document
-
Follow the instructions provided in the portal to upload and submit the document
-
You have 14 days to complete this Action Item

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3.
Do Not Pay: Your name or entity name appears on the Department of Treasury's Do Not Pay (DNP)
list. Your status must be corrected or cleared prior to Award.
-
You will receive an email advising you of the Action Item
-
After logging into the portal, you will see information regarding where and why your name
appears on the Do Not Pay list
-
Follow the instructions provided to contact the source of your Do Not Pay status:
o
Visit Do Not Pay - Privacy Program (treasury.gov),
o
Scroll down to “Data Correction Process,”
o
Find the row for the match source, and
o
Use the Contact Information to contact the source and correct or clear your status
-
In the portal, follow the instructions for notifying the SBA that you cleared or corrected your
status
-
You have 30 days to clear or correct a DNP status
Other Special Circumstances 
A small number of applicants may receive an email from SVOG indicating their tax transcript was 
returned with “No Record Found”. If you receive such an email, follow these instructions:   
Step 1: 
•
Verify with the Internal Revenue Service (IRS) that your 2019 Federal Tax Return has been
received and processed.
•
The IRS provides a few toll-free numbers to assist you, depending on your circumstance:
o
For applicants who filed a Form 1040, call 800-829-1040, from 7 a.m. to 7 p.m. local
time,
o
For applicants who filed Form 1065, 1120, or 1120-S, call 800-829-4933, from 7 a.m. to
7 p.m. local time, or
o
For applicants who filed Form 990 or 990-EZ, call 877-829-5500, from 8 a.m. to 5 p.m.
local time.
Step 2: 
•
If the IRS tells you that your tax return has been received and processed, please follow the
instructions to fill out another 4506-T and ensure that all information is correct.
•
If the IRS indicates that your tax return has been received but not processed, proceed to step
3.
Step 3:  
•
Contact the Taxpayer Advocate Service (TAS). The TAS is an independent organization within 
the IRS designed to help if you have tax problems that you cannot resolve on your own (Home
- Taxpayer Advocate Service (irs.gov)). In the interest of helping your tax return get processed, 
please contact the TAS to inquire if their services can assist you. Additionally, you can directly 
request assistance at Submit a request for assistance - Taxpayer Advocate Service (irs.gov).
Post-Approval Stage 
After approval and prior to disbursement, you may need to complete an Action Item. Possible 
Action Items include:  
1.
Notice of Award (SBA Form 1222 / NOA): Your application is approved, and your Award amount is
finalized. You must sign and return your Notice of Award prior to disbursement.
-
You will receive an email advising you of the Action Item
-
After logging in to the portal, you will see a checklist advising you of the additional
information or documentation to provide

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- 
Follow the instructions provided in the portal to upload and submit the requested 
information 
- 
You have 7 days to complete this Action Item 
- 
Additional notes on Form 1222:  
o The “Project Period” on the Form 1222 is the granting period for issuing an SVOG NOA 
—this does not correspond with the allowable time period to incur costs 
o The “Budget Period” indicates the time you are permitted to spend the grant award 
o You may spend the grant on costs incurred between March 1, 2020, and December 31, 
2021 (or June 30, 2022, if you receive a supplemental award) 
 
2. Special Conditions (SBA Form 1222 Addendum): Your application is approved, and your Award 
amount is finalized. You must fulfill, or agree to fulfill, any listed Special Conditions prior to 
disbursement.  
- 
You will receive an email advising you of the Action Item 
- 
After logging in to the portal, you will see your Notice of Award and any Addendum 
identifying Special Condition documents that must be uploaded at the same time as the 
signed Notice of Award  
- 
Follow the instructions provided in the portal to upload and submit the requested 
information 
- 
You have 7 days to complete this Action Item 
- 
Additional notes on Form 1222 Addendum:  
o You may be asked for a copy of your 2020 federal tax filings. Most applicants were 
required to submit 2019 federal tax filings in the initial application. For fiscal year 
filers, the Form 1222 Addendum requirement is to provide a copy of their most recent 
tax year filings.  
o You may have seen a condition on the Addendum and/or the Portal which read “You 
are required to upload a final 425 and Supporting Documents within 15 days of 
receipt of your final disbursement.”  
 
Update - In subsequent Form 1222 updates, SBA corrected the Addendum language 
to clarify the SF-425 submission and closeout timelines. Specifically, the SBA asks 
grantees to submit the SF-425 document within 15 days after expending all SVOG 
award funds. The maximum allowable time is 120 days after the end of their Budget 
Period to prepare closeout materials and initiate the closeout process. As outlined in 
the Closeout section below, a grantee initiates closeout of their SVOG award when 
they respond to the Expense Report action item. 
 
o If you have less than 500 employees or more than 10,000 employees, you do not need 
to initial line 10 of the additional program assurances.  
 
3. Budget Revision: Your application is approved, but your possible Award amount is higher than 
the Proposed Budget you provided on your application. You must revise your budget to receive 
the additional funds or confirm you wish to receive the smaller grant award.  
- 
You will receive an email advising you of the Action Item 
- 
After logging in to the portal, you will see a checklist advising you of the additional 
information or documentation to provide 
- 
Follow the instructions provided in the portal to upload and submit the requested information 
- 
You have 14 days to complete this Action Item 

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Award & Disbursement Stage 
You must return your properly executed NOA and complete any Special Conditions prior to 
disbursement.  
After the SBA receives the completed NOA, you become an Awardee/Grantee and the SBA schedules a 
disbursement of funds. 
You must have an active SAM entity registration to receive funds. You can check your SAM registration 
status by: 
1. Going to https://www.sam.gov
2. Selecting Check Registration Status in the Register Your Entity section on the home page (or 
selecting Check Registration from the footer on every page)
3. Selecting the Sign In button
4. Entering your Unique Entity ID (with or without an EFT Indicator) or your CAGE Code (if 
applicable)
5. Selecting Search to check your entity registration status
Remember, new SAM.gov entity registrations take up to ten (10) business days to process and can take 
30+ business days during periods of peak volume. 
A small number of Grantees may see a “rejected” status or “pending” status for a disbursement in 
the Application Portal. If you see such a status:  
-
In most cases, the SBA can correct this disbursement issue on your behalf. The SBA checks for
such issues every day and will re-issue the disbursement shortly.
-
In some cases, you may need to take action to correct the issue. If this is the case, the SBA will
reach out to you with specific instructions.
Declined Applications 
If your application was declined, you will receive an email advising you of this status and have the option 
to submit an appeal.  
Most declined applications did not meet the eligibility criteria established in the SVOG statute. Please see 
the SVOG Eligibility Matrix for additional information.  
Appeals, Award Amount Reconsiderations & Supplemental Awards 
After receiving the decision on your initial SVOG application, you will have three options for a next step: 
appeal, award amount reconsideration, or supplemental award.  
Appeal 
If your application was declined, you will receive an email and an update in your SVOG portal indicating 
you are eligible to submit an appeal. The initial appeal window lasts two weeks, during which time 
funding will be preserved. There is no guarantee that funding will remain available for applicants who 
appeal after the close of the initial two-week window.  
If you choose to appeal, you will be asked to review the Eligibility Matrix and upload a signed statement 
indicating your grounds for appeal, as well as any supporting documents. A submitted appeal is final. If 

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your appeal is approved but you receive an Award amount at least $100 less than the Adjusted Proposed 
Grant Amount on your application, you will have the opportunity to request an award amount 
reconsideration. There is no secondary appeal process once an appeal is declined. 
 
Award Amount Reconsideration  
If you receive an award amount at least $100 less than the Adjusted Proposed Grant Amount on your 
initial application, you will receive an email indicating that you are eligible to apply for award amount 
reconsideration. Award amount reconsideration may adjust the amount of your initial award, so this 
process must be completed prior to evaluation for a Supplemental Award.  
 
The initial reconsideration window will last two weeks, during which time funding will be preserved. 
There is no guarantee that funding will remain available for applicants who request reconsideration after 
the close of the initial two-week window. 
 
If you choose to request an award amount reconsideration, you will have to upload supporting 
documents to validate your earned revenue. Submitted award amount reconsideration requests are 
final. 
 
Supplemental Award  
If you receive an initial SVOG, you will receive an action item to update your 2021 earned revenue, which 
you must update to be considered for a Supplemental Award. To do so, log in to the portal and update 
through this action item.  
 
Those eligible for a supplemental award based on the SVOG statute and earned revenue will be invited to 
request a supplemental award. If you qualify for a supplemental award based on the required revenue 
loss and your initial award amount reached the maximum of $10 million, you can qualify for a no-cost 
supplemental award to extend the active grantee phase.  
 
Eligibility is determined based on whether Q1 or Q2 2021 earned revenues were no more than 30 percent 
of Q1 or Q2 2019 earned revenues. For applicants that did not begin operations prior to 2019, Q1 2020 will 
be used as a comparison to Q1 2021. Supplemental award amounts, as defined in statute, will be 50% of 
your initial award (adding back any PPP subtracted from the initial award), not to exceed the balance of 
the initial grant and $10 million for a single entity. 
 
Reconsideration 2.0 – Final Award Amount Reconsideration 
 
Once Supplemental eligibility has been processed, Grantees will be invited to request one final 
opportunity to apply for Reconsideration of their Award Amount.  Grantees will receive an email 
notification of a new Action Item available through their applicant portal inviting them to ‘Apply for 
Reconsideration of your SVOG Award Amount’.  This Action Item allows grantee to correct any potential 
errors on their initial SVOG application which may have decreased their expected award amount.  
 
Grantees should accept the Reconsideration 2.0 invitation if there were any mistakes included in their 
application which may have decreased their Award Calculation, including: Errors in Earned Revenue 
figures for 2019, 2020, or 2021 and incorrect Date Business Began Operation. Date Business Began 
Operation should reflect the date the applying entity began earning revenue, which may be after the date 
the entity was incorporated.  
 

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Completing this Action Item will allow you to review and revise the information you have provided to 
SBA. Revisions may result in a change to your initial award amount, and by extension, any potential 
supplemental award amount. Revisions to the Funding Request made though the Reconsideration 2.0 
process will be final. 
 
The reconsideration window will last two weeks, during which time, funding will be preserved. Grantees 
may request that expired or declined Recon 2.0 Action Items be reissued.  Action Items that have been 
completed cannot be reissued or amended. There is no guarantee that funding will remain available for 
applicants who request reconsideration after the close of the initial two-week window.   
 
Reconsideration 2.0 is not available for declined applicants. 
 
Active Grantee Phase 
SVOG Active Grantee Process Overview 
The SVOG Active Grantee Phase begins on the date of initial NOA issuance and lasts until the Budget 
Period “through” date (Form 1222 Box 5) unless a grantee completes the closeout process before 
the Budget Period concludes. This phase involves identifying eligible and allowable expenditures and 
spending grant award funds until the closeout process is initiated. 
 
The SVOG program is implementing a multi-step, active grantee phase through award closeout. 
Guidance and the portal capabilities for the SVOG active grantee phase are in development. Below is a 
process diagram of the active grantee phase and how it is integrated with the closeout phase.  The SBA 
expects the capabilities and phases below to be finalized and available to grantees early 2022.  
 
 
 
 
Active Grantee Phase  
A Funding Request 
has been fully 
considered for all 
possible awards 
Grantee receives a 
“Finalize Budget” action 
item in their portal. 
This must be completed 
within 14 days 
SVOG Program 
Reviews and Approves 
the Finalized Budget 
Closeout Phase 
Grantee receives an 
“Begin Closeout: 
Expense Report” action 
item in their portal and it 
includes the due date 
SVOG Program 
Reviews and Approves 
Expense Report 
Grantee receives a 
“Complete Closeout: SF-
425” action item in their 
portal. This must be 
completed  
within 14 days 
SVOG Program 
Reviews and Approves 
SF-425 
SVOG Program 
closes out the 
grant 

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Finalize Budget Action Item 
After your SVOG application has been considered for all possible awards, you will receive an email 
to respond to a “Finalize Budget” Action Item. For most, this will be the final budget revision before 
reporting expenditures and initiating closeout.  
 
Finalize Budget Action Item: Your total award is finalized. You must submit a final budget to the 
SVOG program to confirm how you are allocating all awarded funds to allowable budget 
categories.  
- 
You will receive an email advising you of a new, available action item 
- 
After logging in to the portal, you will have the option to check a box to keep your existing 
budget or fill out a revised budget which accounts for additional awards since your last 
budget proposal 
- 
Follow the instructions provided in the portal to respond to the certification and attestation 
statements and submit the finalized budget 
- 
You will have 14 days from the date of receipt to submit the Finalize Budget Action Item 
Communication with the SBA 
Through the course of the active grantee phase process, the SBA continues to be available to you as a 
resource for program support and technical assistance.  
 
You should submit active grantee phase and closeout questions to svogrant@sba.gov. This inbox is 
monitored for specific topics that require SVOG program staff to provide the correct answers. 
Additionally, trending topics may be incorporated into public guidance.  
 
You can also receive assistance through the following resources: 
For general assistance, call the Office of Disaster Assistance’s Customer Service Center: 
Phone: 1-800- 659-2955, Monday through Friday, 8 am to 8 pm ET 
For in-depth assistance, contact SBA’s resource partners: 
You can identify partners in your area by visiting www.sba.gov/local-assistance.   
 
General grantee communication may also be provided via GovDelivery updates from sba-
oda@updates.sba.gov.  
SVOG Award Timeline and Related Notice of Award Terminology  
In the SVOG program statute, grantees were given specific time periods to incur eligible costs and 
to charge costs to the SVOG award. A cost is considered to have been incurred on the exact date the 
financial transaction happened, which may be prior to when it was paid for. The guidance in this section 
outlines the key terms on the NOA (Form 1222) used to establish award timeline parameters and provides 
helpful guidance on implementing and tracking incurrence of eligible and allowable costs. 
 
Important Terminology in Notice of Award (Form 1222) 
 
1. Project Period (Form 1222 Box 4) - The complete length of time for which funds are available for 
award making. 
“From” - Date Initial Phase SVOG Award was issued by the SBA. 

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“Through” - End date for incurring eligible and allowable costs. Grantee may incur costs from 
March 1, 2020, to the date in this box. 
Helpful Information 
- 
Transactions relating to payroll are eligible costs if work was performed between 
March 1, 2020, and the “Through” date in this box. 
- 
Transactions relating to the procurement of goods or services are eligible costs if 
the date of the binding written commitment falls between March 1, 2020, and the 
“Through” date in this box. 
 
2. Budget Period (Form 1222 Box 5) – The complete length of time you have to spend award 
funds on eligible and allowable costs. You can spend award funds to cover eligible and 
allowable costs incurred from March 1, 2020, to the “Through” date in Box 4 in your most 
recently issued NOA.  
“From” - First date to spend award funds. 
“Through” - Final date to spend award funds. 
Helpful Information 
- 
The final date of the Budget Period (“Through” date in Form 1222 Box 5) is the end 
of the grant term and you should start preparing for closeout if you have not 
already begun the closeout process.  
Permissible Spending of SVOG Award Funds  
Assessing Cost Eligibility and Allowability 
Grantees must spend SVOG funds on costs which are eligible and allowable.  
 
Misuse of SVOG funds can result in disciplinary action, such as monetary penalties.  
 
“Eligible Costs” are costs incurred between March 1, 2020, and the Project Period “Through” date on 
Form 1222 at Box 4. Form 1222 is also referred to as the NOA. If you have received more than one NOA, 
rely on the most recently issued NOA.  
 
Costs incurred outside the eligible cost period may not be paid for or reimbursed with SVOG funds (see 
SVOG program FAQ Document – Question 118).  
 
“Allowable Costs” are costs deemed legally permissible based on the authorizing language in the 
program’s statute and Title 2 of the Code of Federal Regulations, Part 200 (2 C.F.R. 200).  
 
For clarifications on allowable use of funds visit SVOG program FAQ Document. 
 
The SVOG program provides a budget form with allowable cost categories; if a cost incurred does 
not align with an allowable budget category, it is likely that cost is not an allowable cost. Use your 
Final Budget response as a guide during the SVOG active phase and to direct the allowable use of SVOG 
funds. 
 

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In addition to the laws and interpretations provided by the SBA, when assessing whether a cost is 
allowable, you should also consider: 
- Is the cost reasonable and necessary for my business? 
- Do sound business practices support the cost? 
- Does the cost clearly fit into an approved cost category in the grant award? 
Demonstrating Costs Allocability 
Allocability means eligible and allowable costs must be properly aligned to cost categories of an 
SVOG award. Grantees should maintain supporting documentation that shows the grant funds used 
align with an allowable budget category. Then in the Expense Report Action Item (Closeout Process), 
the total amount of funds expended across each allowable budget category should equal the supported 
allocable cost amount. 
 
You can split a cost between multiple funding sources. When splitting a cost, you must clearly 
demonstrate in your records how the cost was divided and how the SVOG allocable cost were connected 
to an allowable budget category and charged to the SVOG award. 
Maintaining Supporting Documentation and Record Retention 
The law requires you to maintain employment records for 4 years following the receipt of funds 
(this is the “From” date in Form 1222 Box 5), and to maintain all other records documenting 
compliance and eligibility for the SVOG Program for 3 years following the receipt of funds. These 
retained records should clearly depict how SVOG award funds were spent on eligible and allowable costs. 
The sum of costs documented should align with the total funds spent as recorded in the closeout process 
Expense Report Action Item and Complete Closeout: SF-425 Action Item. 
 
You must maintain all documents associated with SVOG award fund expenditures. Some examples 
include, but are not limited to: 
o Employment Records: The SVOG statute requires grantees to maintain employment records for 4 
years following the receipt of funds (this is the “From” date in Form 1222 Box 5) 
o Contracted Services: procurement process (as applicable), executed contract, invoices, 
payments, evidence of implemented contract deliverables, evidence of, and explanations for, 
partial charges to SVOG award funds, and any files documenting reporting or monitoring efforts. 
o Personnel Costs (staff time): employment contracts stating terms and conditions of employment, 
timesheets for time worked and charged, and evidence and explanations for how much 
personnel time was partially or fully reimbursed with SVOG award funds. 
o Equipment and Supplies (below procurement threshold): paid invoice or receipt clearly 
displaying the vendor, date purchased, the item(s) purchased, and cost amount charged to the 
SVOG award. 
Closeout 
Closeout Timeline 
You initiate your SVOG closeout by responding to the Expense Report Action Item in the SVOG 
portal. You are encouraged to initiate closeout by responding to the action item soon after expending all 
grant award funds, as the award work and financial recordkeeping will be fresh and it should make for an 
easier closeout. The guidance to pursue timely closeout is articulated in the NOA addendum and  SVOG 
Program FAQ Document.  
 

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You are required to respond to the Expense Report Action Item and initiate the closeout process no 
later than 120 days after the end of your Budget Period (“Through” date in Form 1222 Box 5). The 
overarching closeout process expectations for the SBA and grantee are outlined in 2 CFR 200.344 – 
Closeout.  
SVOG Closeout Process Overview 
The SVOG program is implementing a multi-step grant award closeout. Guidance and the portal 
capabilities for the SVOG Closeout Process are in development. Below is a process diagram of the 
closeout phase and how it integrated with the active grantee phase.  As mentioned above, the SBA 
expects the capabilities and phases below to be finalized and available to grantees early 2022.  
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Active Grantee Phase 
A Funding Request 
has been fully 
considered for all 
possible awards 
Grantee receives a 
“Finalize Budget” action 
item in their portal. 
This must be completed 
within 14 days 
SVOG Program 
Reviews and Approves 
the Finalized Budget 
Grantee receives an 
“Begin Closeout: 
Expense Report” action 
item in their portal and it 
includes the due date 
Closeout Phase 
1. SVOG Program 
Reviews and Approves 
Expense Report 
Grantee receives a 
“Complete Closeout: SF-
425” action item in their 
portal. This must be 
completed  
within 14 days 
2. SVOG Program 
Reviews and Approves 
SF-425 
3. SVOG Program 
closes out the 
grant 
Phase 1 
Grantee Responsibilities 
Expense Report 
Action Item 
- Assemble supporting documentation 
- Organize expenditures by budget category 
- If applicable, prepare property inventory and create request for property 
disposition instructions 
- Respond to any follow-up questions from the SBA 
COMPLETE - Phase 1 is complete when the SBA approves the Expense Report Action Item 
Phase 2  
Grantee Responsibilities 
Complete Closeout: 
SF-425 Action Item 
(plus survey and 
supporting 
documents) 
- Confirm SF-425 has the correct data 
- Respond to the survey  
- If applicable, upload supporting documents for property disposition 
- If applicable, complete and document repayment of unused SVOG award 
money 
- Respond to any follow-up questions from the SBA  

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COMPLETE - Phase 2 is complete when the SBA approves the Complete Closeout: SF-425 Action Item 
Phase 3 
Grantee Responsibilities 
Grant Award 
Closure 
- Receive grant award closure notification and (if necessary) provide any final 
response 
COMPLETE – Phase 3 is complete when the grantee receives notification of grant award closeout and (if 
necessary) completes a final response to the SBA 
 
Barriers to Closeout 
The SBA cannot complete grant award closeout if any of the following conditions are present: 
- Open monitoring event (please see below for additional information), 
- Unresolved audit issues, or 
- An unresolved grantee question or response, examples include grantee change in ownership 
request, grantee failure to respond to action item, and grantee failure to repay unused grant 
funds. 
Monitoring 
What is Monitoring? 
Monitoring is an SBA-led review of grantees to determine whether award funds were used for 
eligible and allowable purposes. All federal grants include monitoring and all SVOG grantees should be 
prepared for monitoring. The SBA will use a risk-based monitoring system to select the grantees to 
monitor. SBA will notify you if you have been selected for monitoring.  
SVOG Monitoring Process 
The majority of monitoring will be done remotely by SVOG staff, but some grantees may receive on-
site monitoring. The monitoring process, including review and responses, will be managed through the 
SVOG Portal and SBA staff will follow up directly by email or phone as needed.  SBA will assign a specific 
SVOG program staffer to each monitoring event and this individual will serve as the primary reviewer and 
point of contact. 
 
If selected for monitoring, you will receive a notification in the portal and an email from the SBA 
notifying you that an action item is pending response. The action item will provide the monitoring 
scope and details regarding the information and documentation you must provide.  
 
Most monitoring events will start while the grantee is actively implementing its award, so you are 
encouraged to continue spending award funds unless otherwise notified by the SBA. The SBA may 
begin a monitoring review once the closeout phase has been initiated or after a grant award has been 
closed out.  
Grantee Role and Responsibilities in Monitoring Process 
You are expected to respond timely and completely to monitoring notifications and follow-up 
requests. If you have questions about the monitoring scope or requested documents, please reach out to 
your SVOG point of contact. 
 

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Eligible and allowable expenses can only be determined based on the documents and responses 
you provide to the SBA. If you fail to respond timely or completely, then the SBA will make its eligible 
and allowable use determination based on the responses and documents provided.  
Monitoring Event Conclusions, Corrective Actions and Closure 
You will be contacted by email once a monitoring review is complete. In this email, the SBA will 
provide a summary of its monitoring review and the resulting monitoring conclusions. The monitoring 
conclusions will encompass SBA’s evaluation of eligible and allowable use of funds, plus, if needed, a list 
of corrective actions and the delivery of technical assistance guidance to improve the grantee active 
award phase. 
If the SBA concludes SVOG funds are being used for eligible and allowable purposes, then the SBA 
will close the monitoring event. No further response will be required from you on this monitoring 
event. 
If the SBA concludes SVOG funds are not being used for eligible and allowable purposes, then the 
SBA will provide a list of corrective actions. You will need to resolve all corrective actions with follow-
up responses before the monitoring event can be closed. Corrective action examples include updated 
spending policies, improved financial controls, or repayment of ineligible or unallowable costs. If a cost is 
found to be ineligible or unallowable, the SBA will work with you to reallocate the funds to an eligible and 
allowable cost that has yet to be reimbursed or request the funds be returned.  If you do not comply with 
the Agency’s request for returned funds, the SBA may take other measures to recoup the funds, up to and 
including litigation and noting a grantee’s noncompliance in FAPIIS. 
Audit 
What is Auditing? 
The SVOG Auditing phase captures instances in which you may be required to undergo a third-party audit 
of your organization and/or operation of your SVO grant.  
Audit Requirements 
If you expend more than $750,000 in Federal funds (across all Federal sources including SVOG 
funds) within your fiscal year, you will be required to complete a third-party audit. If you received a 
PPP loan, it does not count against the $750,000 expenditure threshold. SVOG grantees that do not 
surpass the $750,000 expenditure threshold within their own fiscal year will not be responsible for 
conducting an audit under these requirements. 
The audit requirements differ between for-profit entities and all other non-Federal entities 
(includes nonprofit organizations, institution of higher education, state, local government, and 
Indian tribes).  
If you are a nonprofit organization, an institution of higher education, state, local government, or Indian 
tribe, you must complete an audit in line with the requirements outlined in the Uniform Guidance 
Subpart F (2 CFR 200. 500 – 521), which requires a single audit or program-specific audit.  
If you are a for-profit entity, you can complete one of the following to meet the auditing 
requirement: 

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1. Single audit or program specific audit consistent with Uniform Guidance Subpart F (2 CFR 200. 
500 – 521); OR 
2. an audit of the entity’s financial statements. 
 
Which one: Single or Program-Specific Audit? 
If you only receive SVOG as your source of Federal funding, you can elect to have a program specific 
audit (instead of a single audit as outlined in 2 CFR 200.501(c)). Under a program-specific audit, SVOG 
grantees will contract with an independent auditor to conduct a review of your active SVOG award phase 
including a review of SVOG program compliance, your internal controls, and your financial system and 
recordkeeping.  
 
If you are an entity with broader Federal funding support from multiple sources, you must conduct 
a single audit as opposed to a program-specific audit. The structure of a single audit allows for an 
auditor’s review to focus initially on the financial and management controls the organization has in place 
to administer multiple funding streams and ensure that cost allocation is clearly tracked. Then based on 
the size of the funding portfolio and distribution of funding sources, the auditor will test program specific 
records for adherence with the entity’s policies and procedures and compliance with the Federal 
program rules and requirements. The prominence of auditing specific to the SVOG award fund 
management and usage in the single audit will vary based on the proportionate share of SVOG funds 
expended versus other Federal funding expended within the entity’s own fiscal year.  
 
SBA is working to develop an SVOG Compliance Supplement for 2022. This compliance supplement 
will serve as a tool to direct compliance auditors in their audit reviews of SVOG awards. Although the 
compliance supplement is being released for 2022, SBA encourages compliance auditors and SVOG 
awardees to utilize the supplement as guidance for 2021 as well. 
 
Expenses related to a single or program specific audit or a financial audit conducted to meet this 
audit requirement are an allowable use of SVOG award funds, see SVOG Program FAQ Document – 
Question 156. 
Audit Reporting Requirements 
If you are a non-Federal entity required to complete a single or program specific audit, you must 
upload the reporting package to the Federal Audit Clearinghouse (FAC) as detailed in 2 CFR 200.512. 
The composition of the FAC reporting package is described in 2 CFR 200.512(c). If the auditor makes 
findings in their report, then the grantee is expected to resolve the findings with a corrective action plan 
and submit the corrective action plan in its FAC reporting package.  A non-Federal entity will also be 
required to submit their audit reporting package directly to SBA. 
 
For-profit entities required to complete a financial audit must provide a copy of their audit report 
to SBA, including all audit package components, findings, and corrective action plan as applicable. 
 
SBA will utilize an Audit Reporting Action Item to collect audit report packages from non-Federal 
and for-profit entities. Both entity types have nine months from the end of their fiscal year to submit 
their audit report packages. 
 

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Other SVOG Program Audit Activities 
As an SVOG grantee, you may be engaged in other ongoing SBA or SVOG audit activities. The SVOG 
program is experiencing ongoing review from other Federal partners, including SBA’s Office of Inspector 
General, the Government Accountability Office, and the Pandemic Response Accountability Committee, 
which could impact SVOG grantees. Also, the SBA is required to conduct internal control reviews of SVOG 
award decisions and applicant documentation, which could lead to additional follow-up with SVOG 
grantees. The SBA will provide communication to grantees if further follow-up or actions are expected.

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