The Coronavirus Relief Fund

Where the money went

The CARES Act appropriated $150 billion and gave Treasury 30 days from enactment to pay it out. $3 billion was reserved for the District of Columbia and the territories and $8 billion for tribal governments, and no state could receive less than $1.25 billion (OIG-CA-21-020). The remaining $139 billion went to the fifty states, split between each state government and the local governments large enough to claim their own payment (Treasury's payment table).

The Pandemic Response Accountability Committee's final file counts 865 prime recipients and $149.96 billion in awards. The states received $111.37 billion, 154 local governments $27.63 billion, DC and the territories $3 billion, and 655 tribal governments and Alaska Native corporations $7.96 billion. PRAC does not label tribal recipients; the 655 are the recipients that match none of Treasury's state, local or territorial payment lines. The California State Treasurer received the largest award, $9.53 billion, followed by the Texas governor's office at $8.04 billion. New York City's $1.45 billion was the largest local award and the Navajo Nation's $714.2 million the largest tribal one.

Recipients reported $140.29 billion spent. The largest block, $59.47 billion, carries no spending category: it is small payments and payments to individuals, payroll included, that the reporting rules allowed governments to report in aggregate, under the sub-recipient name “MULTIPLE RECIPIENTS”. Among the named categories, economic support came first at $9.66 billion, then items not listed elsewhere ($9.46 billion), payroll for public health and safety employees ($9.2 billion), public health expenses ($8.42 billion) and small-business assistance ($7.45 billion). Every prime, category and state total is in the Coronavirus Relief Fund data table.

Part of the record is still closed. PRAC marked 18,724 rows “DO NOT PUBLISH”, under 719 prime recipients, 650 of them tribal governments or Alaska Native corporations; those rows carry $9.46 billion of sub-award money and no reported spending. As a result the file shows tribal governments and Alaska Native corporations spending $934,314 of the $7.96 billion they received.

What the rules paid for

A cost qualified only if it passed three tests: it was a necessary expenditure caused by the public health emergency, it was not accounted for in the budget most recently approved as of March 27, 2020, and it was incurred between March 1 and December 30, 2020. The Consolidated Appropriations Act, 2021 moved the end of that window to December 31, 2021 (OIG-CA-21-020).

The reporting counted costs too. PRAC's file records what each government spent, on what category and through which sub-recipient. It has no field for jobs kept, patients treated or businesses saved, so no figure for the fund's effect can be read from it.

Treasury issued its guidance and its answers to frequently asked questions as it went. The first versions came out on April 22, 2020; the questions-and-answers document went through seven additional versions, the last on October 19, 2020, and the inspector general's office fielded approximately 500 questions about eligible uses. Its conclusion: “The lack of comprehensive, timely guidance on eligible uses caused confusion among recipients, and in some cases was a factor in ineligible uses of CRF payments” (OIG-CA-21-020).

What the inspector general has questioned and demanded back

Treasury's Office of Inspector General was given authority to recoup a payment if the recipient failed to comply with the law's use-of-funds requirements. Its desk reviews, final determinations and notices of recoupment are among the Treasury OIG source documents.

One case shows the sequence. Treasury paid the Native Village of Selawik, Alaska, $2,568,863.45. After the inspector general's review, Treasury's Bureau of the Fiscal Service sent the village a demand letter for $1,176,698 on May 20, 2026 (OIG-CA-26-039).

The lessons Treasury's inspector general drew

In May 2021, as Treasury prepared to pay out the American Rescue Plan's State and Local Fiscal Recovery Funds, the inspector general sent it the lessons of the relief fund (OIG-CA-21-020). Treasury had issued the money “as direct payments to recipients without agreements and terms and conditions in place” and “did not stand up a program office for administering the CRF.” The recommendations were to finalize guidance at the same time the money goes out, to use frequently asked questions to clarify guidance and not to create it, and to attach agreements with terms and conditions to the payments. Treasury generally agreed and said it would issue a rule defining eligible uses before the new fund's payments were made.

Who ran it, who received it, who went to court

Treasury under Steven Mnuchin paid the fund out in the spring of 2020; under Janet Yellen it made the money available to Alaska Native corporations in August 2021. Treasury's inspector general reviews how recipients spent the money, and the Pandemic Response Accountability Committee, chaired from 2020 by Michael Horowitz, published the recipient data.

Treasury announced on May 5, 2020 that it would pay the $8 billion in two tranches, 60 percent by population with a minimum of $100,000 and 40 percent by employment and spending. On June 12, 2020 it began the second tranche but withheld $679 million because another lawsuit over the set-aside might go against it. On June 15, in a suit tribes had brought over the delay, Agua Caliente Band of Cahuilla Indians v. Mnuchin, a federal judge ordered Treasury to pay the $679 million by June 17. By then Treasury had paid most of the set-aside, more than 7 weeks after the CARES Act deadline (GAO-22-104349). Whether Alaska Native corporations, which are for-profit companies, could share the tribal money went to the Supreme Court. On June 25, 2021, in Yellen v. Confederated Tribes of the Chehalis Reservation, it held that they could. Treasury then made $443,863,750.27 available to them, with a further $14,014,430 held back under preliminary injunctions in two cases (Treasury's notice of August 4, 2021).

Start reading

1. Treasury OIG, OIG-CA-21-020, Application of Lessons Learned From the Coronavirus Relief Fund (May 17, 2021)The inspector general's account of how the fund was paid out, the three cost tests and the lessons.
2. GAO-22-104349, Lessons Learned from Interior and Treasury's Administration of CARES Act Funds for TribesHow Treasury divided the tribal set-aside, and the litigation that delayed it.
3. Treasury, Payments to States and Eligible Units of Local GovernmentThe state and local payment table.
4. Treasury, Coronavirus Relief Fund Tribal Allocation MethodologyHow the tribal payments were computed.
5. Treasury, Coronavirus Relief Fund Disbursements to Alaska Native Corporations (August 4, 2021)The payments to Alaska Native corporations after the Supreme Court's decision.
6. Treasury OIG, Interim Audit Update: Coronavirus Relief Fund Recipient Reporting (OIG-20-036)The inspector general's May 2020 interim audit update on recipient reporting and accountability.
7. Treasury OIG, OIG-CA-26-039, Notice of Recoupment, Native Village of Selawik (June 4, 2026)A recoupment, start to finish.
8. Coronavirus Relief Fund: every prime recipient and what it reported spendingThe data table behind every figure on this page.