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Coronavirus Relief Fund Reporting and Record Retention Requirements (OIG-CA-20-027)

Issuer
Office of Inspector General (OIG)
Document type
Report
Date
2020-03-27

Full text

Coronavirus Relief Fund
Reporting and Record
Retention Requirements
Department of the Treasury
Office of Inspector General (OIG)
1
OIG-CA-20-027

Treasury Office of Inspector
General
• Richard K. Delmar, Deputy Inspector General
• Debbie Harker, Assistant Inspector General for Audit
• Donna Joseph, Deputy Assistant Inspector General for
Audit
• Eileen Kao, Audit Director
• Andrea Smith, Audit Director
• Jeneba Moiwo, Audit Manager
2

Coronavirus Relief Fund
• The Coronavirus Aid, Relief, and Economic Security Act
(CARES Act) was enacted on March 27, 2020 in
response to the Coronavirus disease (COVID-19)
outbreak
• The Coronavirus Relief Fund provides $150 billion in
direct assistance for States, Tribal governments, eligible
units local government, D.C., and U.S. Territories
3

Coronavirus Relief Fund
• Per the CARES Act, recipients must use Coronavirus
Relief Fund payments to cover costs that:
• Are necessary expenditures incurred due to the public health
emergency with respect to COVID-19;
• Were not accounted for in the budget most recently approved as
of March 27, 2020; and
• Were incurred during the period that begins on March 1, 2020,
and ends on December 30, 2020.
4

Treasury OIG Authority
• Responsible for compliance monitoring and
oversight of the receipt, disbursement, and use of
Coronavirus Relief Fund payments
• Recouping funds in the event a recipient fails to
comply with requirements
5

Who is a Prime Recipient?
Coronavirus
Relief  Fund
Department of the Treasury
Prime Recipients
State Governments
Local Governments with
Populations > 500,000
DC & U.S. Territories
Tribal Governments
6

Reporting Requirements
• Prime recipients will begin reporting COVID-19 related costs
incurred from March 1, 2020 – December 30, 2020 in the
GrantSolutions portal beginning September 1, 2020.
• The first quarterly report must cover the period of March 1
through June 30, 2020 and is due by September 21, 2020.
• The GrantSolutions portal will be prepopulated with prime
recipient data (amount, date, recipient identifier, and contact
information)
7

Reporting Requirements
• Projects
• Obligations and
Expenditures
• Contracts ≥ $50,000
• Grants ≥ $50,000
• Loans ≥ $50,000
• Transfers ≥ $50,000
• Direct Payments ≥
$50,000
• Aggregate Reporting
below $50,000
• Aggregate Reporting on
Payments to Individuals
8

Projects
• Prime recipients must list all projects they plan to complete
with the Coronavirus Relief Fund payments, including:
• Project name
• Identification number
• Description
• Status of completion
• Associate the project with obligations and expenditures, if
applicable
9

Expenditure Categories
•
Administrative Expenses
•
Budgeted Personnel and Services Diverted to a
Substantially Different Use
•
COVID-19 Testing and Contact Tracing
•
Economic Support (Other than Small Business,
Housing, and Food Assistance)
•
Expenses Associated with the Issuance of Tax
Anticipation Notes
•
Facilitating Distance Learning
•
Food Programs
•
Housing Support
•
Improve Telework Capabilities of Public Employees
•
Medical Expenses
•
Nursing Home Assistance
•
Payroll for Public Health and Safety Employees
•
Personal Protective Equipment
•
Public Health Expenses
•
Small Business Assistance
•
Unemployment Benefits
•
Workers’ Compensation
•
Other (Item not listed)
10

Contracts ≥ $50,000
• Contractor identifying and demographic information (e.g. Dun & Bradstreet
unique identification number (DUNS number) and location)
• Contract number
• Contract date, type, amount, and description
• Primary place of contract performance
• Related project name(s)
• Period of performance start date
• Period of performance end date
• Quarterly obligation amount
• Quarterly expenditure amount
• Expenditure categories
11

Grants ≥ $50,000
• Grantee identifying and
demographic information (e.g.
DUNS number and location)
• Award number
• Award date
• Award amount
• Award description
• Related project name(s)
• Award payment method
(reimbursable or lump sum
payment)
• Period of performance start date
• Period of performance end date
• Primary place of performance
• Quarterly obligation amount
• Quarterly expenditure amount
• Expenditure categories
12

Contract and Grant Definitions
• Primary place of performance - The address where the predominant
performance of the contract or grant will be accomplished.
• Period of performance start date - The date on which efforts begin or
the contract or grant is otherwise effective.
• Period of performance end date - The date on which all effort is
completed or the contract or grant is otherwise ended.
13

Loans ≥ to $50,000
• Borrower identifying and
demographic information (e.g.
DUNS number and location)
• Loan number
• Loan amount
• Loan date (date when loan signed
by prime recipient and borrower)
• Loan expiration date (date when
loan expected to be paid in full)
• Purpose of loan
• Primary place of performance
• Related project(s)
• Quarterly obligation amount
• Quarterly payments on outstanding
loans
• Recipient plans for reuse
Coronavirus Relief Funds from
loan repayments
• Loan/expenditure categories
14

Transfers ≥ $50,000
• Transferee/government unit identifying and demographic information (e.g.
DUNS number and location)
• Transfer type (reimbursable or advance transfer)
• Transfer date, amount, and description
• Related project(s)
• Quarterly obligation amount
• Quarterly expenditure information
• Expenditure categories
15

Direct Payments ≥ $50,000
• Payee identifying and demographic information (e.g. DUNS number
and location)
• Direct Payments amount and date
• Related project(s)
• Quarterly obligation amount
• Quarterly expenditure amount
• Expenditure categories
16

Aggregate Reporting
• Aggregate reporting of obligations and expenditures is
allowed on:
• Contracts, grants, transfers made to other government entities,
loans, and direct payments below $50,000
• All payments to individuals
17

Certification and Submission
• Each prime recipient was required to designate two
preparers and one authorizing official
• Preparers: enter data into GrantSolutions and validate
entries once completed
• Authorizing Officials: review and certify the data prior to
submission within the portal
18

Submission Approval
• Treasury OIG will review and approve the submission to ensure all
required information is reported and all data is accounted for
• After Treasury OIG’s approval, certain data that does not generally
change will be carried forward (or “cloned”) to reduce reporting
burden in future reporting quarters
19

Reporting Timeline
• By no later than September 21, 2020, recipients shall
submit via the portal the first detailed quarterly report
(March 1 – June 30, 2020)
• Thereafter, quarterly reporting will be due no later
than 10 days after the end of each calendar quarter
20

Reporting Timeline
Reporting
Cycle
Reporting Period
Reporting
Due Date
OIG Review
Period
Data Extract
to PRAC
Cycle 1
3/1-6/30/2020
9/21/2020
9/22-29/2020
9/30/2020
Cycle 2
7/1-9/30/2020
10/13/2020
10/14-20/2020
10/21/2020
Cycle 3
10/1-12/31/2020
1/11/2021
1/12-20/2021
1/21/2021
Cycle 4
1/1-3/31/2021
4/12/2021
4/13-20/2021
4/21/2021
Cycle 5
4/1-6/30/2021
7/12/2021
7/13-20/2021
7/21/2021
Cycle 6
7/1-9/30/2021
10/12/2021
10/13-20/2021
10/21/2021
21

Uses of the Reported Data
• Support Treasury OIG’s compliance monitoring
and oversight efforts
• Support Treasury OIG audit and investigations
• Reported to the Pandemic Response
Accountability Committee (PRAC)
22

Reporting Preparation
• Require current or potential sub-recipients to register with
SAM.gov by September 1, 2020
• This will enable detailed sub-recipient data to be imported
into the GrantSolutions portal
23

What if a Sub-Recipient Is Not
Registered in SAM.gov?
• If a sub-recipient is not registered in SAM.gov, the prime
recipient will be responsible for manually entering the
following data elements in the GrantSolutions portal:
24
• Legal Name
• Address Line 1
• Address Line 2, if applicable
• Address Line 3, if applicable
• City Name
• State Code
• Zip Code
• Country Name (selection menu)
• Organization Type (selection
menu)

Reporting Training
• GrantSolutions will provide training on the portal
access and use during the last week of August 2020
• The GrantSolutions CRF reporting portal is expected
to be operational on September 1, 2020
25

Resources
• Treasury’s Resources (Eligible Expenditures):
•
Guidance for State, Territorial, Local, and Tribal Governments
https://home.treasury.gov/policy-issues/cares/state-and-local-governments
•
Coronavirus Relief Fund Frequently Asked Questions
https://home.treasury.gov/policy-issues/cares/state-and-local-governments
• Treasury’s OIG Resources (Reporting):
•
Coronavirus Relief Fund Reporting and Record Retention Requirements (OIG-CA-20-021)
https://www.treasury.gov/about/organizational-
structure/ig/Audit%20Reports%20and%20Testimonies/OIG-CA-20-021.pdf
•
Coronavirus Relief Fund Reporting Requirements Update (OIG-CA-20-025)
https://www.treasury.gov/about/organizational-
structure/ig/Audit%20Reports%20and%20Testimonies/OIG-CA-20-025.pdf
26

Questions
28

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