OIG-CA-20-021: Coronavirus Relief Fund Reporting and Record Retention Requirements

Summary

Memorandum OIG-CA-20-021, dated July 2, 2020, from the Department of the Treasury Office of Inspector General to Coronavirus Relief Fund recipients, with the subject Coronavirus Relief Fund Reporting and Record Retention Requirements. It states that each prime recipient shall report interim totals of costs incurred from March 1 through June 30, 2020 by no later than July 17, 2020, and then report quarterly through the GrantSolutions portal, with the first detailed quarterly report due no later than September 21, 2020. It lists the records recipients must keep to show compliance with subsection 601(d) of the Social Security Act, to be maintained for a period of five (5) years after final payment. The memorandum bears the name of Richard K. Delmar, Deputy Inspector General, with /s/ printed beside it.

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OFFICE OF
INSPECTOR GENERAL
DEPARTM ENT OF THE TREASURY
WASHINGTON, D.C.  20220

1

July 2, 2020

OIG-CA-20-021
MEMORANDUM FOR
CORONAVIRUS RELIEF FUND RECIPIENTS

FROM:

Richard K. Delmar /s/
Deputy Inspector General

SUBJECT:
Coronavirus Relief Fund Reporting and Record Retention
Requirements

Title VI of the Social Security Act, as amended by Title V of Division A of the
Coronavirus Aid, Relief, and Economic Security Act (Public Law 115-136), provides
that the Department of the Treasury (Treasury) Office of Inspector General (OIG) is
responsible for monitoring and oversight of the receipt, disbursement, and use of
Coronavirus Relief Fund payments. Treasury OIG also has authority to recover
funds in the event that it is determined a recipient of a Coronavirus Relief Fund
payment failed to comply with requirements of subsection 601(d) of the Social
Security Act, as amended, (42 U.S.C. 801(d)). Accordingly, we are providing
recipient reporting and record retention requirements that are essential for the
exercise of these responsibilities, including our conduct of audits and
investigations.
Reporting Requirements and Timelines
Each prime recipient of Coronavirus Relief Fund payments1
1 Prime recipients include all 50 States, Units of Local Governments, the District of Columbia, U.S.
Territories, and Tribal Governments that received a direct payment from Treasury in accordance
with Title V.
 shall report Coronavirus
Disease 2019 (COVID-19) related “costs incurred” during the “covered period”2
2 Refer to Treasury’s guidance dated June 30, 2020 for more information on costs incurred and the
covered period.

(the period beginning on March 1, 2020 and ending on December 30, 2020), in the
manner of and according to the timelines outlined in this memorandum. As
described below, each prime recipient shall report interim and quarterly data and
other recipient data according to these requirements. Treasury OIG is working on
development of a portal with GrantSolutions3
3 A grant management service provider under the U.S. Department of Health and Human Services.
 that is expected to be operational on

2

September 1, 2020, for recipients to report data on a quarterly basis. Until the
GrantSolutions portal is operational, each prime recipient shall follow the interim
reporting requirements. Treasury OIG will notify each prime recipient when
GrantSolutions is operational or of any changes to the expected September 1, 2020
start date.
Interim Reporting for the period March 1 through June 30, 2020
By no later than July 17, 2020, each prime recipient is responsible for reporting costs
incurred during the period March 1 through June 30, 2020. For this interim report, prime
recipients need only report totals by the following broad categories:
a. Amount transferred to other governments;
b. Amount spent on payroll for public health and safety employees;
c. Amount spent on budgeted personnel and services diverted to a substantially
different use;
d. Amount spent to improve telework capabilities of public employees;
e. Amount spent on medical expenses;
f. Amount spent on public health expenses;
g. Amount spent to facilitate distance learning;
h. Amount spent providing economic support;
i. Amount spent on expenses associated with the issuance of tax anticipation notes;
and
j. Amount spent on items not listed above.
Recipients should consult Treasury’s guidance and Frequently Asked Questions in
reporting costs incurred during the period March 1 through June 30, 2020. The total of
all categories must equal the total of all costs incurred during that period. A spreadsheet
is attached for your use in providing the data. As discussed below, the prime recipient
will be required to report information for the period March 1 through June 30, 2020 into
GrantSolutions once it is operational.
Quarterly Reporting
Each prime recipient of Coronavirus Relief Fund payments shall report COVID-19 related
costs into the GrantSolutions portal. Data required to be reported includes, but is not
limited to, the following:
1. the total amount of payments from the Coronavirus Relief Fund received from
Treasury;
2. the amount of funds received that were expended or obligated for each project or
activity;
3. a detailed list of all projects or activities for which funds were expended or
obligated, including:
a. the name of the project or activity;
b. a description of the project or activity; and

3

4. detailed information on any loans issued; contracts and grants awarded; transfers
made to other government entities; and direct payments made by the recipient
that are greater than $50,000.
The prime recipient is responsible for reporting into the GrantSolutions portal information
on uses of Coronavirus Relief Fund payments.
Recipient Portal Access: For future quarterly reporting, each prime recipient will have
GrantSolutions portal access for three (3) individuals: two (2) designees (preparers) to
input quarterly data and one (1) official authorized to certify that the data is true,
accurate, and complete.4
4 The certifying official is an authorized representative of the recipient organization with the legal authority
to give assurances, make commitments, enter into contracts, and execute such documents on behalf of
the recipient.
 By no later than July 17, 2020, please provide the name, title,
email address, phone number, and postal address of these individuals so that portal
access can be granted. After this information is received, guidance on the
GrantSolutions portal access and data submission instructions will be issued separately.
Reporting timeline
By no later than September 21, 2020, recipients shall submit via the portal the first
detailed quarterly report, which shall cover the period March 1 through June 30, 2020.
Thereafter, quarterly reporting will be due no later than 10 days after each calendar
quarter. For example, the period July 1 through September 30, 2020, must be reported
no later than October 13, 2020 (Tuesday after the 10th day of October and the
Columbus Day Holiday). Reporting shall end with either the calendar quarter after the
COVID-19 related costs and expenditures have been liquidated and paid or the calendar
quarter ending September 30, 2021, whichever comes first.
Record Retention Requirements
Recipients of Coronavirus Relief Fund payments shall maintain and make available to the
Treasury OIG upon request all documents and financial records sufficient to establish
compliance with subsection 601(d) of the Social Security Act, as amended, (42 U.S.C.
801(d)), which provides:
(d) USE OF FUNDS.—A State, Tribal government, and unit of local government shall use
the funds provided under a payment made under this section to cover only those costs
of the State, Tribal government, or unit of local government that—
1. are necessary expenditures incurred due to the public health emergency
with respect to COVID-19;

2. were not accounted for in the budget most recently approved as of the date
of enactment of this section for the State or government; and

4

3. were incurred5
5 Refer to Treasury’s guidance dated June 30, 2020 for more information on the definition of costs
incurred.
 during the period that begins on March 1, 2020, and
ends on December 30, 2020.
Records to support compliance with subsection 601(d) may include, but are not
limited to, copies of the following:
1. general ledger and subsidiary ledgers used to account for (a) the
receipt of Coronavirus Relief Fund payments and (b) the disbursements
from such payments to meet eligible expenses related to the public
health emergency due to COVID-19;
2. budget records for 2019 and 2020;
3. payroll, time records, human resource records to support costs
incurred for payroll expenses related to addressing the public health
emergency due to COVID-19;
4. receipts of purchases made related to addressing the public health
emergency due to COVID-19;
5. contracts and subcontracts entered into using Coronavirus Relief Fund
payments and all documents related to such contracts;
6. grant agreements and grant subaward agreements entered into using
Coronavirus Relief Fund payments and all documents related to such
awards;
7. all documentation of reports, audits, and other monitoring of
contractors, including subcontractors, and grant recipient and
subrecipients;
8. all documentation supporting the performance outcomes of contracts,
subcontracts, grant awards, and grant recipient subawards;
9. all internal and external email/electronic communications related to use
of Coronavirus Relief Fund payments; and
10. all investigative files and inquiry reports involving Coronavirus Relief
Fund payments.
Records shall be maintained for a period of five (5) years after final payment is
made using Coronavirus Relief Fund monies. These record retention requirements
are applicable to all prime recipients and their grantees and subgrant recipients,
contractors, and other levels of government that received transfers of Coronavirus
Relief Fund payments from prime recipients.
Thank you and we appreciate your assistance.

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