OIG-CA-20-025 Coronavirus Relief Fund Reporting Requirements Update

Summary

Memorandum OIG-CA-20-025, dated July 31, 2020, from Deputy Inspector General Richard K. Delmar of the Department of the Treasury Office of Inspector General to Coronavirus Relief Fund recipients, on Coronavirus Relief Fund Reporting Requirements Update. It augments the July 2, 2020 memorandum OIG-CA-20-021 and sets out how prime recipients report COVID-19 costs incurred from March 1, 2020 through December 30, 2020 in a GrantSolutions portal. Prime recipients must list projects, select expenditure categories, and give detailed information on contracts, grants, loans, transfers and direct payments of $50,000 or more, with aggregate reporting allowed below $50,000. The first quarterly report, covering March 1 through June 30, 2020, is due by September 21, 2020, and reported data will be provided to the PRAC.

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

July 31, 2020

OIG-CA-20-025

MEMORANDUM FOR
CORONAVIRUS RELIEF FUND RECIPIENTS

FROM:

Richard K. Delmar /s/
Deputy Inspector General

SUBJECT:
Coronavirus Relief Fund Reporting Requirements Update

On July 2, 2020, my office issued memorandum OIG-CA-20-021, Coronavirus Relief
Fund Recipient Reporting and Record Retention Requirements informing you of the
Department of the Treasury (Treasury) Office of Inspector General’s (OIG) monitoring
and oversight responsibilities related to the Coronavirus Relief Fund, among other
things. Specifically, 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
116-136), provides that Treasury 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)).
Recipient reporting and record retention requirements are essential for the exercise of
these responsibilities, including our conduct of audits and investigations.
This memorandum augments and clarifies the prime recipient’s quarterly reporting
requirements contained in memorandum OIG-CA-20-021. We plan to use reported
data to support our office’s Coronavirus Relief Fund compliance monitoring and
oversight efforts and for audit and investigative purposes. In addition, reported data
will be provided to the Pandemic Response Accountability Committee (PRAC), which
will report the data on its website in accordance with Section 15010 of the CARES
Act.1
1 P. L. 116-136 (March 27,2020), Section 15010, established the PRAC within the Council of
Inspectors General on Integrity and Efficiency to promote transparency and conduct and support
oversight of covered funds and the coronavirus response to (1) prevent and detect fraud, waste,
abuse, and mismanagement; and (2) mitigate major risks that cut across program and agency
boundaries. The PRAC’s website will provide data on relevant operational, economic, financial, grant,
subgrant, contract, and subcontract information in user-friendly visual presentations to enhance public
awareness of the use of covered funds and the Coronavirus response.

2

Reporting Requirements
The Treasury OIG has engaged GrantSolutions, a grant and program management
Federal shared service provider under the U.S. Department of Health and Human
Services, to develop a customized and user-friendly reporting solution to capture the
use of Coronavirus Relief Fund payments. In this regard, the GrantSolutions portal will
be prepopulated with prime recipient data to include the Coronavirus Relief Fund
payment amount, date, recipient Dun & Bradstreet unique identification
number (DUNS number), and contact information. It is the responsibility of the prime
recipients2
2 Prime recipients include all 50 States, units of local governments, the District of Columbia, U.S.
Territories, and Tribal Governments that received a direct Coronavirus Relief Fund payment from
Treasury in accordance with the CARES Act.
 to report on uses of Coronavirus Relief Fund payments. Accordingly, each
prime recipient shall report Coronavirus Disease 2019 (COVID-19) related costs
incurred 3
3 Refer to Treasury’s Guidance for State, Territorial, Local, and Tribal Governments updated
June 30, 2020, at
 during the covered period (the period beginning on March 1, 2020, and
ending on December 30, 2020), as follows.
Projects
List all projects4
4  Projects are a grouping of related activities that together are intended to achieve a specific goal.
 the prime recipient plans to complete with Coronavirus Relief
payments. For each project, the prime recipient will be required to enter the project
name, identification number (created by the prime recipient), description, and status
of completion. Once a project is entered into the GrantSolutions portal, the prime
recipient will be able to report on the project’s obligations and expenditures.
Expenditure Categories
Once expenditures are entered against obligations, the prime recipient will need to
select the specific expenditure category from the available options from a dropdown
menu:
a. Administrative Expenses
b. Budgeted Personnel and Services Diverted to a Substantially Different Use
c. COVID-19 Testing and Contact Tracing
d. Economic Support (Other than Small Business, Housing, and Food Assistance)
e. Expenses Associated with the Issuance of Tax Anticipation Notes
f. Facilitating Distance Learning
g. Food Programs
h. Housing Support
i. Improve Telework Capabilities of Public Employees
j. Medical Expenses

https://home.treasury.gov/system/files/136/Coronavirus-Relief-Fund-Guidance-for-State-
Territorial-Local-and-Tribal-Governments.pdf, for more information on costs incurred and the covered
period.

3

k. Nursing Home Assistance
l. Payroll for Public Health and Safety Employees
m. Personal Protective Equipment
n. Public Health Expenses
o. Small Business Assistance
p. Unemployment Benefits
q. Workers’ Compensation
r. Items Not Listed Above - to include other eligible expenses that are not
captured in the available expenditure categories
Each prime recipient shall also provide detailed obligation and expenditure information
for any contracts and grants awarded, loans issued, transfers made to other
government entities, and direct payments made by the prime recipient that are greater
than or equal to $50,000 as follows.
Contracts Greater Than or Equal to $50,000
a. Contractor identifying and demographic information (e.g. DUNS number and
location)
b. Contract number
c. Contract date, type, amount, and description
d. Primary place of contract performance
e. Related project name(s)
f. Period of performance start date
g. Period of performance end date
h. Quarterly obligation amount
i. Quarterly expenditure amount
j. Expenditure categories (listed above)
Grants Greater Than or Equal to $50,000
a. Grantee identifying and demographic information (e.g. DUNS number and
location)
b. Award number
c. Award date, amount, and description
d. Award payment method (reimbursable or lump sum payment(s))
e. Related project name(s)
f. Period of performance start date
g. Period of performance end date
h. Primary place of performance
i. Quarterly obligation amount
j. Quarterly expenditure amount
k. Expenditure categories (listed above)

4

Loans Greater Than or Equal to $50,000
a. Borrower identifying and demographic information (e.g. DUNS number and
location)
b. Loan number
c. Loan amount, date (date when loan signed by prime recipient and borrower),
and description
d. Loan expiration date (date when loan expected to be paid in full)
e. Purpose of loan
f. Primary place of performance
g. Related project(s)
h. Quarterly obligation amount
i. Quarterly payments on outstanding loans
j. Recipient plans for reuse of Coronavirus Relief Fund loan repayments
k. Loan/expenditure categories
Transfers to Other Government Entities Greater Than or Equal to $50,000
a. Transferee/government unit identifying and demographic information (e.g.
DUNS number and location)
b. Transfer date, amount, and description
c. Related project(s)
d. Quarterly obligation amount
e. Quarterly expenditure information
f. Expenditure categories (listed above)
Direct Payments Greater Than or Equal to $50,000
a. Payee identifying and demographic information (e.g. DUNS number and
location)
b. Direct Payments amount and date
c. Related project(s)
d. Quarterly obligation amount
e. Quarterly expenditure amount
f. Expenditure categories (listed above)

Aggregate reporting below $50,000
Aggregate reporting is allowed on contracts, grants, transfers made to other
government entities, loans, direct payments, and payments to individuals that are
below $50,000.

5

Certification and Submission
As noted in our July 2, 2020 memorandum, each prime recipient was required to
designate two preparers to enter data into GrantSolutions and an authorizing official,
who is responsible for certification and submission of the recipient’s quarterly report.
Preparers are only permitted to enter data into the required fields and validate entries
once completed. Authorizing officials are responsible for reviewing and certifying the
information prior to submission within the portal. Accordingly, these individuals will
be granted user permissions in the GrantSolutions portal.
Once a report submission is complete, the Treasury OIG will review the submission to
ensure that the prime recipient has reported all required information and accounted for
the current period’s obligations, expenditures, and loan payments, among other
information. The Treasury OIG will approve final submissions that are determined to
be complete. After approval of the prime recipient’s report, certain data fields that do
not change will be carried forward to reduce reporting burden in future quarters. All
prime recipient data will be captured on a quarterly and cumulative basis.
Reporting Timeline
By no later than September 21, 2020, the prime recipient’s authorizing official shall
certify and submit via the GrantSolutions portal the first detailed quarterly report,
which shall cover the period of March 1 through June 30, 2020. Thereafter, quarterly
reporting will be due no later than 10 calendar days after the end of each calendar
quarter. If the 10th calendar day falls on a weekend or a Federal holiday, the due date
will be the next working day. For example, the period July 1 through September 30,
2020, must be reported no later than Tuesday, October 13, 2020 (considers that the
10th calendar is on a weekend and the following Monday is a Federal Holiday).The
table below summarizes the quarterly reporting timeline for prime recipients of
Coronavirus Relief Fund payments.
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

6

Reporting Preparation and Training
To prepare for the initial reporting cycle, each prime recipient should ensure that any
current or potential sub-recipients are registered in SAM.gov.5
5 The System for Award Management (SAM) is an official website of the U.S. government. Entities are required to
register at SAM.gov to do business with the U.S. government.
 While each prime
recipient is responsible for reporting on its sub-recipients, sub-recipient registration in
SAM.gov will enable detailed sub-recipient data to be imported into the
GrantSolutions portal. Therefore, the prime recipient should require that sub-recipients
register with SAM.gov prior to September 1, 2020.
In anticipation of GrantSolutions portal becoming operational on September 1, 2020,
training will be provided on portal access and use during the last week of August
2020.
Questions
For questions regarding eligible uses of Coronavirus Relief Fund payments, please
consult Treasury’s Guidance for State, Territorial, Local, and Tribal Governments and
Treasury’s Coronavirus Relief Fund Frequently Asked Questions documents which are
located at https://home.treasury.gov/policy-issues/cares/state-and-local-governments.
Thank you and we appreciate your compliance with these reporting requirements.

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