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DEPARTMENT OF THE TREASURY
OFFICE OF INSPECTOR GENERAL
Coronavirus Relief Fund
Prime Recipient Desk Review Procedures1
OIG-CA-21-004R
March 22, 2021
1 These procedures have been updated to reflect extension of the covered period for Coronavirus
Relief Fund recipients to use proceeds March 1, 2020 through December 31, 2021, and replace the
previous procedures dated October 26, 2020.
2
A. Coronavirus Relief Fund Overview
Title VI of the Social Security Act, as amended by Title V of Division A of
the Coronavirus Aid, Relief, and Economic Security Act2 established the
Coronavirus Relief Fund (CRF) and appropriated $150 billion for making
payments to States, Tribal governments, units of local government, the
District of Columbia, and U.S. Territories. Payments were made in
accordance with requirements outlined in Title V, of which $3 billion was
reserved for payments to the District of Columbia and U.S. Territories and
$8 billion was reserved for payments to Tribal governments. Further, no
State received a payment of less than $1.25 billion. The CARES Act
assigned the Department of the Treasury (Treasury) Office of Inspector
General (OIG) with responsibility for compliance monitoring and oversight of
the receipt, disbursement, and use of CRF payments. Treasury OIG also was
assigned authority to recoup CRF proceeds in the event that it is determined
a recipient of a CRF payment failed to comply with requirements of
subsection 601(d) of the Social Security Act, as amended, (42 U.S.C.
801(d)). The Consolidated Appropriations Act, 20213 extended the covered
period for recipients of CRF payments to use proceeds from March 1, 2020
through December 31, 2021.
The CARES Act, as amended, stipulates that CRF recipients shall use the
funds provided under a payment made under Title V to cover only those
costs that
(1) are necessary expenditures incurred due to the public health emergency
with respect to Coronavirus Disease 2019 (COVID-19);
(2) were not accounted for in the budget most recently approved as of
March 27, 2020; and
(3) were incurred between March 1, 2020 and December 31, 2021.
B. CRF Prime Recipient Reporting
Each prime recipient must report COVID-19 related costs incurred during the
covered period (the period beginning on March 1, 2020, and ending on
December 31, 2021), into the GrantSolutions4 portal, as outlined in the
2 P. L. 116-136 (March 27,2020)
3 P. L. 116-260 (December 27, 2020)
4 GrantSolutions, a grant and program management Federal shared service provider under the
U.S. Department of Health and Human Services, developed a customized reporting solution to
capture the use of CRF payments from prime recipients. Each prime recipient was required to
designate two preparers to enter and validate data in the portal and an authorizing official, who is
responsible for certification and submission of the recipient’s quarterly report. Prime recipient
quarterly data is provided to the Pandemic Response Accountability Committee, which publishes
the data on its website in accordance with Section 15010 of the CARES Act.
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Coronavirus Relief Fund Reporting Requirements Update (OIG-CA-20-025,
July 31, 2020)5 as follows.
Projects
The prime recipient must list all projects6 it plans to complete with CRF
payments. For each project, the prime recipient will be required to enter the
1. project name,
2. identification number (created by the prime recipient),
3. description, and
4. status of completion.
Expenditure Categories
The prime recipient must 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
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 must also provide detailed obligation and expenditure
information for any contracts and grants awarded, loans issued, transfers
5 The original prime recipient reporting requirements are contained in Coronavirus Relief Fund
Reporting and Record Retention Requirements (OIG-CA-20-021; July 2, 2020).
6 Projects are a grouping of related activities that together are intended to achieve a specific goal.
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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)
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
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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 and for payments to individuals
Aggregate reporting is required on contracts, grants, transfers made to other
government entities, loans, and direct payments that are below $50,000,
and for all payments to individuals.
C. Prime Recipient Certification and Submission
Once the prime recipient preparer(s) has entered and validated data, the
prime recipient’s authorizing official is responsible for reviewing and
certifying the information prior to submission within the GrantSolutions
portal.
D. Treasury OIG Coronavirus Relief Fund Desk Review Overview
Purpose
The purpose of this desk review procedures guide is to assist Treasury OIG
in performing monitoring of the prime recipient’s receipt, disbursements, and
uses of CRF proceeds (hereinafter referred to collectively as uses of CRF) as
reported in GrantSolutiions on a quarterly basis. Procedures for monitoring,
reviewing, and approving prime recipient’s quarterly GrantSolutions
submissions are documented separately in the Coronavirus Relief Fund: Prime
Recipient Quarterly GrantSolutions Submissions Monitoring and Review
Procedures Guide.
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Objective
The objective of the desk review is to evaluate the prime recipient’s
documentation supporting the uses of CRF proceeds as reported in
GrantSolutions, and assess risk of unallowable use of funds. As part of the
desk review, other publically available information, such as Single Audit or
other State Auditor reports, will be used to identify internal control matters
that may pose risk or impact the prime recipient’s appropriate use of CRF
proceeds. The desk review may result in a site visit to the prime recipient for
a more in-depth review or a recommendation for audit.
Desk Review Scope and Methodology
The scope of the desk review will include a single quarter or multi-quarters,
as deemed appropriate, during the prime recipient quarterly reporting period
beginning with the first cycle submission (March 1- June 30, 2020) due
September 21, 2020, through the quarter ending September 30, 2022.
The review methodology includes, but is not limited to, the following:
• review the prime recipient’s quarterly GrantSolutions submission(s);
• review other audit reports (Single Audit, State Auditor, Government
Accountability Office (GAO), and other applicable Federal agency OIG
reports at Oversight.gov) for internal control or other deficiencies that
may pose risk or impact the prime recipient’s uses of CRF proceeds;
• review the National Association of State Auditors, Comptrollers, and
Treasurers newsletter for issues that may pose risk or impact the
prime recipient’s uses of CRF proceeds;
• review Office of Investigations, Pandemic Response Accountability
Committee (PRAC), and Office of Counsel leads on issues that may
pose risk or impact the prime recipient’s uses of CRF proceeds;
• select a judgmental sample of contracts, grants, loans, transfers to
other governments, direct payments, and aggregate reporting
(hereinafter referred to as payment types) based on risks identified in
other audit reports, GrantSolutions reporting deficiencies identified by
the monitoring/approval team, and anomalies identified by the Data
Analytics manager. If necessary, consult with a statistician to identify
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a sampling methodology to determine the appropriate sample size for
review of the prime recipient’s reported obligations and expenditures;
• obtain and evaluate the prime recipient’s documentation and records
used to support the quarterly submission(s);
• interview the prime recipient preparer(s) and certifier as deemed
appropriate;
• interview State Auditors and other applicable oversight agency
personnel as deemed necessary; and
• conduct site visits to the prime recipient, as deemed necessary.
E. Desk Review Procedures
These procedures do not exclude performing additional procedures or steps
deemed necessary based on the prime recipient, the type of payment, and or
other matters identified during the desk review and/or site visit.
I.
Identify a prime recipient for review and consider the following:
a. the prime recipient has exhibited a high degree of difficulty in the
quarterly reporting process;
b. the prime recipient has submitted one or more late quarterly
reports; or
c. the prime recipient has triggered a non-compliance status in one or
more quarterly reports.
d. document the rationale for the selection of prime recipient for
review.
II.
Notify the Prime Recipient of planned desk review.
a. Issue a notification or engagement memorandum to the prime
recipient’s authorized official explaining the purpose of the desk
review. Copy Treasury, the State Auditor, or other oversight
agency as appropriate.
b. Schedule a mutually agreeable date for an entrance conference
with the appropriate management official(s) where details of the
desk review will be provided.
c. Provide a document request list for records supporting sample
selection of contracts, grants, transfers made to other government
entities, loans, direct payments, and payments to individuals
selected for review. See below for consultation with statistician
procedure.
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III.
Perform Preliminary Desk Review Due Diligence
a. Review the prime recipient’s quarterly submission(s) in
GrantSolutions to identify any unresolved reporting issues,
variances between obligations and expenditures, insufficient
descriptions provided for “Items Not Listed Above” expenditure
category, or other anomalies needing further review.
b. Review results of Single Audit(s) and other audits to identify
internal control deficiencies that may pose a risk and/or impact
the prime recipient’s quarterly reporting and compliance with
uses of CRF proceed requirements. Single Audit reports may be
obtained from the recipient's website(s), or the Federal Audit
Clearinghouse Database at https://facweb.census.gov/. Review
reports for the following:
1. the report’s audit findings that could have a potential
effect on the recipient's administration of CRF proceeds
(e.g., cash management, segregation of duties, etc.). For
Single Audit reports, pay particular attention to the
Schedule of Expenditure and Questioned Costs and
Summary Schedule of Prior Audit Findings. If the
recipient's Single Audit report is not a separate report,
review the Federal Program section of the State report for
any findings, paying particular attention to the types of
compliance requirements that caused problems for the
recipient.
2. If findings are identified, review the Management
Response section of the finding and determine if a
corrective action plan (CAP) has been identified. If there
is a CAP, determine if the any of the proposed actions
may otherwise impact the recipient’s management of CRF
received. Also, note the status of corrective actions.
c. Review audit reports related to the prime recipient that received
Federal funding from other Federal agencies. Search websites to
include:
1. https://www.oversight.gov/
2. U.S. Government Accountability Office (U.S.
GAO)
3. https://www.pandemicoversight.gov/
4. Other Federal awarding agencies that provided
Federal funds to the recipient (e.g., the top five
Federal awarding agencies of the recipient,
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which can be collected from the Single Audit
report).
Search for any reports on these websites relating
to CRF/Federal grants to the recipient using the
following terms: "CARES Act," "Coronavirus Relief
Fund”
d. Document reviews of other audit reports or evaluations,
summarizing internal control or other deficiencies,
recommendations, and conclusion as to risk and/or impact on
the prime recipient’s quarterly reporting and compliance with
uses of CRF requirements. Include pertinent information about
the report, including: name of report, link to report, name of
auditor, name of government agency, and date of report.
e. Perform and/or review results of data analytics of the prime
recipient’s GrantSolutions data to include but not limited to (1)
analysis of projects completed using CRF proceeds; (2) analysis
of the prime recipient’s use of CRF by expenditure category to
identify high dollar and unique expenditure types (as described
in Other Category of GrantSolutions); (3) trend analysis by
expenditure category, and (4) identification of anomalies within
obligation and expenditure data, projects (if any), and sub-
recipient population reported.
IV.
Select Sample of Payment Types for Review
a. Select a judgmental sample of payment types. Consider internal
control deficiencies identified in other audit reports or
GrantSolutions reporting deficiencies that may pose risk to and/or
impact the prime recipient appropriate uses of CRF proceeds. If
deemed necessary, consult with statistician to determine
appropriate sample methodology and sample selection to review
obligations and expenditures for payment types. Provide statistician
with GrantSolutions extracts and other information to determine
approach to selecting sample records to review.
b. Document the sample selection to include the methodology and/or
rationale for the selection.
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c. If statistician is consulted, obtain statistician’s documented
sampling methodology to support sample selections or document
the rationale for selection.
V.
Review Prime Recipient Documents/Records
a. Contracts >= $50,000
i. Record the dollar amount ($) of selected contract’s
obligations and expenditures selected for review, contract
date, period of performance, and associated project, if
any.
ii. Does the documentation sufficiently support the selected
contract’s obligations and expenditures, contract date,
period of performance dates, and associated project, if
any?
iii. Does the documentation sufficiently support the selected
expenditure category (noted above)?
iv. Are there any internal control deficiencies identified in
Single Audit and other audit reports that pose a risk to
the prime recipient’s use of CRF proceeds for contracts?
Document potential risk(s). Request and review applicable
prime recipient policies and procedures as necessary.
v. Summarize review results and the types of documents
evaluated.
b. Grants >= $50,000
i. Record the dollar amount ($) of selected grant’s
obligations, expenditures, grant payment type (one-time
payment or reimbursable), grant date, grantee
compliance/noncompliance, and associated project, if
any.
ii. Does the documentation sufficiently support the selected
grant’s obligations and expenditures, and type of grant
(one-time payment or reimbursable)?
iii. For grantee noncompliance, does the documentation
adequately describe circumstances for noncompliance?
Follow up with the prime recipient if deemed appropriate
(i.e. if noncompliance occurs over several quarterly
GrantSolutions submissions).
iv. Does the documentation support the selected expenditure
category (noted above)?
v. Are there internal control deficiencies identified in Single
Audit and other audit reports that pose a risk to the prime
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recipient’s use of CRF proceeds for grants? Document
potential risk(s). Request and review applicable prime
recipient policies and procedures as necessary.
vi. Summarize review results and the types of documents
evaluated.
c. Loans >= $50,000
i. Record dollar amount ($) of selected loan’s obligations,
expenditures, loan date, and associated project, if any.
ii. Does the documentation sufficiently support the selected
loan’s obligation and expenditures, loan date, and project,
if any?
iii. Does the documentation support the selected
expenditure/payment category (noted above)?
iv. Are loan repayment proceeds used or plan to be used for
other CRF allowable uses or returned to Treasury? If
repayments are returned to Treasury, request
documentation supporting the return. If not returned,
document how the funds are used or plans for use by the
prime recipient.
v. Are there internal control deficiencies identified in Single
Audit and other audit reports that pose a risk to the prime
recipient’s use of CRF proceeds for loans? Document
potential risk(s). Request and review applicable prime
recipient policies and procedures as necessary.
vi. Summarize review results and the types of documents
evaluated.
d. Transfers to Other Government Entities >= $50,000
i. Record dollar amount ($) of selected transfer obligations,
expenditures, transfer date, and associated project, if
any.
ii. Record the of government to which the transfer was
made?
iii. Does the documentation sufficiently support the selected
transfer’s obligations, expenditures, transfer date, and
project, if any?
iv. Does the documentation support the selected expenditure
category (noted above)?
v. Are there internal control deficiencies identified in Single
Audit and other audit reports that pose a risk to the prime
recipient’s use of CRF proceeds for transfers (i.e. cash
management and disbursement deficiencies? Document
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potential risk(s). Request and review applicable prime
recipient policies and procedures as necessary.
vi. Summarize review results and the types of documents
evaluated.
e. Direct Payments >= $50,000
i. Record dollar amount ($) of selected direct payment’s
obligations, expenditures, payment date, and associated
project, if any.
ii. Does the documentation sufficiently support the selected
direct payment’s obligations, expenditures, payment date,
and associated project, if any?
iii. Does the documentation support the selected expenditure
category (noted above)?
iv. Are there internal control deficiencies identified in Single
Audit and other audit reports that pose a risk to the prime
recipient’s use of CRF proceeds for direct payments (i.e.
cash management and disbursement deficiencies?
Document potential risk(s). Request and review applicable
prime recipient policies and procedures as necessary.
v. Summarize review results and the types of documents
evaluated.
f. Aggregate Reporting < $50,000
i. Select a payment type (i.e. contract, grant, loan, direct
payment, transfer) to review. Note: Expenditure
categories are not selected for aggregate reporting.
ii. Record dollar amount ($) of selected payment type’s
obligations and expenditures, and payment dates.
iii. Does the documentation sufficiently support the selected
payment type’s obligations, expenditures, and payment
dates?
iv. Are there internal control deficiencies identified in Single
Audit and other audit reports that pose a risk to the prime
recipient’s use of CRF proceeds for payment type?
Document potential risk(s).
v. Summarize review results and the types of documents
evaluated. Request and review applicable prime recipient
policies and procedures as necessary.
g. Aggregate Payments to Individuals (in any amount)
i. Record dollar amount ($) of selected payment type’s
obligations and expenditures, and payment dates.
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ii. Does the documentation sufficiently support the selected
payment type’s obligations, expenditures, and payment
dates?
iii. Are there internal control deficiencies identified in Single
Audit and other audit reports that pose a risk to the prime
recipient’s use of CRF proceeds for payment type?
Document potential risk(s).
iv. Summarize review results and the types of documents
evaluated. Request and review applicable prime recipient
policies and procedures as necessary.
h. Perform follow up with the prime recipient to resolve any
variances and discrepancies identified in the reviews of above
payment types.
i. Prepare a memorandum documenting desk review findings
based on summary results for each payment type category and
overall assessment of the prime recipient’s compliance with
GrantSolutions reporting and uses of CRF proceed requirements.
Based on results of the overall desk review, determine whether
to conduct a site visit to the prime recipient for a more in-depth
review or refer for audit to the Treasury OIG CARES Act I team
or the Office of Investigations (see attachment 1).
VI.
Site Visits
Site visits represent the highest level of prime recipient monitoring.
Treasury OIG staff may initiate site visits based on information obtained
during quarterly reviews and desk reviews. When an on-site field visit is
not possible or practicable for either Treasury OIG staff or the prime
recipient, a virtual site visit may be an option. Among other things, on-
site visits should resolve desk review issues, allow the Treasury OIG to
evaluate the status of projects and/or activities as selected, and apply the
desk review procedures to an expanded scope for review.
During the on-site visit, Treasury OIG will perform additional procedures
to include:
a. conducting an entrance interview with the prime recipient’s
management officials, project personnel, or financial/accounting
staff to set the tone and establish expectations for the on-site
visit;
b. interviewing key officials and staff to discuss any unresolved
issues or problems that were noted during the desk review, and, if
applicable and appropriate, conduct interviews with sub-recipients;
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c. performing desk review procedures above on expanded scope of
obligations, expenditures, payment type, or expenditure categories
as deemed necessary; and
d. conducting an exit conference with the prime recipient to discuss
results and next steps.
Following the site visit, Treasury OIG staff will document the analyses
completed, conclusions drawn, and any next steps or recommended
corrective actions. Based on results of the site review, determine whether
to refer for audit to Treasury OIG CARES Act I Team (see attachment 1)
or the Office of Investigations.
VII.
Perform Post Desk Review Review/Site Visit Procedures
a. Prepare memorandum to notify prime recipient of desk review
results. Document next steps (i.e. audit, refer to Office of
Investigations, or no other action).
b. If site visit conducted, prepare memorandum to notify prime
recipient of the site visit review results. Document next steps (i.e.
audit, refer to Office of Investigations, or no further action).
Attachment 1
CARES Act Coronavirus Relief Fund
Desk Review Report Cover Sheet
Prime Recipient:
Name
Location
Full Address
Date of Desk Review
Date
Reviewers:
Name(s)
Audit Manager Signature & Date
Audit Director Signature & Date
Findings:
Recommendations:
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
________________________________________________________________________
Assistant Inspector General for Audit
Comments:_________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
______________________________________________
Approve:___________ Disapprove:_________ Date:_______
SIGN
SIGN