Increasing Transparency into COVID-19 Spending

Source document: Increasing Transparency into COVID-19 Spending; document type: Review report (CIGIE inspection and evaluation standards).

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PANDEMIC RESPONSE
ACCOUNTABILITY COMMITTEE
INCREASING
TRANSPARENCY
INTO COVID-19
SPENDING
OCTOBER 19, 2021

1
Background
In March 2020 the Coronavirus Aid, Relief, and
Economic Security (CARES) Act created the
Pandemic Response Accountability Committee
(PRAC) to promote transparency and conduct
and support oversight of pandemic-related
funds and the response to the Coronavirus
pandemic (COVID-19).
The objective of this review was to identify
specific gaps in transparency in award data for
federal assistance spending in response to
COVID-19. We conducted the review in
accordance with the Quality Standards for
Inspection and Evaluation issued by the
Council of the Inspectors General on Integrity
and Efficiency (CIGIE).
The CARES Act, the American Rescue Plan Act,
and other related pandemic relief legislation
provided more than $5 trillion to support the
nation’s response to COVID-19. Included in the
legislation are numerous provisions designed
to promote transparency and accountability in
pandemic spending.
Section 15010 of the CARES Act requires the
PRAC to maintain a public website
(PandemicOversight.gov) to provide—among
other things—detailed data on any federal
government awards that expend covered
funds1
1 Section 15010(a)(6) of the CARES Act defines ‘‘covered
funds’’ as any funds, including loans, that are made
available in any form to any non-Federal entity, not including
an individual, under the CARES Act and other pandemic
relief legislation.
 over $150,000. The reported data was
to include data elements required under the
Federal Funding Accountability and
Transparency Act of 2006 (FFATA), as
amended by the Digital Accountability and
Transparency Act (DATA Act), and data at the
subgrant and subcontract level.
Section 15011 of the CARES Act requires
agencies to report on a monthly basis any
obligations or expenditures of awards over

$150,000. The CARES Act also contains
requirements for recipient reporting, similar to
those established during the American
Recovery and Reinvestment Act of 2009
(ARRA). Specifically, on a quarterly basis,
recipients of awards over $150,000 (large
covered funds) are required by statute to
report:
•
The total amount of large covered funds
received from the agency;
•
The amount of large covered funds
received that were expended or
obligated for each project or activity;
•
A detailed list of all projects or activities
for which large covered funds were
expended or obligated, including the
name and description of the projects or
activities;
•
The estimated number of jobs created
or retained; and
•
Detailed information on any level of
subcontracts or subgrants, to include
the data elements required to comply
with FFATA.
Following passage of the CARES Act, the Office
of Management and Budget (OMB) issued
Memorandum M-20-21, Implementation
Guidance for Supplemental Funding Provided
in Response to the Coronavirus Disease 2019
(COVID-19). The guidance allows agencies and
recipients to meet the CARES Act reporting
requirements using the existing agency
reporting processes under the FFATA and the
DATA Act.
The guidance also requires agencies to track
COVID-19 relief spending by Disaster
Emergency Fund Codes (DEFC). OMB Memo M-
20-21 details the role of the DEFC code: “With

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the inclusion of the DEFC attribute in agency
DATA Act reporting, information on covered
funds will be available by obligation and
expenditure at the award level so that the
American public will have insight into how
COVID-19 relief funds were spent. This process
provides low-burden transparency into how
COVID-19 relief funds have been distributed,
thus increasing accountability at multiple
levels, and reducing the likelihood of waste,
fraud, and abuse, and provides a user-friendly
mechanism for agencies and recipients to
meet their financial reporting requirements
under sections 15010 and 15011 of the Act.”
The OMB memo also stipulated that once
agencies have met these requirements, the
information reported by agencies and
recipients should be publicly available on
USAspending.gov.
USAspending.gov is the official source for
spending data for the U.S. Government. In
general, federal spending data flows to
USAspending.gov based on the reporting
requirements in FFATA and the DATA Act. The
DATA Act requires OMB and the U.S.
Department of the Treasury (Treasury), in
consultation with federal agencies, to establish
government-wide data standards that, to the
extent reasonable and practicable, produce
consistent, comparable, and searchable
spending data for any federal funds made
available to or expended by federal agencies.
The DATA Act also requires OMB and Treasury
to ensure that the standards are applied to the
data made available on USAspending.gov.
The federal government provides a broad
range of assistance to the American public in
various areas, such as education, health care,
research, infrastructure, economic
development, and others—through grants,
loans, scholarships, insurance, and other types
of financial assistance. Each assistance
program has a title and unique number, called
an Assistance Listing (previously called a
Catalog of Federal Domestic Assistance (CFDA)
Number), that follows the program throughout
the lifecycle for data and funding transparency.
For example, the Supplemental Nutrition
Assistance Program, operated by the U.S.
Department of Agriculture, is Assistance Listing
number 10.551. Additionally, FFATA and the
DATA Act require data reporting, based on the
Assistance Listing number of the federal
financial assistance, and this reporting is done
through USAspending.gov.
For transparency in pandemic spending,
USAspending.gov created a COVID-19
Spending web page to capture the journey of
COVID-19 dollars from appropriation to
obligation and outlay by federal agencies,
allowing users to see who received funding,
which agencies spent the funds, which
programs were funded, and more.
The data submitted to USAspending.gov is
particularly important to achieving the CARES
Act transparency requirements. Foremost
among these is the award description field,
which is designed to provide a plain language
description of the purpose of the federal
assistance award.

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Finding No. 1: Agencies Are Inconsistent in How They Interpret and Apply OMB
Guidance for Award Descriptions.
DATA REPORTED
• Recipient Name
• Award Description
• Place of Performance
• Awarding Agency
• ...
COVID AWARD
REPORTING
COVID FUNDS
AWARDED
Awarding
Prime
Subrecipients
Agencies
Recipients
Figure 1 – Example of how COVID-19 funding flows from awarding agencies to prime recipients and to
subrecipients for federal assistance programs. With each award, the awarding agency (for prime awards)
and the prime recipient (for sub-awards) reports information regarding the purpose of the award, along
with other award details.
The PRAC found that agencies differ in how
they interpret and apply OMB guidance for the
award description field. As a result, data on
USAspending.gov are not always comparable,
and in many cases, users will have difficulty
understanding the purpose of an award based
on the award description field.
In November 2020, OMB released OMB
Memorandum M-21-03, Improvements in
Federal Spending Transparency for Financial
Assistance, emphasizing the requirements that
agencies:
•
develop award descriptions that avoid
acronyms or federal- or agency-specific
terminology, and
•
include the purpose of the award along
with specific performance goals,
indicators, milestones, or expected
outcomes, and intended beneficiary or
recipient of the funds.
In this guidance, OMB states, “Award
descriptions are distinct from the
programmatic level information provided in the
Assistance Listings and Federal awarding
agencies are discouraged from including
general programmatic level information in the
award description.” In other words, OMB is
reminding agencies to avoid re-using text from
other award data fields (such as the Assistance
Listing field) in the award description field.
Our review of the award description data in
USAspending.gov for pandemic assistance
programs identified approximately 12,600
awards totaling approximately $11.6 billion
where the award description simply matched
the Assistance Listing name. In addition to
being non-complaint with OMB guidance, re-
using the Assistance Listing name in the award
description field is both redundant and offers
no additional information regarding the intent
or purpose of each award. Of the 12,600
awards, more than 9,900 awards totaling

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Good Award Description
Poor Award Description
Education Stabilization Fund
Child Care and Development
Block Grant
Education Stabilization Fund
Coronavirus Emergency
Supplemental Funding Program
Award ID: P425F202271
“Higher Education Emergency Relief
Fund for institutional cost related to
COVID-19 for expenses related to
moving education and services to
students to an online environment.”
Award ID: 2101TXCCC5
“CCC5-2021”
Award ID: P425E201557
“CARES”
Award ID: 2020VDBX0855
“COVID-19”
Figure 2 – An example of a COVID-19 award description that meets the OMB requirements compared to
poor award descriptions that use agency-specific jargon or only reference the legislation (e.g., CARES) or
COVID-19.
approximately $8.8 billion are from the U.S.
Department of Housing and Urban
Development (HUD). As an example, HUD has
more than 1,100 awards (totaling $2.1B)
within Assistance Listing 14.218, Community
Development Block Grants/Entitlement Grants,
all with the same award description of
“Community Development Block
Grants/Entitlement Grants,” a verbatim match
to the Assistance Listing title. When including
all grants, loans, direct payments, and other
financial assistance awards, HUD has more
than 37,000 awards totaling approximately
$11B in COVID assistance spending with award
descriptions that are an exact or close match
to the Assistance Listing name. We brought this
preliminary finding to the attention of the Chief
Financial Officers Council and HUD leadership
in March 2021 for further review.
We also identified more than 2,450 awards
totaling approximately $19 billion in pandemic
assistance that include agency specific jargon
for award descriptions. For example, we
identified 276 Child Care and Development
Block Grants (Assistance Listing 93.575)
totaling $9.8 billion from the U.S. Department
of Health and Human Services (HHS) had the
award description “CCC5-2021.” We identified
a $300 million award from the Department of
Transportation Federal Transit Formula Grants
(Assistance Listing 20.507) with the award
description “CRRSAA 2021.”
We identified more than 360 pandemic
assistance awards totaling more than $1.8
billion that include brief and non-descriptive
award descriptions, such as “CARES,” “CARES
ACT,” or “COVID-19.”
Non-specific award descriptions prevent the
public, agency management, and policy makers
from determining the use of the federal
pandemic assistance. A lack of transparency
also hampers oversight and accountability
efforts.
These substandard entries were partially the
result of the need to quickly award COVID-19
assistance in the initial months of the
pandemic. These entries were also likely due to
a lack of continuous monitoring of government-
wide agency submissions and the absence of
data governance processes that enforce the
consistent use of established standards and
guidelines. Without these processes,

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preexisting challenges2
2  Government Accountability Office’s prior work on Federal Data Transparency: https://www.gao.gov/federal-data-transparency
 related to how
agencies interpret and apply data standards
were amplified by the pandemic.
During the ARRA reporting, recipient reporting
included narrative data fields that provided
details into the purpose of the award. These
data fields are not available for COVID-19
reporting. As a result, the award description
field is the lone remaining narrative field to
detail the purpose and intent of pandemic
assistance spending.
We recognize that OMB has made efforts to
enhance the quality of information in the award
description field for pandemic assistance by
issuing guidance in Memo M-20-21 (April
2020), Memo M-21-03 (November 2020), and
Memo M-21-20 (March 2021), and Controller
Alert, Additional Instructions to Agencies for
Contract Awards in Support of COVID-19
Response - Improve Clarity of Award &
Modification Descriptions (August 2020).
Recommendations:
1. OMB should, in coordination with the
PRAC, offer resources for agencies that
focuses on improving the quality of
award descriptions to result in
consistent use and application of this
field across all agency submissions and
to provide clarity on the intent and
purpose of pandemic assistance.
OMB Response and PRAC Evaluation:
OMB concurred with the
recommendation. OMB plans to
develop resources to assist agencies in
addressing the quality of their
descriptions. OMB plans to complete
planned actions within the next year in
coordination with the PRAC.
This recommendation is resolved. To
close this recommendation, OMB will
need to provide the PRAC evidence of
resources (training sessions, fact
sheets, etc.) that support agency staff
in addressing the quality of their award
descriptions to improve the quality of
COVID-19 relief spending data reported
to USAspending.gov.
2. OMB should develop and implement a
plan, leveraging its resources and in
coordination with the PRAC, to
disseminate to individual agencies
examples of insufficient award
descriptions in need of remediation.
OMB Response and PRAC Evaluation:
OMB concurred with the
recommendation. OMB plans to
disseminate to agencies examples of
award descriptions that do not meet the
level of quality required in OMB policy.
OMB plans to complete planned actions
within the next year in coordination with
the PRAC.
This recommendation is resolved. To
close this recommendation, OMB will
need to provide the PRAC evidence that
OMB disseminated to each agency with
COVID-19 relief award descriptions that
do not meet OMB policy guidance
actions for improvement/remediation.
3. OMB should engage with Congress to
consider legislating amendments to
extend independent oversight of
USAspending.gov data submissions,
including developing new requirements
in consultation with CIGIE and the PRAC
for the review of agency award
descriptions.

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OMB Response and PRAC Evaluation:
OMB concurred with the
recommendation. OMB plans to
continue to work closely with PRAC and
Congress to ensure that PRAC and
CIGIE have the appropriate statutory
mandates to conduct the proper
oversight of COVID-19 relief data.
This recommendation is resolved. To
close this recommendation, OMB will
need to provide the PRAC evidence of
actions to initiate conversations and
engage with Congress and/or key policy
stakeholders to consider legislative
amendments to extend independent
oversight of USAspending.gov data
submissions.
Finding No. 2: USAspending.gov Does Not Definitively Track COVID-19 Supplemental
Spending at the Subrecipient Level.
Figure 3 - COVID-19 funding is tracked at the prime recipient level; however, there is no way to trace COVID-
19 funding at the subrecipient level, which leads to a lack of transparency in how and where COVID-19
funding was used at the local level.
A large percentage of subrecipient3
3 Covered, or pandemic-related funds, can also be spent by subrecipients—nonfederal entities that are awarded covered funding
through a legal instrument from the prime recipient to manage and support the performance of any portion of the substantive
project or program for which the prime recipient received the covered funding.
 awards
tracked on USAspending.gov can only be
inferred to be COVID-19- related. This occurs
because the prime recipient reporting the sub-
award information is not required—or able—to
identify the sub-award as COVID-19 funded
when the prime receives funds from multiple
appropriations/sources. USAspending.gov
contains the following disclaimer: ‘If a prime
award is funded by a combination of COVID-19
supplemental appropriations and general
appropriations, there is no way to be certain
from this data which source funded a given
subaward.’
To determine how prevalent the issue is, the
PRAC reviewed the top 100 grant Assistance
Listings with the largest COVID-19 obligations.
The PRAC discovered that 71 of the top 100
Assistance Listings received funding from
multiple sources, thereby making it impossible
to definitively follow COVID-19 funding down to
subrecipient awards. The CARES Act requires
recipients to submit to agencies detailed
information on any level of subcontracts or
subgrants awarded by the covered (i.e., prime)

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recipient or its subcontractors or subgrantees4
4 See CARES Act Section 15011.
.
Unlike prime award data submitted by federal
agencies to USAspending.gov that use the
DEFC to track COVID-19 funding,
USAspending.gov cannot display COVID-19
funding for subrecipients since it is not
reported.
Prime recipients submit their first-tier
sub-award data to the FFATA Subaward
Reporting System (FSRS). The sub-award
information entered in FSRS is then displayed
on USASpending.gov associated with the prime
award. However, FSRS does not have the
capability for prime award recipients to detail if
they used COVID-19 funding (i.e., a DEFC) when
reporting subrecipient awards. As a result,
COVID-19 spending data for sub-awards is not
displayed on USAspending.gov. This means
that the only way to know for certain if a
sub-award used COVID-19 funding is if the
prime recipient only received COVID-19 funding
but not due to systemic tracking or reporting.
Without processes to definitively track
COVID-19 spending at the subrecipient level,
there is little transparency into how COVID-19
funding flows down to local projects. Moreover,
the inability to track subrecipient spending for
many of the assistance programs leads to a
misunderstanding of where and how the funds
were used.
Not knowing this information could lead users
of USAspending.gov to inadvertently draw
inaccurate conclusions from the data.
Recommendation
4. OMB should conduct a feasibility study,
in coordination with relevant federal
and non-federal stakeholders, as to
how to better track and report
subrecipient funding.
OMB Response and PRAC Evaluation:
OMB concurred with the
recommendation. OMB plans to
conduct a feasibility study of how to
better track and report subrecipient
spending and anticipates providing the
PRAC with better access to subrecipient
data.
This recommendation is resolved. To
close this recommendation, PRAC will
need evidence that OMB initiated and
completed a feasibility study focused on
improving the tracking and reporting of
subrecipient spending presented on
USAspending.gov.
Finding No. 3: Populations of Pandemic Assistance Sub-Award Data Are Missing on
USAspending.gov.

Subrecipients
UNKNOWN/UNTRACKED
SUBRECIPIENTS
Awarding
Agencies
Prime
Recipients
COVID FUNDS
AWARDED
COVID AWARD
REPORTING
UNCONFIRMED
COVID FUNDS
AWARDED
LACK OF COVID
AWARD REPORTING
Figure 4 - Not all prime recipients are reporting sub-award data to USAspending.gov, leading to questions as to
whether there are a) no awards or b) awards do exist but the prime recipient never reported the sub-award
data so it is not displayed on USAspending.gov.

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Not all prime recipients are consistently
reporting subrecipient data, leading to
questions as to whether there are (a) no such
awards or (b) awards do exist but the prime
recipients never reported the sub-award data.
We identified gaps in subrecipient reporting
data by cross-referencing other authoritative
sources of spending data, such as states’
financial reports and federal and state agency
websites. We found that, on average, only 59%
of prime recipients are reporting any
subrecipient data across the ten grant
programs with the largest COVID-19
obligations.
The CARES Act requires agencies to submit
detailed information on any level of
subcontracts or subgrants awarded by the
covered recipient or its subcontractors or
subgrantees. FFATA and the DATA Act require
that all data regarding sub-awards are
disclosed in the same manner as data
regarding other federal awards. Prime
recipients are required to self-report first-tier
sub-award information in FSRS, however, there
is minimal monitoring of the submissions by
the awarding agency.
Furthermore, while limited data is
collected/reported for the first-tier sub-awards,
no information is collected or reported at
subsequent second- to n-tier (third tier and
beyond) sub-awards.
This gap in reporting sub-award data was
partially the result of the focus on awarding
assistance funds in OMB Memo M-20-21 which
stated that “time is of the essence” and
agencies should seek to balance mission
achievement, expediency, and transparency
and accountability.
During our review, for example, we identified
more than 1,600 State of California sub-
awards for the U.S. Department of Education’s
Education Stabilization Fund (Assistance
Listing 84.425) that were not listed on
USAspending.gov. However, information
regarding these sub-awards was available for
download on the California Department of
Education website. We found at least two other
states (New York, Vermont) and the District of
Columbia that did not have any sub-awards
reported for the Education Stabilization Fund
on USAspending.gov as of May 2021, more
than 13 months after the enactment of the
CARES Act (and obligation of the associated
COVID-19 supplemental funds). Sub-award
data for each of these states and the District of
Columbia was updated in USAspending.gov in
June 2021, after we brought this preliminary
finding to the attention of Chief Financial
Officers Council and OMB in March 2021;
however, this reporting delay creates
transparency concerns.
We have determined that similar issues persist
in other assistance programs. For example, the
State of Florida’s Comprehensive Annual
Financial Report for FY2020 highlights the
state making more than 1,000 sub-awards
totaling more than $1.2 billion for the U.S.
Department of Homeland Security Disaster
Grants – Public Assistance (Presidentially
Declared Disasters) program (Assistance
Listing 97.036). None of these sub-awards are
reported on USAspending.gov. Further analysis
shows that 55 states and territories received
awards as part of the Disaster Grants – Public
Assistance (Presidentially Declared Disasters)
program. However, only 37 states and
territories are reporting any sub-award data.
The remaining 18 states and territories (such
as Florida) are not reporting any sub-award
data, which means nothing is listed on
USAspending.gov.
A lack of data is assumed as a lack of award(s).
This is not always the case but due to the lack
of sub-award data, false assumptions are
likely. Furthermore, an incomplete

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understanding of the impact of pandemic
assistance programs leads to a lack of
transparency into the outcomes and objectives
of the assistance program(s).
As noted in Finding No. 2, the inability to track
local (e.g., subrecipient) spending for many of
the assistance programs leads to a
misunderstanding of where and how the funds
were used.
Recommendation
5. OMB should engage with Congress to
consider legislating amendments to
extend independent oversight of
USAspending.gov data submissions,
including developing new requirements
in consultation with the CIGIE and the
PRAC for the review of subrecipient
reporting.
OMB Response and PRAC Evaluation:
OMB concurred with the
recommendation. OMB plans to
continue to work closely with PRAC and
Congress to ensure that PRAC and
CIGIE have the appropriate statutory
mandates to conduct the proper
oversight of COVID-19 relief data.
This recommendation is resolved. To
close this recommendation, OMB will
need to provide the PRAC evidence of
actions to initiate conversations and
engage with Congress and/or key policy
stakeholders to consider legislative
amendments to extend independent
oversight of USAspending.gov data
submissions.
Other Matters: Delays in Updating or Omitting Key Data Elements on USAspending.gov
Could Lead Users to Draw Inaccurate Conclusions.
Outlay data not reported more than 19
months after the onset of the pandemic.
Per OMB Memo 20-21, agencies were required
to report outlay (or expenditure) data for
pandemic funding beginning in June 2020.
However, we discovered that some agencies
are not reporting any outlay data for COVID-19
awards, more than 19 months after the onset
of the pandemic. The lack of outlay data 19
months into the pandemic means that there is
less transparency into how much has actually
been spent in response to the pandemic.
Although some agencies are reporting outlay
data in their assistance submissions, other
agencies are not providing data at all. Even
within agencies, some Assistance Listings
include outlay data, while others do not.
Further compounding this issue, alerts or
notices informing users about the potential
lack of outlay data are not fully disclosed on
USAspending.gov. Not knowing this information
could lead users of USAspending.gov to
inadvertently draw inaccurate conclusions from
the data.
Awards labeled “Unknown” create confusion
for users.
As of July 2021, there are approximately 1,900
COVID-19 awards totaling more than $3.4
billion on USAspending.gov that are labeled
“unknown” and have no award information.
These “unknown” awards are not tied to
specific Assistance Listing(s), resulting in no
transparency into what the funding is intended
to support or achieve.
Subrecipient award data is reported in
USAspending.gov but is not tied to a specific
Assistance Listing.
As of April 2021, more than 24,000 sub-award
records within the Department of Education’s

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Education Stabilization Fund (Assistance
Listing 84.425) had no information in the
Assistance Listing field. As a result, these sub-
awards are not presented on USAspending.gov
when searching for the Education Stabilization
Fund Assistance Listing. This is another
example of the difficulties in tracking sub-
awards, combined with the previously
discussed issues around the inability to
definitively track COVID-19 sub-award funding
and the significant populations omitting sub-
award data.
Additional Gaps Previously Identified
As identified in the November 2020 PRAC-
commissioned report, Transparency in
Pandemic-Related Spending: Report of
Alignment and Gaps, the following major data
gaps still exist in USAspending.gov although
the data is required by the CARES Act.
1. No Second- to N-tier award
information.
Data is collected for the first-tier sub-
awards, but no information is collected
or reported at subsequent n-tier sub-
awards (second tier and beyond).
2. No information about jobs created or
retained by award.
Per OMB 20-21, agencies are not
required to collect and report data on
jobs created or retained as required by
the CARES Act. Therefore, this data is
not available on USAspending.gov, as
required under the CARES Act.

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Acronyms
ARRA
American Recovery and Reinvestment Act of 2009
CARES Act
Coronavirus Aid, Relief, and Economic Security Act
CFDA
Catalog of Federal Domestic Assistance (recently retitled as Assistance Listing)
COVID-19
Coronavirus pandemic
CIGIE
Council of the Inspectors General on Integrity and Efficiency
DAIMS
DATA Act Information Model Schema
DATA Act
Digital Accountability and Transparency Act
DEFC
Disaster Emergency Fund Codes
FFATA
Federal Funding Accountability and Transparency Act of 2006
FSRS
FFATA Subaward Reporting System
FY

Fiscal Year
HHS

U.S. Department of Health and Human Services
HUD

U.S. Department of Housing and Urban Development
OIG

Office of Inspector General
OMB

Office of Management and Budget
PRAC
Pandemic Response Accountability Committee
Treasury
U.S. Department of the Treasury

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Appendix A: Summary of Poor COVID-19 Award Descriptions
Table 1: Examples of Award Descriptions That Match the Assistance Listing Name
Award Description
Agency
Assistance
Listing
Number
Count of Award
Description
Occurrence
COVID-19 Obligation
EMERGENCY SOLUTIONS
GRANT PROGRAM
DEPARTMENT OF
HOUSING AND URBAN
DEVELOPMENT (HUD)
14.231
354
$3,727,250,105
COMMUNITY DEVELOPMENT
BLOCK GRANTS/ENTITLEMENT
GRANTS
HUD
14.218
1,104
$2,089,675,440
COMMUNITY DEVELOPMENT
BLOCK GRANTS/STATE'S
PROGRAM AND
NON-ENTITLEMENT GRANTS IN
HAWAII
HUD
14.228
50
$2,085,916,492
UNEMPLOYMENT INSURANCE
DEPARTMENT OF
LABOR
17.225
135
$1,143,687,844
BLOCK GRANTS FOR
COMMUNITY MENTAL HEALTH
SERVICES
DEPARTMENT OF
HEALTH AND HUMAN
SERVICES (HHS)
93.958
53
$813,323,457
PUBLIC AND INDIAN HOUSING
HUD
14.850
6443
$684,547,081
EMERGENCY FOOD AND
SHELTER NATIONAL BOARD
PROGRAM
DEPARTMENT OF
HOMELAND SECURITY
(DHS)
97.024
2
$310,000,000
HEAD START
HHS
93.600
426
$123,590,593
INDIAN COMMUNITY
DEVELOPMENT BLOCK GRANT
PROGRAM
HUD
14.862
96
$99,100,000
ASSISTANCE TO FIREFIGHTERS
GRANT
DHS
97.044
1,608
$76,266,388
EMERGENCY MANAGEMENT
PERFORMANCE GRANTS
DHS
97.042
33
$66,815,816
HOUSING OPPORTUNITIES FOR
PERSONS WITH AIDS
HUD
14.241
205
$62,937,351

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TABLE 2: EXAMPLES OF AWARD DESCRIPTIONS USING AGENCY-SPECIFIC JARGON
Award Description
Agency
Assistance Listing
Number
Count of Award
Description
Occurrence
COVID-19
Obligation
CCC5-2021
DEPARTMENT OF
HEALTH AND HUMAN
SERVICES (HHS)
93.575
276
$9,872,841,870
CCC3-2020
HHS
93.575
275
$3,455,997,101
PHFE CDPH ELC
2019-2024
HHS
93.323
1
$2,251,104,897
CSC3-2020
HHS
93.569
111
$983,508,021
E5C3-2020
HHS
93.568
195
$899,998,456
HDC3-2020
HHS
93.045
56
$480,143,372
CRRSAA 2021
DEPARTMENT OF
TRANSPORTATION
20.507
1
$301,367,165
SSC3-2020
HHS
93.044
56
$199,856,628
HDC5-2021
HHS
93.045
56
$168,000,000
FCC3-2020
HHS
93.052
56
$100,000,000
2020 ILC3 –
CARES
HHS
93.432
352
$85,000,000
CWC3-2020
HHS
93.645
231
$44,897,402
FVC3-2020
HHS
93.671
188
$39,112,939
RADX-UP CDCC
HHS
93.310
1
$27,816,167
N/A
DEPARTMENT OF
EDUCATION
84.425
13
$22,009,561

14
TABLE 3: EXAMPLES AWARD DESCRIPTIONS THAT REFERENCES TO CARES ACT, COVID-19, OR OTHER
SIMILAR TYPES OF ENTRIES
Award
Description
Agency
Assistance
Listing
Number
Award Description
Occurrence Count
COVID-19
Obligation
CARES ACT
FUNDING FY20
DEPARTMENT OF
TRANSPORTATION (DOT)
20.507
1
$817,487,351
CARES ACT
DEPARTMENT OF EDUCATION
(ED)
84.425
65
$72,884,031
CARES ACT
DOT
20.507
3
$54,519,876
CARES ACT
OPERATING
ASSISTANCE
DOT
20.507
3
$123,776,765
CARES ACT
FUNDING
ED
84.425
20
$72,964,845
CARES ACT
FUNDING
DOT
20.509
1
$359,675
FY 20 CARES ACT
DOT
20.507
1
$61,307,439
CARES ACT 5311
RURAL
DOT
20.509
1
$55,954,848
RURAL AREA
5311 CARES ACT
DOT
20.509
1
$47,126,485
IADOT 5311
CARES ACT
DOT
20.509
1
$42,820,959
FY20 COVID-19
EMERGENCY
GRANT
ED
84.425
1
$31,448,178
CARES ACT
RELIEF
ED
84.425
2
$30,476,999
2ND EMERGENCY
RELIEF FUND
ED
84.425
1
$28,156,561
CARES ACT
FUNDING –
COVID-19
ED
84.425
3
$26,337,032
2020 CARES ACT
DOT
20.507
1
$24,162,926

15
Appendix B: Subrecipient Data for the State of Florida in Florida’s
Comprehensive Annual Financial Report Compared to USAspending.gov for
Assistance Listing 97.036

16
Appendix C: OMB’s Response to the Draft Report
EXECUTIVE OFFICE OF THE PRESIDENT
OFFICE OF MANAGEMENT AND BUDGET
WASHINGTON, D.C. 20503
October 14, 2021
The Honorable Michael E. Horowitz
Chairman
Committee on Pandemic Response and Accountability
United States Senate
Washington, D.C. 20510-6250
Dear Mr. Chairman:
OMB provides this response on its actions related to the findings and recommendations
of the Pandemic Response and Accountability Committee (PRAC) in its report titled “Increasing
Transparency into COVID-19 Spending” pursuant to Section 15010 of the Coronavirus Aid
Relief and Economic Security (CARES) Act. In its final report, the PRAC provides three
findings and five recommendations to OMB to improve financial assistance spending
transparency. OMB generally agrees with the PRAC’s findings and recommendations. More
broadly, OMB appreciates the ongoing collaboration between OMB, the White House American
Rescue Plan (ARP) Implementation Team, and the PRAC to strengthen implementation to
deliver on pandemic relief programs provided by the Congress.
OMB remains committed to improving the quality of COVID-19 relief spending data
reported to USAspending.gov. OMB, in coordination with the PRAC, will continue to focus on
improving financial assistance award description and subaward data. Within the next year we
expect these efforts will include dissemination to agencies of examples of award descriptions
that do not meet the level of quality required in OMB policy (PRAC Recommendation 2), and
the development of resources to assist agencies in addressing the quality of their descriptions
going forward (PRAC Recommendation 1). Strengthening financial assistance award
descriptions has been an important implementation priority for OMB with regards to ARP
implementation. We also look forward to conducting a feasibility study of how to better track
and report subrecipient spending, and anticipate providing the PRAC with better access to
subrecipient data in order to facilitate our exchanges on that topic. (PRAC Recommendation 4).
Finally, OMB highly values the work of the PRAC and the Council of Inspectors General
on Integrity and Efficiency (CIGIE) in conducting independent oversight of the quality of

17
transparency reporting data, in particular with respect to award descriptions and subaward
reporting (PRAC Recommendations 3 and 5). OMB looks forward to continuing to engage with
the PRAC and Congress to ensure that the PRAC and CIGIE have the appropriate statutory
mandates to conduct needed oversight of these data.
Further, due to the high priority that OMB places on independent oversight of data
quality, and in accordance with the Single Audit Act Amendments of 1996, OMB updated the
Single Audit Compliance Supplement to require the review of recipient subaward reporting for
programs with COVID-19 spending in 2020, and for all programs as part of audits of fiscal years
ending after September 30, 2020. OMB anticipates this new requirement will allow agencies to
leverage insights from the Single Audits they receive to understand where further efforts on the
part of recipients to improve data quality may be needed.
OMB appreciates the efforts on the part of the PRAC to provide oversight and
accountability for transparency of federal spending in response to the COVID-19 pandemic, and
looks forward to continued engagement to advance these efforts.
If you have any questions, please contact OMB’s Office of Federal Financial
Management at 202-395-3993.
Sincerely,
Shalanda D. Young
Acting Director

18
Appendix C: Scope and Methodology
The objective of this review was to identify specific transparency gaps in award data for federal
assistance spending in response to the Coronavirus Disease 2019 (COVID-19) pandemic. This review
was completed between March 2021 – August 2021.
To review federal assistance award data for COVID-19 spending, we used data from USAspending.gov’s
COVID-19 Spending web page. Data was originally downloaded from USAspending.gov in March, with
additional downloads in April, May, June, July and August 2021. The USAspending.gov COVID-19
Spending web page allows users to view spending data by Assistance Listing, along with total spending
by budget category, spending by recipient, spending by sub-agency, and other pre-set filters. For the
Assistance Listing award data, USAspending classifies the different federal assistance by grants, loans,
direct payments, and other financial assistance.
For this evaluation, we analyzed the award data across the ~250 different grant programs that received
COVID-19 funding.  To view the metadata for all awards, we downloaded the USAspending.gov COVID-
19 download, which includes all data displayed on the USAspending.gov COVID-19 Spending web page
as well as many additional data elements. We then analyzed the award data to conduct our evaluation.
Key data elements we reviewed as part of the evaluation included:
-
Award Description
-
Recipient Name
-
Awarding Agency Name
-
CFDA Numbers and Titles
-
COVID-19 Supplementals Funding
Obligations
-
Outlayed Amount Funded by COVID-19
Supplementals
-
Period of Performance, and
-
Other award data elements to examine
the transparency of each award.
In addition to data downloaded from USAspending.gov, where available, the PRAC reviewed federal
agencies’ websites, state agency websites, and other publicly available COVID-19 award data to
determine if additional award data exists beyond what is submitted to USAspending.gov. In addition,
the PRAC searched reports and audits published in the Federal Audit Clearinghouse
(https://facweb.census.gov/uploadpdf.aspx) to cross-reference data from these reports against data
posted on USAspending.gov.
This assessment is reliant on the quality of data made available on the USAspending.gov. The PRAC
did not alter or change any data downloaded from USAspending.gov in any capacity to conduct this
assessment.
We conducted this engagement in accordance with the Council of the Inspectors General on Integrity
and Efficiency’s Quality Standards for Inspection and Evaluation. Those standards require that we plan
and perform the engagement to obtain sufficient and appropriate evidence to provide a reasonable
basis for our conclusions and observations based on our objective. We believe that the evidence
obtained provided a reasonable basis for our conclusions and observations based on our evaluation
objective. We relied on computer-processed data to satisfy our evaluation objective. We relied on
previous audit work regarding the reliability of the computer-processed data we used and deemed the
data to be sufficiently reliable.

PRAC Point of Contact
Brooke Holmes
Associate Director of Oversight and Accountability
Brooke.Holmes@cigie.gov
Visit Our Website at:
https://PandemicOversight.gov
Follow us social media:
@COVID_Oversight
REPORT FRAUD, WASTE, ABUSE, AND MISMANAGEMENT
To report allegations of fraud, waste, abuse, or misconduct regarding funds or
programs covered within the following Acts, please go to the PRAC website at
PandemicOversight.gov.

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