Government Grantee Quarterly Reporting Desk Review Procedures (OIG-CA-22-013)

Source document: Government Grantee Quarterly Reporting Desk Review Procedures (OIG-CA-22-013); document type: inspector-general-sigpr-reports.

Full text

DEPARTMENT OF THE TREASURY
OFFICE OF INSPECTOR GENERAL

Emergency Rental Assistance
Government Grantee Quarterly Reporting Desk Review
Procedures
OIG-CA-22-013
April 22, 2022

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A. Emergency Rental Assistance Program Overview

Section 501 of Division N, Title V, Subtitle A, of the Consolidated
Appropriations Act, 2021 (CAA, 2021) created the first Emergency
Rental Assistance program (ERA1). ERA1 provides up to
$24.985 billion in assistance to States (including Washington, DC),
U.S. Territories, Tribes or their Tribally Designated Housing
entity (TDHE), the Department of Hawaiian Home Lands, and units of
local government with populations of 200,000 or greater. ERA1 funds
are to be available for vulnerable renter households negatively
impacted by the 2019 Novel Coronavirus Disease (COVID-19)
pandemic to pay for rent, utilities, and other housing related expenses
and arrears. The American Rescue Plan Act of 2021 extended the
availability of ERA1 funding through September 30, 2022.

Section 501(i) of the CAA, 2021 requires the Department of the
Treasury (Treasury) Office of Inspector General (OIG) to provide
oversight and monitoring in conjunction with Treasury management
over ERA1 funds and authorizes our office to require repayment of
funds to Treasury if we determine a grantee has failed to comply with
ERA1 program requirements.

B. ERA1 Grantee Quarterly Reporting

Payments and Allocations
Grantees may use ERA1 funds to provide financial assistance and
housing stability services to eligible households.
Eligible Uses
Under ERA1, eligible grantees must use not less than 90 percent of
awarded funds to provide financial assistance to eligible households.

Financial Assistance includes:
– Rent
– Rental Arrears
– Utilities and Home Energy costs
– Utilities and Home Energy Costs Arrears
– Other Expenses related to housing incurred due, directly or
indirectly, to the COVID-19 outbreak, as defined by the
Secretary.1

1  For ERA1, other expenses related to housing include relocation expenses (including prospective
relocation expenses), such as rental security deposits, and rental fees, which may include
application or screening fees. It can also include reasonable accrued late fees (if not included in
rental or utility arrears), and Internet service provided to the rental unit.

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Not more than 10 percent of awarded funds received by an eligible
grantee shall be used for housing stability services including case
management and other services intended to keep households stably
housed.
Housing Stability Services include:
– Housing and fair housing counseling
– Eviction prevention and diversion services
– Funds to provide eligible households with case management and
other services related to the COVID-19 outbreak (under ERA1)
Not more than 10 percent of the amount paid to an eligible grantee
under this section may be used for covering administrative costs
attributed to providing financial assistance and housing stability
services.2
Administrative Costs include salaries, overhead and personnel
expenses associated with administering the program.3
Period of Assistance:
– An eligible household may receive up to 12 months of
assistance (under ERA1)
o an additional three months may be received, if necessary,
to ensure housing stability for the household (subject to
the availability of funds)
– Financial assistance for prospective rent payments is limited to
three months based on any application by or on behalf of the
household
o the household may receive assistance for prospective rent
payments for additional months that are:
 subject to the availability of remaining funds
currently allocated to the grantee
 based on a subsequent application for additional
assistance
o If an applicant has rental arrears, grantees may not make
commitments for prospective rent payments to an eligible

2  The revised award terms for ERA1 issued by Treasury permit grantees to use funds provided to
cover both direct and indirect costs. A grantee may permit a subrecipient to incur more than
10 percent of the amount of the subaward issued to that subrecipient as long as the total of all
administrative costs incurred by the grantee and all subrecipients, whether as direct or indirect
costs, does not exceed 10 percent of the total amount of the award provided to the grantee
from Treasury.
3  The revised award terms for ERA1 no longer require grantees to deduct administrative costs
charged to the award from the amount available for housing stability services. Rather, any
direct and indirect administrative costs in ERA1 must be allocated by the grantee to either the
provision of financial assistance or the provision of housing stability services.

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household unless assistance has also been provided to
reduce that household’s rental arrears
Eligible Household Requirements
To be eligible, a household must be obligated to pay rent on a
residential dwelling and the grantee must determine that:
– one or more individuals within the household has
o qualified for unemployment benefits or
o experienced a reduction in household income, incurred
significant costs, or experienced other financial hardship
due, directly or indirectly, to the COVID 19 outbreak,
which the applicant shall attest in writing;
– one or more individuals within the household can demonstrate a
risk of experiencing homelessness or housing instability, which
may include:
o a past due utility or rent notice or eviction notice
o unsafe or unhealthy living conditions
o any other evidence of such risk, as determined by the
eligible grantee involved
– the household income is at or below 80 percent of the Area
Median Income (AMI); and
– funds made available are not duplicative of any other federally
funded rental assistance provided to such household
Income Determination:
– Grantees shall consider either a household’s:
o Total household income for calendar year 2020; or
o Monthly income at the time of application for assistance
(grantees must re-determine income eligibility every
3 months for this determination)
Reallocation Guidance
The ERA1 statute requires Treasury to identify excess funds for
reallocation from amounts grantees have not obligated from their initial
ERA1 allocations. Specifically, the statute provides that beginning on
September 30, 2021, Treasury must recapture excess funds, as
determined by the Secretary, not obligated by a grantee for eligible
ERA1 purposes, and Treasury must reallocate those funds to Grantees
that, at the time of the reallocation, have obligated at least 65 percent
of their initial ERA1 allocation, including a 10 percent set-aside of the
initial allocation for administrative costs. The amount of any
reallocation is based on demonstrated need within a Grantee’s
jurisdiction, as determined by Treasury.4

4  Detailed instructions for reallocating ERA funds is located in the ERA-Reallocation Guidance
dated October 4, 2021. ERA-Reallocation-Guidance.pdf (treasury.gov)

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– Consistent with these requirements, Treasury has developed the
following policies and procedures for identifying the excess
funds that will be available for reallocation: Treasury will rely on
the following factors for identifying excess funds.5
1. Insufficient Expenditure Ratio
2. Failure to Make Required Submissions
3. Unobligated Funds at Final Assessment
– Each factor will be applied separately.
– Treasury will notify a grantee in writing upon determining that
any part of its allocation constitutes excess funds and will
provide instructions for the funds’ return.
– Excess funds must be returned within 10 days of receiving such
notice.
Full Quarterly Reporting Requirements
The ERA Program requires ERA grantees to certify and submit monthly
and quarterly reports.6
– The monthly reports are brief two-question updates through
which ERA grantees provide Treasury with very high-level
counts of the numbers of households receiving assistance and
the amounts of ERA funds distributed.
– The quarterly reports are in-depth reports with information on
an array of programmatic and financial information.
ERA grantees must gather and track required information throughout
each reporting period and submit required reports using Treasury’s
Salesforce Portal (Portal). Grantees with both ERA1 and ERA2 awards
must provide separate, independent reports for each award. Grantees
with multiple ERA awards must take care to ensure that they do not
commingle funds, data, or records across the two awards and to
submit separate reports for each award.
The ERA reporting requirements differ by the type of ERA grantee.
State, Local and Territorial (SLT) ERA1 and ERA2 grantees are
required to submit monthly and quarterly reports, while Tribes, TDHE
and the Department of Hawaiian Home Lands (DHHL) are required to
submit only partial quarterly reports.

5  If Treasury identifies excess funds based on multiple factors, the amount to be reallocated from
the Grantee will equal the aggregate total. Treasury will not identify excess funds from
allocations to Indian Tribes, TDHEs or U.S. territories prior to April 2022.
6  In addition to the Monthly and Quarterly Reports, all ERA Recipients also will be required to
submit final close-out reports at the end of their ERA award performance periods. Treasury will
provide detailed requirements and instructions for those reports in 2022.

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Monthly Reports
SLT grantees must submit brief Monthly Reports for April 2021
through June 2022. These required reports include only two data
points:
1) the total number of participant households in the reporting
period, and
2) total amount of ERA funds expended in the reporting period
Quarterly Reports
All ERA grantees (SLT, all Tribe, TDHE, and the DHHL Grantees) must
submit Quarterly Reports. Each Quarterly Report covers one calendar
quarter.
Table 1 displays the reporting deadlines for ERA1 Grantees
Table 1
ERA1 Award Reports – Reporting Periods and Submission Deadlines
SLT
Grantees
Tribe, TDHE, and
the DHHL Grantees
Cycle
Calendar Quarter /
Month and Year
Reporting Period
Submission
Deadline
Required
Not Required
Interim 1
Q1
Award Date – Mar 30, 2021
May 12, 2021
Required
Required
Partial 1
Q2 Partial
Apr 1, 2021 – Jun 30, 2021
Aug 6, 2021
Required
Not Required
Monthly 1
April Monthly
Apr 1-30, 2021
May 15, 2021
Required
Not Required
Monthly 2
May Monthly
May 1-31, 2021
Jun 15, 2021
Required
Not Required
Monthly 3
Jun Monthly
Jun 1-30, 2021
Jul 15, 2021
Required
Not Required
Monthly 4
Jul Monthly
Jul 1 – Jul 31, 2021
Aug 16, 2021
Required
Not Required
Monthly 5
Aug Monthly
Aug 1 – Aug 31, 2021
Sep 15, 2021
Required
Not Required
Monthly 6
Sep Monthly
Sep 1 – 30, 2021
Oct 15, 2021
Required
Not Required
Monthly 7
Oct Monthly
Oct 1 – 31, 2021
Nov 15, 2021
Required
Not Required
Monthly 8
Nov Monthly
Nov 1 – 31, 2021
Dec 15, 2021
Required
Not Required
Monthly 9
Dec Monthly
Dec 1 – 31, 2021
Jan 17, 2022
Required
Not Required
Monthly 10
Jan Monthly
Jan 1 – 31, 2022
Feb 15, 2022
Required
Not Required
Monthly 11
Feb Monthly
Feb 1 – 28, 2022
Mar 15, 2022
Required
Not Required
Monthly 12
Mar Monthly
Mar 1 – 30, 2022
Apr 15, 2022
Required
Not Required
Monthly 13
April Monthly
Apr 1 – 30, 2022
May 15, 2022
Required
Not Required
Monthly 14
May Monthly
May 1 – 31, 2022
Jun 15, 2022
Required
Not Required
Monthly 15
Jun Monthly
Jun 1 – 30, 2022
July, 15, 2022
Required
Required
1
Q1 2021
Award Date – Mar 30, 2021
Oct 29, 2021
Required
Required
2
Q2 2021
Apr 1, 2021 – Jun 30, 2021
Oct 29, 2021
Required
Required
3
Q3 2021
Jul 1, 2021 – Sep 30, 2021
Oct 29, 2021
Required
Required
4
Q4 2021
Oct 1, 2021 – Dec 31, 2021
Feb 1, 2022
Required
Required
5
Q1 2022
Jan 1, 2022 – Mar 31, 2022
Apr 15, 2022
Required
Required
6
Q2 2022
Apr 1, 2022 – Jun 30, 2022
Jul 15, 2022
Required
Required
7
Q3 2022
Jul 1, 2022 – Sep 30, 2022
Oct 17, 2022
Required
Required
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Final Report
TBD

Source: ERA Reporting Guidance: ERA-Reporting-Guidance (treasury.gov)

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Quarterly Reporting Guidance
The ERA Reporting Guidance provides in-depth instructions for
complying with quarterly reporting requirements.7
The required Quarterly reports consist of the following eight
components, each of which correspond with a tab in the ERA
quarterly reporting form as shown on Treasury’s portal:
1. Recipient Profile
2. Project Overview
3. Subrecipients, Contractors, and Beneficiaries
4. Recipient Subawards, Contracts, and Direct Payments
5. Expenditures
6. Project Data and Participant Demographics
7. Performance and Financial Reporting
8. Report Certification and Submission
Note: Tribe, TDHE, and the DHHL grantees are required to complete
only specific sections of the Quarterly Report form, as indicated in the
Quarterly Reporting description below.8
Recipient Profile Tab:
This tab includes the following three items:
1. Verification of Grantee Details
2. Official Points of Contacts
3. Registration with System for Award Management System
(SAM.gov)
Project Overview Tab:
All grantees must use this tab to report details about the subject ERA
Project including:
– Recipient (Grantee) Project ID
– Name of the Subject ERA Project
– Subject ERA1 or ERA2 Project webpage URL
– Geographic Service Area for the Subject ERA1 or ERA2 Project
– Description of the System for Prioritizing Assistance for the
Subject ERA1 or ERA2 Project
– Overall Description of the Subject ERA1 or ERA2 Project

7  Reporting Guidance and Bulk Upload Templates and Instructions will also be available in the
Portal.
8  Specific details for the Tribe, TDHE, and DHHL grantees can be found in Appendix 1 of the ERA
Reporting Guidance. ERA Report Guidance 052021 (treasury.gov)

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– Description of the Recipient’s Use of Fact-Based Proxies for
Determining Eligibility for the Subject ERA1 or ERA2 Project
Subrecipients, Contractors, and Beneficiaries Tab:9
– This tab is used for recording and reporting information about
each Subrecipient and Contractor with which the ERA grantee
collaborates to administer the ERA Project.
– The tab is also used to record required information about each
entity that received significant financial assistance from the ERA
Project.
– Each ERA1 and ERA2 grantee must report detailed information
about each subrecipient, contractor, and beneficiary entities
(other than individual tenants or unincorporated small landlords)
to which it obligated $30,000 or more of ERA funds in the
reporting period. The required information includes identifying
information such as the name, address, and other data need for
reporting to FSRS.gov and other purposes, as follows:
o Unique Entity Identifier or Tax Identification Number
o Type of Entity (select from a pick list of entity types)
o Legal Name
o POC Email
o Address
o Whether the Subrecipient or Contractor is Registered in
SAM.gov
Recipient Subawards, Contracts, and Direct Payments Tab:10
– This tab is used for recording information on the categories of
transactions including amounts of ERA funds obligated to any of
the above-mentioned Subrecipients or Contractors.
– Each ERA grantee must also report information on each
obligation (of $30,000 or more) of ERA funds that it awards or
makes via a subaward, contract, or direct payment in the
quarterly reporting period. The required information includes:
o Name of entity to which the Subaward, Contract or
Direct Payment is directed
o Subaward, Contract or Direct Payment Number (to be
provided by the ERA Recipient)

9  Specific details regarding Subrecipient, Contractors, and Beneficiaries can be found in the ERA
Reporting Guidance. ERA Report Guidance 052021 (treasury.gov). More information and examples
are found in Appendix 9 of the guidance.
10  Specific details regarding Recipient Subawards, Contracts, and Direct Payments can be found in
the ERA Reporting Guidance. ERA Report Guidance 052021 (treasury.gov). More information and
examples are found in Appendix 9 of the guidance.

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o Type of Transaction (select from a pick list of types)
o Amount obligated
o Date of obligation
o Place of Performance (address)
o Performance start and end dates
Expenditures Tab:11
– This tab is used to record all subrecipient and contractor
expenditures (payments) using the grantee’s associated
subawards and contracts and provide additional details on direct
payments to beneficiaries.
– The ERA grantee must report the following information for the
ERA grantee’s direct expenditures and all expenditures
associated with the ERA grantee’s subawards, contracts and
direct payments valued at $30,000 or more.
o Subaward, Contract, or Direct Payment number (the ERA
grantee’s internal number reported in previous screens)
o Name of Subrecipient, Contractor, or Beneficiary
receiving the Expenditure (only beneficiaries that are
businesses, corporations or non-profits receiving $30,000
or more)
o Expenditure Start and End date;
o Expenditure amount;
o Expenditure description (if Administrative Cost);
o Expenditure Category (allowed ERA Expenditure
categories are listed here):
 Financial Assistance: Rent
 Financial Assistance: Rental arrears
 Financial Assistance: Utility/home energy costs
 Financial Assistance: Utility/home energy costs
arrears
 Other housing costs related to COVID-19
 Other housing costs (ERA 2 only)
 Housing Stability Services
 Administrative Costs
– All ERA Recipients must report the total (aggregate) amount of
all obligations in amounts less than $30,000 associated with all
subawards, contracts, and direct payments recorded in the
reporting period.

11  Specific details regarding Expenditures can be found in the ERA Reporting Guidance. ERA Report
Guidance 052021 (treasury.gov). More information and examples are found in Appendix 9 of the
guidance.

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– ERA grantees must also report the total (aggregated) amounts
expended in the reporting period related to subawards,
contracts and direct payments for which the grantee had
obligated less than $30,000.
– In addition, ERA grantees must categorize and report these
aggregate obligation and expenditure amounts by combinations
of up to eight authorized ERA expenditure categories and the
three aggregate types (subawards, contracts, and direct
payments).
Project Data and Participant Demographics Tab:12
– Each ERA grantee must report performance information and
participant demographic data for the subject ERA1 or ERA2
Project over the reporting period.
– In addition, each SLT ERA grantee must also report certain data
elements by Race, Ethnicity and Gender of the participant
households’ primary applicant for assistance. See Appendix 3 of
Treasury’s guidance for details about the required demographic
categories.
Note: Tribe, TDHE, and the DHHL Recipients are not required to
report the race, gender, and ethnicity data elements.
Performance & Financial Reporting Tab:
Each ERA grantee must provide a brief narrative describing the
performance and accomplishments of the subject ERA Project over the
reporting period.
Performance Reporting
– Current Performance Narrative
o The narrative should support the performance and
demographic data submitted and must include the
following information:
 Activities implemented and notable achievements
over the calendar quarter;
 Activities planned for the next calendar quarter;
 Notable challenges and status of each challenge;
 Details on compliance/non-compliance issues and
mitigation plans;

12  Specific details regarding Project Data and Participant Demographic can be found in the ERA
Reporting Guidance. ERA Report Guidance 052021 (treasury.gov). More information about
required demographic categories can be found in Appendix 3 of the guidance.

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 Requests for additional assistance or guidance from
Treasury; and

Other information, as appropriates do not need to
repeat information provided in the Project Overview
– Effective Practices Narrative
o  Each ERA grantee may provide a brief narrative
describing the ERA grantee’s effective practices for
administering ERA programming to share with the ERA
community.
Financial Reporting
– As of Quarter 1, 2022, each ERA recipient is required to provide
financial data directly into Treasury’s portal, rather than
uploading SF-425 forms as was required through Quarter 4,
2021. Total recipient award amount will be prepopulated in the
portal. Data points from the SF-425 forms that recipients are
required to report are:
o Cumulative amount of Award Obligated as of the end of
the Reporting Period
o Cumulative amount of Award Obligated but not Expended
as of the end of the Reporting Period
o Cumulative amount of Award Expended as of the end of
the Reporting Period
o Amount of award Unobligated as of the end of the
Reporting Period
o Current Quarter Obligations
o Current Quarter Expenditures
Participant Household Payment Data (PHPDF) File
– Each SLT ERA grantee must submit a data file containing
household-level information described below for each ERA
Financial Assistance payment made to or on behalf of each
participant household during the reporting period.
– Recipients must use a Treasury template for providing the
PHPDF.
– Required PHPDF File Elements are as follows:
o Physical address of the participant household that
received the payment (not P.O. Box).
o Type of Payee to whom the payment was made (payee
types are: Tenant; Landlord or Owner; Utility/Home
Energy Service Provider; Other Housing Services and
Eligible Expenses Provider)

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o Category of ERA Financial Assistance provided
 In situations where a payment is for multiple
categories of financial assistance, please report the
predominant category for the payment;
o Amount of payment;
o Date of the payment; and
o Start and End Dates covered by the payment (as
documented in the participant household’s application /
records, as appropriate).
 In situations where the period of coverage is not
known, please provide a Start Date and leave the
End Date field blank.
Note: Tribe, TDHE, and the DHHL ERA Recipients are not required
to submit a PHPDF as part of each Quarterly Report.
Report Certification and Submission Tab:
– Treasury’s portal will require a statement that the grantee’s
authorized representative for reporting must use to certify that
the information provided is complete and accurate.
– The grantee’s designated authorized representative for reporting
will be required to e-sign this certification before final
submission of Quarterly Reports via the portal.
– Note that the certification will be the last step in the Recipients’
submission process
– In addition, to ensure that the individual currently logged-in to
Treasury’s portal is in fact authorized to certify and submit an
ERA Quarterly Report, the portal will display the name, title,
phone and email address of the currently person who is current
logged-in to the system.

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Table 2
Required Quarterly Reporting ERA Performance Measures of
SLT / Tribe, TDHE, and the DHHL Grantees

ERA Performance Measures & Required Data
SLT
Grantees
Tribe,
TDHE, and
the DHHL
Grantees
1.
Number of unique households that completed and submitted an
application for ERA assistance
X
X
2.
Number of unique households that received ERA assistance of any kind
i.
Number of unique households that received ERA assistance (#),
and
ii.
Number of unique households that received their initial ERA
assistance in the current reporting period.
X
X
3.
Number of households that received ERA assistance by type:
i.
Rent (#),
ii.
Rental arrears (#),
iii.
Utilities/home energy bills (#),
iv.
Utilities/home energy costs arrears (#), and
v.
Other expenses related to housing (#).
X
X
4.
Number of unique participant households at certain income levels
i.
Less than 30% of area median income (#),
ii.
Between 30% and 50% of area median income (#),
iii.
Between 50% and 80% of area median income (#),
iv.
Total number of grantee households whose income eligibility
was determined based on their eligibility for other federal
benefit programs (#), and
v.
Total number of grantee households whose income eligibility
was determined using a fact-based proxy (#).
X

5.
Total amount of ERA award funds paid to or for participant households
X
X
6.
Average number of months of rent or utility/home energy payments
covered for each participant household
X

7.
Housing stability services (#)
X
X
8.
Amounts approved for payment (obligated) and amounts paid
(expended) in the reporting period:
i.
Total dollar amount of ERA award funds approved (obligated) to
or for participating households,
ii.
Total amount of ERA award funds paid (expended) for
administrative expenses,
iii.
Total amount of ERA award funds approved (obligated) for
administrative expenses,
iv.
Total dollar amount of the ERA award funds paid (expended) for
housing stability services, and
v.
Total dollar amount of the ERA funds approved (obligated) for
housing stability services costs.
X
X
Source: ERA Reporting Guidance: ERA-Reporting-Guidance (treasury.gov)

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Table 3
Required Quarterly ERA Performance Measures and
 Demographic Data Breakdown of SLT Grantees

Required ERA Performance Measure
Required
Demographic
Data
1. Number of unique households that completed and submitted an application
for ERA assistance
X
2. Number of unique households that received ERA assistance of any kind
i.
Number of unique households that received ERA assistance (#),
ii.
Number of unique households that received their initial ERA, and
assistance in the current reporting period.
X
3. Number of unique households that received ERA assistance by type
i.
Rent,
ii.
Rental arrears,
iii.
Utilities/home energy bills,
iv.
Utilities/home energy bills arrears, and
v.
Other expenses related to housing.
X
4. Number of unique households at certain income levels:
i.
Less than 30% of Area Median Income,
ii.
Between 30% and 50% of Area Median Income,
iii.
Between 50% and 80% of Area Median Income,
iv.
Total number of recipient households whose income eligibility was
determined based on their eligibility for other federal benefit
programs, and
v.
Total number of recipient households whose income eligibility was
determined using a fact-based proxy.
X
5. Total amount of ERA award paid to or for participant households
X
6. Average Number of Months of Rent or Utility/Home Energy Payments
Covered for Each Participant Household
X
7. Housing Stability Services (#)

8. Amounts approved for payment (obligated) and amounts paid (expended) in
the reporting period:
i.
Total dollar amount of ERA award funds approved (obligated) to or
for participating households
ii.
Total amount of ERA award funds paid (expended) for administrative
expenses
iii.
Total amount of ERA award funds approved (obligated) for
administrative expenses
iv.
Total dollar amount of the ERA award funds paid (expended) for
housing stability services
v.
Total dollar amount of the ERA funds approved (obligated) for
housing stability services costs

Source: ERA Reporting Guidance: ERA-Reporting-Guidance (treasury.gov)

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C. Treasury OIG Emergency Rental Assistance 1 Desk Review
Overview
Purpose
The purpose of this desk review guide is to assist Treasury OIG in
performing monitoring of the grantees’ receipt, disbursement, and
uses of ERA1 funds as reported in Treasury’s ERA Portal on a
quarterly basis.
Objective
The objective of the desk review is to evaluate the selected
grantee’s documentation supporting the uses of ERA1 funds as
reported in the Portal, and assess risk of unallowable use of funds.
As part of the desk review, we will use other publicly available
information including, but not limited to, Single Audit or other State
or Local Auditor reports, to identify internal control matters that
may pose a risk to or impact the grantee’s appropriate use of ERA1
funds. The desk review may result in a site visit to the grantee 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
multiple quarters, as deemed appropriate, beginning with the first
submission (Award date - March 30, 2021) due October 29, 2021,
through the final submission due January 21, 2023.
The review methodology includes, but is not limited to, the
following:
– Review the grantee’s monthly and quarterly ERA Portal
submission(s).
– Review other audit reports (Single Audit, State or Local 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 grantee’s
uses of ERA1 funds.
– Review the National Association of State Auditors Comptrollers,
and Treasurers newsletter for issues that may pose risk or
impact the grantee’s uses of ERA1 funds.
– Review Office of Investigations, Pandemic Response
Accountability Committee (PRAC), and Office of Counsel leads
on issues that may pose risk or impact the grantee’s uses of
ERA1 funds.
– Select a judgmental sample of the grantee’s distributions to or
for participant households based on risks identified in other

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audit reports, already identified ERA Portal reporting
deficiencies, and anomalies identified by the Data Analytics
manager.
o If necessary, consult with a statistician to identify a
sampling methodology to determine the appropriate
sample size for review of the grantee’s reported
obligations and expenditures
– Obtain and evaluate the grantee’s documentation and records
used to support the quarterly submission(s).
– Interview the grantee preparer(s) and certifier as deemed
appropriate.
– Interview State or Local Auditors and other applicable oversight
agency personnel as deemed necessary.
– Conduct site visits to the grantee, as deemed necessary.
D. Desk Review Procedures
These procedures do not exclude performing additional procedures
or steps deemed necessary based on the grantee, the type of
payment, and or other matters identified during the desk review
and/or site visit.
I.
Identify a grantee for review considering the following:
a. Has the grantee exhibited difficulty in the quarterly reporting
process?
b. Has the grantee submitted one or more quarterly reports
late?
c. Has the grantee been noncompliant on one or more of its
quarterly reports?
d. Do the results of any data analytic procedures performed on
submission data identify anomalies that indicate potential
risk or inaccurate reporting?
e. Document the rationale for the selection of grantee for
review.
II.
Notify the grantee of the planned desk review.
a. Issue a notification or engagement memorandum to the
grantee’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 an initial document request list to the grantee.
i.
Include a request for non-personally identifiable
information to support the grantee’s submission to
Treasury’s ERA Portal. The grantee should identify the

17

following items with each payment made within the
PHPDF.
1. AMI indicator (<30%, 30%<50%, 50%<80%)
2. Identify if the unique participant household is
receiving financial assistance for the first time
under ERA in the applicable quarter.
3. Was this household previously enrolled in other
income-based federal benefit programs?
4. Was this household deemed categorically eligible
based on fact-based proxy?
ii.
Provide the guidance and communication given to both
potential and actual participant households.
iii.
Provide the ERA program’s policies and procedures
related to internal control functions.
1. Include specific policies and procedures to
document controls around accepting self-
attestations, categorical eligibility, fact-specific
proxies, or other flexibilities designed to ensure
ERA funds are provided to all eligible households.
2. Include specific policies and procedures on the
eligibility application appeals process.
iv.
Provide documentation (accounting system reports, raw
data counts, other records, etc.) and a brief
walkthrough (narrative explanation) to support the
amounts included in the ERA portal for the following
data elements. The supporting documentation should
include information to discern the timeframe and
parameters used to generate the report:
1.  Number of unique households that completed and
submitted an application for ERA program
assistance
2. Number of unique households that received ERA
assistance of any kind
3. Number of unique households that received the
following types of ERA assistance (where
applicable):
a. Rent (#)
b. Rental arrears (#)
c. Utilities/home energy bills (#)
d. Utilities/home energy costs arrears (#)
e. Other expenses related to housing (#)
f. Housing stability services (#)
4. Number of unique households at certain income
levels
a. Less than 30% of area median income
b. Between 30% and 50% of area median income
c. Between 50% and 80% of area median income

18

5. Total dollar amount of ERA grant funds paid by the
ERA grantee to or for participating households
6. Total dollar value of approved ERA applications that
have not yet been paid
7. Total dollar amount of ERA award funds approved
(Obligated) to or for participant households
8. Total amount of ERA award funds paid (Expended)
for administrative expenses
9. Total amount of ERA award funds approved
(Obligated) for administrative expenses
10. Total dollar amount of the ERA award funds paid
(Expended) for housing stability services
11. Total dollar amount of the ERA funds approved
(Obligated) for housing stability service costs
12. Current Quarter Obligations to Date
13. Cumulative Obligations to Date across all reporting
periods
14. Current Quarter Expenditures to Date
15. Cumulative Expenditures to Date across all
reporting periods
III.
Perform Desk Review Due Diligence
a. Review the grantee’s quarterly submission(s) in Treasury’s
ERA Portal to identify any unresolved reporting issues.
b. Review results of the grantee’s Single Audit(s) and other
audits to identify internal control deficiencies that may pose
a risk and/or impact the grantee’s quarterly reporting and
compliance with uses of ERA1 funds requirements. Single
Audit reports may be obtained from the grantee'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 grantee's administration of
ERA1 funds (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 grantee'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 grantee.
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 any of the proposed

19

actions may otherwise impact the grantee’s
management of ERA1 funds received. Also, note
the status of corrective actions.
c. Review audit reports related to the grantee that received
Federal funding from other Federal agencies.
1. Search websites to include:
• https://www.oversight.gov/
• https://www.gao.gov/
• https://www.pandemicoversight.gov/
• https://www.hud.gov/
• Other Federal awarding agencies that provided
Federal funds to the grantee (e.g., the top five
Federal awarding agencies of the grantee,
which can be collected from the Single Audit
report).
2. Search for any reports on these websites relating
to ERA1 awards to the grantee using "Emergency
Rental Assistance."
d. Review the National Association of State Auditors
Comptrollers and Treasurers newsletter to identify issues
that may impact the grantee’s use or management of ERA1
funds.
e. 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 grantee’s quarterly reporting and compliance with
uses of ERA1 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.
f. Perform data analytic procedures and/or review the results of
data analytic procedures of the grantee’s portal
submission(s) to analyze trends and identify anomalies, as
needed. For trend analyses and identifying anomalies,
consider expended and obligated amounts as well as
performance metrics and participant demographics.
IV.
Perform an analytical review of the dollar amounts of each ERA
assistance type (rent, rental arrears, utilities/home energy bills,
utilities/home energy costs to arrears, other expenses, and
housing stability services) to identify anomalies and/or outliers:
a. Reconcile the grantee-provided data to verify completeness
of data input into the Portal.
i. Compare the supporting data (reports) provided by the
grantee and the data elements identified in Section
D.II.c.iv.

20

ii. Identify whether any amounts or applications were
improperly included in the quarterly report(s) under our
review.
iii. Follow up on any differences identified and document
the grantee’s understanding of the data element
definition(s) in question.
b. Obtain data from the PHPDF and view distribution of dollar
amounts and counts by financial assistance type (see
Financial Assistance types in Section B on page 2 above), if
available. Review for anomalies.
i. Calculate or identify the following amounts for each
assistance type and payee type:
1. Average amount per type
2. Identify the high, low, and median amounts of
each financial type
3. Overall percentage when compared to total
expended dollar amounts of each financial type
4. If the cost is related to rental or utilities arrears,
calculate the average number of months of arrears
assistance that was provided by dividing the
average rental or utilities arrears amount by the
average rental or utilities amount calculated in
Section IV.b.i.1.
5. Present the number of housing participants
reported in the PHPDF by financial assistance
amount for high, low, median, and average ranges
c. Review subaward types and descriptions for ineligible uses.
d. Review administrative expenses and explanations for
ineligible uses.
e. Review the number of unique participant households and
total spending data for each zip code within the grantee’s
coverage area for anomalies.
i. Calculate the average financial assistance amount by
general area and zip code.
1. To calculate the general area average, sum the
total dollar amounts of all zip codes and divide by
the total number of participants.
2. To calculate the zip code average, divide each zip
code dollar amount by the zip code’s household
participants.
ii. Identify the high, low, and median of calculated average
amounts by zip code.
iii. Identify the count of zip codes within each range (high,
low, median, and average amounts).
iv. Compare the calculated rent and rental arrears by zip
code with the area’s 50th percentile rent data by

21

county for four bedrooms or greater (huduser.gov).
Identify possible anomalies and/or outliers.
f. Determine whether the grantee had additional funds
allocated due to a reallocation by Treasury and/or had funds
recaptured. Confirm the amount of the reallocated or
recaptured funds, if applicable.
g. Assess whether administrative and housing stability costs
limitations were exceeded when compared to allocated or
expended funds.
i. Do administrative expenditures and obligations exceed
10 percent of total ERA1 funds the grantee has
expended to date?
ii. Do administrative expenditures and obligations exceed
10 percent of total ERA1 funds Treasury provided to the
grantee (including any approved and paid reallocated
funds)?
iii. Do housing stability services expenditures and
obligations exceed 10 percent of total ERA1 funds the
grantee has expended to date?
iv. Do housing stability services expenditures and
obligations exceed 10 percent of total ERA1 funds
Treasury provided to the grantee (including any
approved and paid reallocated funds)?
V.
Select a Sample of Financial Assistance Payments for Review
a. Select a judgmental sample of distributions the grantee made
to or for participant households.
b. Based on the steps performed above, consider the following
and review for outliers and anomalies:
– Reporting issues
– Reconciliation issues
– Internal control deficiencies
– Financial assistance amounts
– Subaward descriptions and amounts
– Portal reporting deficiencies that may pose risk to and/or
impact the grantee’s ability to appropriately report uses
of ERA1 funds
o Potential Sample Categories include:
1. Rent
2. Rental Arrears
3. Utilities
4. Utilities Arrears
5. Housing Stability Expenses
6. Administrative Expenses
7. Subawards / Subrecipients expenditures
8. Housing Eligibility
i.
If deemed necessary, consult with statistician to
determine appropriate sample methodology and sample

22

selection to review obligations and expenditures for
payment types. Provide statistician with ERA Portal
extracts and other information to determine approach to
selecting sample records to review.
c. Document the sample selection to include the methodology
and/or rationale for the selection.
i.
If we consult a statistician, obtain documented sampling
methodology to support sample selections or document
the rationale for selection.
d. Send an additional data request to the grantee requesting
documentation and records for the selected sample.
VI.
Review Selected Grantee’s Documents/Records
a. Review the guidance and communication the grantee
provided to both potential and actual participant households.
b. Review the narrative describing the grantees’ plan to
prioritize assistance to households with less than 50 percent
of the area median income and assistance to households
with one or more members that have been unemployed for
at least 90 days.
c. Review participant household-related documentation, if
applicable.
i. Does the documentation sufficiently support the
eligibility of the participant household, in accordance
with the CAA, 2021, as well as Treasury and grantee
guidance?
d. Review the grantee documentation to determine the financial
assistance type(s) the household received and the dollar
amount of each, if applicable.
i. Does the documentation sufficiently support the dollar
amount of each assistance type and the total amount
provided for this household?
e. Review the supporting records for incurred housing stability
service expenses, administrative expenses, and subawards
to verify eligible expenses and amounts paid, if applicable.
i. Does the documentation sufficiently support the dollar
amount of the incurred expense type stated above and
the total amount provided for this household?
ii. Does the documentation sufficiently support the eligible
purposes for the expense type stated above in
accordance with Treasury guidance?
f. Summarize the results of the review and the types of
documents evaluated. Discuss expanding scope with
manager, Director, and Deputy Assistant Inspector General
for Audit based on the results of the review.
VII.
Financial Reporting
a. Did the grantee submit an SF-425?
i. If yes, were all required fields completed?

23

b. Did the grantee provide the four requisite data points
described under the Financial Reporting section beginning on
page 10 above and can they support the data points?
c. Mathematically verify the four data points discussed in
Section VII.b. and portal data. If differences are identified,
follow up with the grantee.
d. Mathematically verify the SF-425 reported award amounts
and portal data. If differences are identified, follow up with
the grantee.
i. Compare the Total Federal funds authorized (10.d)
amount on the SF-425 to the total amount allocated
and paid to the grantee.
ii. Compare the Federal share of expenditures (10.e.) to
the Portal reported expenditure amounts (including
previous quarter’s reported expenses, if applicable).
iii. Compare the Federal share of unliquidated obligations
(10.f.) to the Portal reported obligation amounts
(including previous quarter’s reported expenses, if
applicable).
VIII.
Site Visits
Site visits represent the highest level of grantee 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 grantee, a virtual site visit may be an
option. Among other things, on-site visits should resolve desk
review issues, allow 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 grantee’s
management officials, project personnel, or
financial/accounting staff to 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
subgrantees;
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 grantee to discuss
results and next steps.

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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
Emergency Rental Assistance Team (see attachment 1) or the
Office of Investigations.
IX.
Perform Post Desk Review/Site Visit Procedures
a. Perform follow up effort with the grantee to resolve any
variances and discrepancies identified above in our review.
b. Prepare a memorandum to notify the grantee of desk review
results. Document next steps (i.e. audit, refer to Office of
Investigations, or no other action).
c. If a site visit is conducted, prepare memorandum to notify
grantee of the site visit review results. Document next steps
(i.e. audit, refer to Office of Investigations, or no further
action).

Attachment 1
Emergency Rental Assistance
Desk Review Report Cover Sheet
Grantee:
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:_______

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