Shuttered Venue Operators Grant Post-Application Guidance (SBA, July 22, 2022)
Summary
Guidance on the Shuttered Venue Operators Grant (SVOG) program, dated July 22, 2022 and stated to be current as of that date. It says the program was established in Section 324 of the Economic Aid to Hard-Hit Small Businesses, Nonprofits and Venues Act and signed into law on Dec. 27, 2020, and that Section 5005 of the American Rescue Plan Act amended Section 324. It states that as of February 10, 2022, the SBA has issued decisions on 100% of all initial 17,637 applications. The contents cover the application and award decision process, the active grantee phase, permissible spending of award funds, closeout, monitoring and audit.
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Cite this document
“Shuttered Venue Operators Grant Post-Application Guidance (SBA, July 22, 2022).”
Original at www.sba.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2022-07-small-business-administration-sba-svog-post-application-guidan-5ae2a8d13c/
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Shuttered Venue Operators Grant
Post-Application Guidance | July 22, 2022
The Shuttered Venue Operators Grant (SVOG) program was established in Section 324 of the
Economic Aid to Hard-Hit Small Businesses, Nonprofits and Venues Act (Economic Aid Act) and
signed into law on Dec. 27, 2020, as part of H.R. 133 Consolidated Appropriations Act, 2021
(Public Law No. 116-260). Section 324 of the Economic Aid Act was amended by Section 5005 of
the American Rescue Plan Act (Public Law No. 117-2) and signed into law on March 11, 2021.
This guidance document answers common questions about the SVOG program for applicants and is
current as of July 22, 2022.
Contents
Application and Award Decision Process ..................................................................................... 2
Application Review Update and Applicant Responses .............................................................. 2
Applicant Action Items During "In Review" Stage ................................................................... 3
Other Special Circumstances .................................................................................................... 4
Post-Approval Stage ................................................................................................................. 4
Award & Disbursement Stage .................................................................................................. 6
Declined Applications .............................................................................................................. 6
Appeals, Award Amount Reconsiderations & Supplemental Awards ........................................ 7
Active Grantee Phase.................................................................................................................... 8
SVOG Active Grantee Process Overview ................................................................................. 8
Finalize Budget Action Item ..................................................................................................... 9
Communication with the SBA .................................................................................................. 9
SVOG Award Timeline and Related Notice of Award Terminology ....................................... 10
Permissible Spending of SVOG Award Funds ............................................................................ 10
Assessing Cost Eligibility and Allowability ............................................................................ 10
Demonstrating Costs Allocability ........................................................................................... 11
Maintaining Supporting Documentation and Record Retention ............................................... 11
Closeout ..................................................................................................................................... 12
Closeout Timeline .................................................................................................................. 12
SVOG Closeout Process Overview ......................................................................................... 12
Barriers to Closeout ................................................................................................................ 13
Monitoring ................................................................................................................................. 13
What is Monitoring?............................................................................................................... 13
SVOG Monitoring Process ..................................................................................................... 14
Grantee Role and Responsibilities in Monitoring Process ....................................................... 14
Monitoring Event Conclusions, Corrective Actions and Closure ............................................. 14
Audit .......................................................................................................................................... 14
What is Auditing? .................................................................................................................. 14
Audit Requirements................................................................................................................ 15
Which one: Single or Program-Specific Audit? ...................................................................... 15
Audit Reporting Requirements ............................................................................................... 16
Other SVOG Program Audit Activities................................................................................... 16
Application and Award Decision Process
Application Review Update and Applicant Responses
The SBA began processing applications in order of priority in April 2021 and issuing grant
award decisions in late May 2021.
As of February 10, 2022, the SBA has issued decisions on 100% of all initial 17,637 applications.
SVOG Applicants receive communications from the SBA via the contact information provided on
their application. Changes or updates to the contact information on file with SVOG must be made
by contacting customer service via svogrant@sba.gov or by calling 1-800-659-2955. Maintaining
up-to-date contact information for your current authorized representative is crucial, as only the
authorized representative will receive notifications about information requests and available
documents. These communications are time sensitive, so please review carefully for the applicable
deadlines.
Official SVOG communications are sent from an @sba.gov email address, typically
noresponse@sba.gov or svogrant@sba.gov. For some email applications, the email address will
show as coming from “noreply@salesforce.com; on behalf of noresponse@sba.gov.” In some
circumstances SVOG Customer Service will follow up on an email or action item via phone. These
legitimate calls are made from official SBA phone numbers, and can be verified via an email from
an @sba.gov address. To verify further, you can log in to your SBA account on the SVOG
Application Portal to view any required action items and contact svogrant@sba.gov for more
information.
The SBA provides status updates throughout the decision-making process. You may receive
email status updates for several reasons, including that your:
o award is finalized and you need to execute your pre-award documents;
o application has been reviewed and additional documentation or information is required;
o application has been reviewed and declined (see below for appeal information);
o award amount is being reconsidered and additional documentation or information is
required;
o application is eligible for appeal and additional documentation or information is
required;
o supplemental award is ready and you need to execute your pre-award documents.
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When you receive a status update from the SBA, log in to the SVOG Application Portal to
complete all required action items.
You may click the link in the email or enter https://www.svograntportal.sba.gov/s/ directly into
your browser.
After logging in, click the “Funding Request Name” to open your application.
- Status Update will appear in the top left of the page.
- Action Items are at the top right of the page.
o Click there and follow the instructions provided.
o Action Items are time sensitive, please review carefully for your applicable
deadlines.
If you have questions about completing Action Items, please contact the SBA.
For general assistance, call the Office of Disaster Assistance’s Customer Service Center:
Phone: 1-800-659-2955; Monday through Friday, 8 am to 8 pm ET
Email: svogrant@sba.gov
For in-depth assistance, contact SBA’s resource partners:
You can identify partners in your area by visiting www.sba.gov/local-assistance.
You may request to withdraw an application by emailing svogrant@sba.gov.
The request must be sent from the email address used to create the SVOG application, and must
include:
1. Subject Line: “Request to Withdraw SVOG Application”
2. Email Message:
- SVOG application number
- Email address used to create the application
- Entity name, address, and phone number
- Name of person making the request
o Request must be made by applicant or authorized representative named in the
application
- Reason the applicant is requesting to withdraw the application
Applicant Action Items During "In Review" Stage
After review and prior to approval or decline, you may need to complete an Action Item.
Possible Action Items include:
1. Technical Corrections: Your application has been reviewed, but additional information or
documentation of specific requirements is needed.
- You will receive an email advising you of the Action Item
- After logging in to the portal, you will see a checklist advising you of the additional
information or documentation to provide
- Follow the instructions provided in the portal to upload and submit the requested
information
- You have 14 days to complete this Action Item
2. 4506T: The IRS could not process your 4506T for various reasons.
- You will receive an email advising you of the Action Item
- After logging in to the portal, you will see a new 4506T checklist. You may make
corrections, if needed
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- Review and sign the document
- Follow the instructions provided in the portal to upload and submit the document
- You have 14 days to complete this Action Item
3. Do Not Pay: Your name or entity name appears on the Department of Treasury's Do Not Pay
(DNP) list. Your status must be corrected or cleared prior to Award.
- You will receive an email advising you of the Action Item
- After logging into the portal, you will see information regarding where and why your
name appears on the Do Not Pay list
- Follow the instructions provided to contact the source of your Do Not Pay status:
o Visit Do Not Pay - Privacy Program (treasury.gov),
o Scroll down to “Data Correction Process,”
o Find the row for the match source, and
o Use the Contact Information to contact the source and correct or clear your status
- In the portal, follow the instructions for notifying the SBA that you cleared or corrected
your status
- You have 30 days to clear or correct a DNP status
Other Special Circumstances
A small number of applicants may receive an email from SVOG indicating their tax
transcript was returned with “No Record Found”. If you receive such an email, follow these
instructions:
Step 1:
• Verify with the Internal Revenue Service (IRS) that your 2019 Federal Tax Return has
been received and processed.
• The IRS provides a few toll-free numbers to assist you, depending on your circumstance:
o For applicants who filed a Form 1040, call 800-829-1040, from 7 a.m. to 7 p.m.
local time,
o For applicants who filed Form 1065, 1120, or 1120-S, call 800-829-4933, from 7
a.m. to 7 p.m. local time, or
o For applicants who filed Form 990 or 990-EZ, call 877-829-5500, from 8 a.m. to
5 p.m. local time.
Step 2:
• If the IRS tells you that your tax return has been received and processed, please follow
the instructions to fill out another 4506-T and ensure that all information is correct.
• If the IRS indicates that your tax return has been received but not processed, proceed to
step 3.
Step 3:
• Contact the Taxpayer Advocate Service (TAS). The TAS is an independent organization
within the IRS designed to help if you have tax problems that you cannot resolve on
your own (Home - Taxpayer Advocate Service (irs.gov)). In the interest of helping your
tax return get processed, please contact the TAS to inquire if their services can assist
you. Additionally, you can directly request assistance at Submit a request for assistance -
Taxpayer Advocate Service (irs.gov).
Post-Approval Stage
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After approval and prior to disbursement, you may need to complete an Action Item. Possible
Action Items include:
1. Notice of Award (SBA Form 1222 / NOA): Your application is approved, and your Award
amount is finalized. You must sign and return your Notice of Award prior to disbursement.
- You will receive an email advising you of the Action Item
- After logging in to the portal, you will see a checklist advising you of the additional
information or documentation to provide
- Follow the instructions provided in the portal to upload and submit the requested
information
- You have 7 days to complete this Action Item
- Additional notes on Form 1222:
o The “Project Period” on the Form 1222 is the granting period for issuing an
SVOG NOA —this does not correspond with the allowable time period to incur
costs
o The “Budget Period” indicates the time you are permitted to spend the grant
award
o You may spend the grant on costs incurred between March 1, 2020, and
December 31, 2021 (or June 30, 2022, if you receive a supplemental award)
2. Special Conditions (SBA Form 1222 Addendum): Your application is approved, and your
Award amount is finalized. You must fulfill, or agree to fulfill, any listed Special Conditions
prior to disbursement.
- You will receive an email advising you of the Action Item
- After logging in to the portal, you will see your Notice of Award and any Addendum
identifying Special Condition documents that must be uploaded at the same time as the
signed Notice of Award
- Follow the instructions provided in the portal to upload and submit the requested
information
- You have 7 days to complete this Action Item
- Additional notes on Form 1222 Addendum:
o You may be asked for a copy of your 2020 federal tax filings. Most applicants
were required to submit 2019 federal tax filings in the initial application. For
fiscal year filers, the Form 1222 Addendum requirement is to provide a copy of
their most recent tax year filings.
o You may have seen a condition on the Addendum and/or the Portal which read
“You are required to upload a final 425 and Supporting Documents within 15
days of receipt of your final disbursement.”
Update - In subsequent Form 1222 updates, the SBA corrected the Addendum
language to clarify the SF-425 submission and closeout timelines. Specifically,
the SBA asks grantees to submit the SF-425 document within 15 days after
expending all SVOG award funds. The maximum allowable time is 120 days
after the end of their Budget Period to prepare closeout materials and initiate the
closeout process. As outlined in the Closeout section below, a grantee initiates
closeout of their SVOG award when they respond to the Expense Report action
item.
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o If you have less than 500 employees or more than 10,000 employees, you do not
need to initial line 10 of the additional program assurances.
3. Budget Revision: Your application is approved, but your possible Award amount is higher
than the Proposed Budget you provided on your application. You must revise your budget to
receive the additional funds or confirm you wish to receive the smaller grant award.
- You will receive an email advising you of the Action Item
- After logging in to the portal, you will see a checklist advising you of the additional
information or documentation to provide
- Follow the instructions provided in the portal to upload and submit the requested
information
- You have 14 days to complete this Action Item
Award & Disbursement Stage
You must return your properly executed NOA and complete any Special Conditions prior to
disbursement.
After the SBA receives the completed NOA, you become an Awardee/Grantee and the SBA
schedules a disbursement of funds.
You must have an active SAM entity registration to receive funds. You can check your SAM
registration status by:
1. Going to https://www.sam.gov
2. Selecting Check Registration Status in the Register Your Entity section on the home page
(or selecting Check Registration from the footer on every page)
3. Selecting the Sign In button
4. Entering your Unique Entity ID (with or without an EFT Indicator) or your CAGE Code
(if applicable)
5. Selecting Search to check your entity registration status
Remember, new SAM.gov entity registrations take up to ten (10) business days to process and can
take 30+ business days during periods of peak volume.
A small number of Grantees may see a “rejected” status or “pending” status for a
disbursement in the Application Portal. If you see such a status:
- In most cases, the SBA can correct this disbursement issue on your behalf. The SBA
checks for such issues every day and will re-issue the disbursement shortly.
- In some cases, you may need to take action to correct the issue. If this is the case, the
SBA will reach out to you with specific instructions.
Declined Applications
If your application was declined, you will receive an email advising you of this status and have the
option to submit an appeal.
Most declined applications did not meet the eligibility criteria established in the SVOG statute.
Please see the SVOG Eligibility Matrix for additional information.
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Appeals, Award Amount Reconsiderations & Supplemental Awards
After receiving the decision on your initial SVOG application, you will have three options for a next
step: appeal, award amount reconsideration, or supplemental award.
Appeal
If your application was declined, you will receive an email and an update in your SVOG portal
indicating you are eligible to submit an appeal. The initial appeal window lasts two weeks, during
which time funding will be preserved. There is no guarantee that funding will remain available for
applicants who appeal after the close of the initial two-week window.
If you choose to appeal, you will be asked to review the Eligibility Matrix and upload a signed
statement indicating your grounds for appeal, as well as any supporting documents. A submitted
appeal is final. If your appeal is approved but you receive an Award amount at least $100 less than
the Adjusted Proposed Grant Amount on your application, you will have the opportunity to request
an award amount reconsideration. There is no secondary appeal process once an appeal is declined.
Award Amount Reconsideration
If you receive an award amount at least $100 less than the Adjusted Proposed Grant Amount on
your initial application, you will receive an email indicating that you are eligible to apply for award
amount reconsideration. Award amount reconsideration may adjust the amount of your initial
award, so this process must be completed prior to evaluation for a Supplemental Award.
The initial reconsideration window will last two weeks, during which time funding will be
preserved. There is no guarantee that funding will remain available for applicants who request
reconsideration after the close of the initial two-week window.
If you choose to request an award amount reconsideration, you will have to upload supporting
documents to validate your earned revenue. Submitted award amount reconsideration requests are
final.
Supplemental Award
If you receive an initial SVOG, you will receive an action item to update your 2021 earned revenue,
which you must update to be considered for a Supplemental Award. To do so, log in to the portal
and update through this action item.
Those eligible for a supplemental award based on the SVOG statute and earned revenue will be
invited to request a supplemental award. If you qualify for a supplemental award based on the
required revenue loss and your initial award amount reached the maximum of $10 million, you can
qualify for a no-cost supplemental award to extend the active grantee phase.
Eligibility is determined based on whether Q1 or Q2 2021 earned revenues were no more than 30
percent of Q1 or Q2 2019 earned revenues. For applicants that did not begin operations prior to
2019, Q1 2020 will be used as a comparison to Q1 2021. Supplemental award amounts, as defined
in statute, will be 50% of your initial award (adding back any PPP subtracted from the initial
award), not to exceed the balance of the initial grant and $10 million for a single entity.
Reconsideration 2.0 – Final Award Amount Reconsideration
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Once Supplemental eligibility has been processed, Grantees will be invited to request one final
opportunity to apply for Reconsideration of their Award Amount. Grantees will receive an email
notification of a new Action Item available through their applicant portal inviting them to ‘Apply
for Reconsideration of your SVOG Award Amount’. This Action Item allows grantee to correct
any potential errors on their initial SVOG application which may have decreased their expected
award amount.
Grantees should accept the Reconsideration 2.0 invitation if there were any mistakes included in
their application which may have decreased their Award Calculation, including: Errors in Earned
Revenue figures for 2019, 2020, or 2021 and incorrect Date Business Began Operation. Date
Business Began Operation should reflect the date the applying entity began earning revenue, which
may be after the date the entity was incorporated.
Completing this Action Item will allow you to review and revise the information you have provided
to SBA. Revisions may result in a change to your initial award amount, and by extension, any
potential supplemental award amount. Revisions to the Funding Request made though the
Reconsideration 2.0 process will be final.
The reconsideration window will last two weeks, during which time, funding will be preserved.
Grantees may request that expired or declined Recon 2.0 Action Items be reissued. Action Items
that have been completed cannot be reissued or amended. There is no guarantee that funding will
remain available for applicants who request reconsideration after the close of the initial two-week
window.
Reconsideration 2.0 is not available for declined applicants.
Active Grantee Phase
SVOG Active Grantee Process Overview
The SVOG Active Grantee Phase begins on the date of initial NOA issuance and lasts until the
Budget Period “through” date (Form 1222 Box 5) unless a grantee completes the closeout
process before the Budget Period concludes. This phase involves identifying eligible and
allowable expenditures and spending grant award funds until the closeout process is initiated.
The SVOG program is implementing a multi-step active grantee phase through award
closeout. Guidance and the portal capabilities for the SVOG active grantee phase are in
development. Below is a process diagram of the active grantee phase and how it is integrated with
the closeout phase. The SBA expects the capabilities and phases below to be finalized and
available to grantees at the beginning of December 2021.
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Active Grantee Phase
Grantee receives an
A Funding Request Grantee receives a
“Begin Closeout:
“Finalize Budget” action SVOG Program
has been fully Expense Report” action
item in their portal. Reviews and Approves
considered for all This must be completed
item in their portal and it
the Finalized Budget includes the due date
possible awards within 14 days
Grantee receives a
“Complete Closeout: SF-
SVOG Program 425” action item in their SVOG Program SVOG Program
Reviews and Approves portal. This must be Reviews and Approves closes out the
Expense Report completed SF-425 grant
within 14 days
Closeout Phase
Finalize Budget Action Item
After your SVOG application has been considered for all possible awards, you will receive an
email to respond to a “Finalize Budget” Action Item. For most, this will be the final budget
revision before reporting expenditures and initiating closeout.
Finalize Budget Action Item: Your total award is finalized. You must submit a final budget
to the SVOG program to confirm how you are allocating all awarded funds to allowable
budget categories.
- You will receive an email advising you of a new, available action item
- After logging in to the portal, you will have the option to check a box to keep your
existing budget or fill out a revised budget which accounts for additional awards since
your last budget proposal
- Follow the instructions provided in the portal to respond to the certification and
attestation statements and submit the finalized budget
- You will have 14 days from the date of receipt to submit the Finalize Budget Action
Item
Communication with the SBA
Through the course of the active grantee phase process, the SBA continues to be available to you as
a resource for program support and technical assistance.
You should submit active grantee phase and closeout questions to svogrant@sba.gov. This
inbox is monitored for specific topics that require SVOG program staff to provide the correct
answers. Additionally, trending topics may be incorporated into public guidance.
You can also receive assistance through the following resources:
For general assistance, call the Office of Disaster Assistance’s Customer Service Center:
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Phone: 1-800- 659-2955, Monday through Friday, 8 am to 8 pm ET
For in-depth assistance, contact SBA’s resource partners:
You can identify partners in your area by visiting www.sba.gov/local-assistance.
General grantee communication may also be provided via GovDelivery updates from sba-
oda@updates.sba.gov.
SVOG Award Timeline and Related Notice of Award Terminology
In the SVOG program statute, grantees were given specific time periods to incur eligible costs
and to charge costs to the SVOG award. A cost is considered to have been incurred on the exact
date the financial transaction happened, which may be prior to when it was paid for. The guidance
in this section outlines the key terms on the NOA (Form 1222) used to establish award timeline
parameters and provides helpful guidance on implementing and tracking incurrence of eligible and
allowable costs.
Important Terminology in Notice of Award (Form 1222)
1. Project Period (Form 1222 Box 4) - The complete length of time for which funds are
available for award making.
“From” - Date Initial Phase SVOG Award was issued by the SBA.
“Through” - End date for incurring eligible and allowable costs. Grantee may incur costs
from March 1, 2020, to the date in this box.
Helpful Information
- Transactions relating to payroll are eligible costs if work was performed
between March 1, 2020, and the “Through” date in this box.
- Transactions relating to the procurement of goods or services are eligible costs
if the date of the binding written commitment falls between March 1, 2020,
and the “Through” date in this box.
2. Budget Period (Form 1222 Box 5) – The complete length of time you have to spend
award funds on eligible and allowable costs. You can spend award funds to cover
eligible and allowable costs incurred from March 1, 2020, to the “Through” date in Box
4 in your most recently issued NOA.
“From” - First date to spend award funds.
“Through” - Final date to spend award funds.
Helpful Information
- The final date of the Budget Period (“Through” date in Form 1222 Box 5) is
the end of the grant term and you should start preparing for closeout if you
have not already begun the closeout process.
Permissible Spending of SVOG Award Funds
Assessing Cost Eligibility and Allowability
Grantees must spend SVOG funds on costs which are eligible and allowable.
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Misuse of SVOG funds can result in disciplinary action, such as monetary penalties.
“Eligible Costs” are costs incurred between March 1, 2020, and the Project Period “Through” date
on Form 1222 at Box 4. Form 1222 is also referred to as the NOA. If you have received more than
one NOA, rely on the most recently issued NOA.
Costs incurred outside the eligible cost period may not be paid for or reimbursed with SVOG funds
(see SVOG program FAQ Document – Question 118).
“Allowable Costs” are costs deemed legally permissible based on the authorizing language in the
program’s statute and Title 2 of the Code of Federal Regulations, Part 200 (2 C.F.R. 200).
For clarifications on allowable use of funds visit SVOG program FAQ Document.
The SVOG program provides a budget form with allowable cost categories; if a cost incurred
does not align with an allowable budget category, it is likely that cost is not an allowable cost.
Use your Final Budget response as a guide during the SVOG active phase and to direct the
allowable use of SVOG funds.
In addition to the laws and interpretations provided by the SBA, when assessing whether a
cost is allowable, you should also consider:
- Is the cost reasonable and necessary for my business?
- Do sound business practices support the cost?
- Does the cost clearly fit into an approved cost category in the grant award?
Demonstrating Costs Allocability
Allocability means eligible and allowable costs must be properly aligned to cost categories of
an SVOG award. Grantees should maintain supporting documentation that shows the grant
funds used align with an allowable budget category. Then in the Expense Report Action Item
(Closeout Process), the total amount of funds expended across each allowable budget category
should equal the supported allocable cost amount.
You can split a cost between multiple funding sources. When splitting a cost, you must clearly
demonstrate in your records how the cost was divided and how the SVOG allocable cost were
connected to an allowable budget category and charged to the SVOG award.
Maintaining Supporting Documentation and Record Retention
The law requires you to maintain employment records for 4 years following the receipt of
funds (this is the “From” date in Form 1222 Box 5), and to maintain all other records
documenting compliance and eligibility for the SVOG Program for 3 years following the
receipt of funds. These retained records should clearly depict how SVOG award funds were spent
on eligible and allowable costs. The sum of costs documented should align with the total funds
spent as recorded in the closeout process Expense Report Action Item and Complete Closeout: SF-
425 Action Item.
You must maintain all documents associated with SVOG award fund expenditures. Some
examples include, but are not limited to:
o Employment Records: The SVOG statute requires grantees to maintain employment records
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for 4 years following the receipt of funds (this is the “From” date in Form 1222 Box 5)
o Contracted Services: procurement process (as applicable), executed contract, invoices,
payments, evidence of implemented contract deliverables, evidence of, and explanations for,
partial charges to SVOG award funds, and any files documenting reporting or monitoring
efforts.
o Personnel Costs (staff time): employment contracts stating terms and conditions of
employment, timesheets for time worked and charged, and evidence and explanations for
how much personnel time was partially or fully reimbursed with SVOG award funds.
o Equipment and Supplies (below procurement threshold): paid invoice or receipt clearly
displaying the vendor, date purchased, the item(s) purchased, and cost amount charged to
the SVOG award.
Closeout
Closeout Timeline
You initiate your SVOG closeout by responding to the Expense Report Action Item in the
SVOG portal. You are encouraged to initiate closeout by responding to the action item soon after
expending all grant award funds, as the award work and financial recordkeeping will be fresh and it
should make for an easier closeout. The guidance to pursue timely closeout is articulated in the
NOA addendum and SVOG Program FAQ Document.
You are required to respond to the Expense Report Action Item and initiate the closeout
process no later than 120 days after the end of your Budget Period (“Through” date in Form
1222 Box 5). The overarching closeout process expectations for the SBA and grantee are outlined in
2 CFR 200.344 – Closeout.
SVOG Closeout Process Overview
The SVOG program is implementing a multi-step grant award closeout. Guidance and the
portal capabilities for the SVOG Closeout Process are in development. Below is a process diagram
of the closeout phase and how it integrated with the active grantee phase. As mentioned above, the
SBA expects the capabilities and phases below to be finalized and available to grantees at the
beginning of December 2021.
Active Grantee Phase
Grantee receives an
Grantee receives a
“Begin Closeout:
A Funding Request has “Finalize Budget” action SVOG Program
Expense Report” action
been fully considered item in their portal. Reviews and Approves item in their portal and it
for all possible awards This must be completed the Finalized Budget includes the due date
within 14 days
Grantee receives a
“Complete Closeout: SF-
1. SVOG Program 425” action item in their 2. SVOG Program 3. SVOG Program
Reviews and Approves portal. This must be Reviews and Approves closes out the
Expense Report completed SF-425 grant
within 14 days
Closeout Phase 12 | P a g e
Phase 1 Grantee Responsibilities
Expense Report - Assemble supporting documentation
Action Item - Organize expenditures by budget category
- If applicable, prepare property inventory and create request for property
disposition instructions
- Respond to any follow-up questions from the SBA
COMPLETE - Phase 1 is complete when the SBA approves the Expense Report Action Item
Phase 2 Grantee Responsibilities
Complete - Confirm SF-425 has the correct data
Closeout: SF-425 - Respond to the survey
Action Item (plus - If applicable, upload supporting documents for property disposition
survey and - If applicable, complete and document repayment of unused SVOG award
supporting money
documents) - Respond to any follow-up questions from the SBA
COMPLETE - Phase 2 is complete when the SBA approves the Complete Closeout: SF-425 Action
Item
Phase 3 Grantee Responsibilities
Grant Award - Receive grant award closure notification and (if necessary) provide any
Closure final response
COMPLETE – Phase 3 is complete when the grantee receives notification of grant award closeout
and (if necessary) completes a final response to the SBA
Barriers to Closeout
The SBA cannot complete grant award closeout if any of the following conditions are present:
- Open monitoring event (please see below for additional information),
- Unresolved audit issues, or
- An unresolved grantee question or response, examples include grantee change in ownership
request, grantee failure to respond to action item, and grantee failure to repay unused grant
funds.
Monitoring
What is Monitoring?
Monitoring is an SBA-led review of grantees to determine whether award funds were used for
eligible and allowable purposes. All federal grants include monitoring and all SVOG grantees
should be prepared for monitoring. The SBA will use a risk-based monitoring system to select the
grantees to monitor. SBA will notify you if you have been selected for monitoring.
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SVOG Monitoring Process
The majority of monitoring will be done remotely by SVOG staff, but some grantees may
receive on-site monitoring. The monitoring process, including review and responses, will be
managed through the SVOG Portal and SBA staff will follow up directly by email or phone as
needed. SBA will assign a specific SVOG program staffer to each monitoring event and this
individual will serve as the primary reviewer and point of contact.
If selected for monitoring, you will receive a notification in the portal and an email from the
SBA notifying you that an action item is pending response. The action item will provide the
monitoring scope and details regarding the information and documentation you must provide.
Most monitoring events will start while the grantee is actively implementing its award, so you
are encouraged to continue spending award funds unless otherwise notified by the SBA. The
SBA may begin a monitoring review once the closeout phase has been initiated or after a grant
award has been closed out.
Grantee Role and Responsibilities in Monitoring Process
You are expected to respond timely and completely to monitoring notifications and follow-up
requests. If you have questions about the monitoring scope or requested documents, please reach
out to your SVOG point of contact.
Eligible and allowable expenses can only be determined based on the documents and
responses you provide to the SBA. If you fail to respond timely or completely, then the SBA will
make its eligible and allowable use determination based on the responses and documents provided.
Monitoring Event Conclusions, Corrective Actions and Closure
You will be contacted by email once a monitoring review is complete. In this email, the SBA
will provide a summary of its monitoring review and the resulting monitoring conclusions. The
monitoring conclusions will encompass SBA’s evaluation of eligible and allowable use of funds,
plus, if needed, a list of corrective actions and the delivery of technical assistance guidance to
improve the grantee active award phase.
If the SBA concludes SVOG funds are being used for eligible and allowable purposes, then the
SBA will close the monitoring event. No further response will be required from you on this
monitoring event.
If the SBA concludes SVOG funds are not being used for eligible and allowable purposes, then
the SBA will provide a list of corrective actions. You will need to resolve all corrective actions
with follow-up responses before the monitoring event can be closed. Corrective action examples
include updated spending policies, improved financial controls, or repayment of ineligible or
unallowable costs. If a cost is found to be ineligible or unallowable, the SBA will work with you to
reallocate the funds to an eligible and allowable cost that has yet to be reimbursed or request the
funds be returned. If you do not comply with the Agency’s request for returned funds, the SBA
may take other measures to recoup the funds, up to and including litigation and noting a grantee’s
noncompliance in FAPIIS.
Audit
What is Auditing?
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The SVOG Auditing phase captures instances in which you may be required to undergo a third-
party audit of your organization and/or operation of your SVO grant.
Audit Requirements
The audit requirements differ between non-Federal entities (includes nonprofit organizations,
institution of higher education, state, local government, and Indian tribes) and for-profit
entities.
For non-Federal entities, if you expend more than $750,000 in Federal funds (across all
Federal sources including SVOG funds) within your fiscal year, you will be required to
complete a third-party audit. If you received a PPP loan, it does not count against the $750,000
expenditure threshold. SVOG grantees that do not surpass the $750,000 expenditure threshold
within their own fiscal year will not be responsible for conducting an audit under these
requirements.
Non-Federal entities must complete an audit in line with the requirements outlined in the
Uniform Guidance Subpart F (2 CFR 200. 500 – 521), which requires a single audit or
program-specific audit.
If you are a for-profit entity that received and recognized an SVOG award in the amount (or
combined amount if initial and supplemental awards were recognized in the same fiscal year)
of $750,000 or more during the entity’s fiscal year, you will select from one of four audit
options to meet the audit requirement:
1. Single audit consistent with Uniform Guidance Subpart F (2 CFR 200. 500 – 521);
2. Program specific audit consistent with Uniform Guidance Subpart F (2 CFR 200. 500 –
521);
3. An audit of the entity’s financial statements, along with the auditor’s opinion on the
financial statements performed under Generally Accepted Auditing Standards (GAAS)
issued by the American Institute of Public Accountants; OR
4. A compliance examination engagement performed by a practitioner in accordance with the
Government Accountability Office (GAO) Government Auditing Standards..
a. Such engagements are further conducted in accordance with the American Institute
of Certified Public Accountants (AICPA) Statements on Standards for Attestation
Engagements (SSAEs).
b. Such engagements include a practitioner opining directly on compliance with SVOG
requirements.
More information on audit requirements relevant to for-profit entities can be found in the
document Audit and Attestation Requirements for For-Profit Recipients.
Which one: Single or Program-Specific Audit?
If you only receive SVOG as your source of Federal funding, you can elect to have a program
specific audit (instead of a single audit as outlined in 2 CFR 200.501(c)). Under a program-
specific audit, SVOG grantees will contract with an independent auditor to conduct a review of your
active SVOG award phase including a review of SVOG program compliance, your internal controls,
and your financial system and recordkeeping.
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If you are an entity with broader Federal funding support from multiple sources, you must
conduct a single audit as opposed to a program-specific audit. The structure of a single audit
allows for an auditor’s review to focus initially on the financial and management controls the
organization has in place to administer multiple funding streams and ensure that cost allocation is
clearly tracked. Then based on the size of the funding portfolio and distribution of funding sources,
the auditor will test program specific records for adherence with the entity’s policies and procedures
and compliance with the Federal program rules and requirements. The prominence of auditing
specific to the SVOG award fund management and usage in the single audit will vary based on the
proportionate share of SVOG funds expended versus other Federal funding expended within the
entity’s own fiscal year.
The Office of Management and Budget released the 2022 Compliance Supplement on May 12,
2022. The supplement includes a section dedicated to the SVOG program and can be accessed
at: 2022 Compliance Supplement (whitehouse.gov). This compliance supplement will serve as a
tool to direct compliance auditors in their audit reviews of SVOG awards. Although the compliance
supplement is being released for 2022, SBA encourages compliance auditors and SVOG awardees
to utilize the supplement as guidance for 2021 as well.
Expenses related to a single or program specific audit or a financial audit conducted to meet
this audit requirement are an allowable use of SVOG award funds, see SVOG Program FAQ
Document – Question 156.
Audit Reporting Requirements
If you are a non-Federal entity required to complete a single or program specific audit, you
must upload the reporting package to the Federal Audit Clearinghouse (FAC) as detailed in 2
CFR 200.512. The composition of the FAC reporting package is described in 2 CFR 200.512(c). If
the auditor makes findings in their report, then the grantee is expected to resolve the findings with a
corrective action plan and submit the corrective action plan in its FAC reporting package. A non-
Federal entity will also be required to submit their audit reporting package directly to SBA.
For-profit entities required to complete a financial audit must provide a copy of their audit
report to SBA, including all audit package components, findings, and corrective action plan as
applicable.
SBA will utilize an Audit Reporting Action Item to collect audit report packages from non-
Federal and for-profit entities. Both entity types have nine months from the end of their fiscal
year to submit their audit report packages.
Other SVOG Program Audit Activities
As an SVOG grantee, you may be engaged in other ongoing SBA or SVOG audit activities.
The SVOG program is experiencing ongoing review from other Federal partners, including SBA’s
Office of Inspector General, the Government Accountability Office, and the Pandemic Response
Accountability Committee, which could impact SVOG grantees. Also, the SBA is required to
conduct internal control reviews of SVOG award decisions and applicant documentation, which
could lead to additional follow-up with SVOG grantees. The SBA will provide communication to
grantees if further follow-up or actions are expected.
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