Full text
COVID-19
U.S. Territory
Experiences
Could Inform
Future Federal
Relief
Report to Congressional Committees
September 2023
GAO-23-106050
United States Government Accountability Office
United States Government Accountability Office
Highlights of GAO-23-106050, a report to
congressional committees.
September 2023
COVID-19
U.S. Territory Experiences Could Inform Future
Federal Relief
What GAO Found
Federal agencies allocated more than $32 billion in COVID-19 relief funding to
the five permanently inhabited U.S. territories—American Samoa, the
Commonwealth of the Northern Mariana Islands, Guam, Puerto Rico, and the
U.S. Virgin Islands. This relief funding was provided through more than 100 new
and existing federal programs across 16 federal agencies. Territory government
officials told GAO that this funding helped them meet key priorities, including the
public health response to COVID-19, improvements to health care infrastructure
and access, replacement of lost revenue for continued government operations,
and infrastructure development.
COVID-19 Relief Funding Allocated to U.S. Territory Governments as of May 2023
Total allocations (in billions)
American Samoa
$1.3
Commonwealth of the Northern Mariana Islands
$1.9
Guam
$2.7
Puerto Rico
$24.8
U.S. Virgin Islands
$1.5
Total
$32.1
Source: GAO analysis of appropriation and federal agency allocation data. | GAO-23-106050
Notes: Total allocations include COVID-19 relief funding for which U.S. territory government
agencies were the recipient. Allocation data were collected between May 2022 and May 2023, prior
to the rescission of unobligated funds in a number of COVID-19 relief programs under the Fiscal
Responsibility Act of 2023 in June 2023. See Pub. L. No. 118-5, div. B, tit. I, 137 Stat. 10, 23-30
(2023). Allocations do not sum to total due to rounding. COVID-19 relief funding awarded directly to
local governments is not included.
Territory government officials told us they faced challenges administering
selected COVID-19 relief programs. These included having sufficient
administrative capacity, determining allowable uses for funding, spending funds
within allotted time frames, and managing reporting requirements.
Based on the experiences of the territorial governments administering COVID-19
relief funding and federal agency actions to mitigate certain challenges, GAO
identified four themes that could inform future federal relief to U.S. territories:
•
Leveraging pre-existing programs. In contrast to newly created programs,
territory officials reported experiencing fewer challenges administering and
reporting on pre-existing federal programs that received additional funding.
•
Technical assistance. Territory officials faced fewer challenges
implementing programs where there was strong coordination and
communication between the federal agency and the territory regarding
program requirements and reporting.
•
Funding flexibilities. Territory governments used COVID-19 relief funding
with flexible or broad allowable uses to meet needs that might not be
allowable under other federal programs, and worked with federal agencies to
modify allowable uses and funding time frames to meet territory needs.
•
Immediately available funding. Territory officials said funding that was
immediately available, rather than provided as reimbursement, enabled them
to better plan, schedule, and expend funds for allowable uses.
View GAO-23-106050. For more information,
contact Jeff Arkin at 202-512-6806 or
arkinj@gao.gov
Why GAO Did This Study
The federal government has provided
more than $4 trillion to help the nation
respond to and recover from the
COVID-19 pandemic. A portion of
those funds went to U.S. territories
through various federal programs.
The CARES Act includes a provision
for GAO to conduct monitoring and
oversight related to the COVID-19
pandemic. This report examines (1)
how much funding was allocated to the
territories and how territories reported
those funds were used; (2) territories’
experiences administering COVID-19
relief funding; and (3) how selected
federal agencies helped territories
administer the funding and what
themes can inform future federal relief
to the territories.
GAO reviewed the six COVID-19 relief
laws enacted in 2020 and 2021,
federal agency allocation data, and
spending data from USAspending.gov.
GAO reviewed program
documentation, reports to federal
agencies on the use of funds, and
applicable Office of Inspector General
reports. GAO also interviewed federal
and territory agency officials about
selected COVID-19 relief programs.
These selected programs were those
that (1) were implemented by federal
agencies that administered the largest
COVID-19 relief programs for Tribes,
states, localities, and territories; and
(2) allocated more than $100 million to
the U.S. territories.
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GAO-23-106050 COVID-19
Letter
1
Background
3
Federal Agencies Provided More Than $32 Billion in COVID-19
Relief Funding to U.S. Territories through More Than 100
Programs
9
Territory Agencies Identified Challenges in Administering Selected
COVID-19 Relief Programs
24
Federal Actions Helped Mitigate Challenges and Could Inform
Future Federal Funding
35
Agency Comments
39
Appendix I
Objectives, Scope, and Methodology
43
Appendix II
COVID-19 Relief Funding Allocated to U.S. Territories by Program
as of May 2023
51
Appendix III
Comments from Government of Puerto Rico
61
Appendix IV
Comments from the Office of the Governor, American Samoa
Government
63
Appendix V
GAO Contact and Staff Acknowledgments
68
Tables
Table 1: COVID-19 Relief Funding Allocated to U.S. Territory
Governments as of May 2023
10
Table 2: COVID-19 Relief Allocations as of May 2023 and
USAspending.gov Data on Obligations and
Disbursements to U.S. Territory Governments by Federal
Agency as of February 28, 2023
12
Table 3: COVID-19 Relief Programs that Allocated More Than
$100 Million to U.S. Territory Governments, as of
May 2023
14
Contents
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GAO-23-106050 COVID-19
Table 4: Selected COVID-19 Relief Programs
49
Table 5: Funding Allocated to U.S. Territories for Department of
Agriculture COVID-19 Programs
51
Table 6: Funding Allocated to U.S. Territories for Department of
Commerce COVID-19 Programs
52
Table 7: Funding Allocated to U.S. Territories for Department of
Education COVID-19 Programs
52
Table 8: Funding Allocated to U.S. Territories for U.S. Election
Assistance Commission COVID-19 Programs
53
Table 9: Funding Allocated to U.S. Territories for Environmental
Protection Agency COVID-19 Programs
53
Table 10: Funding Allocated to U.S. Territories for Federal
Communications Commission COVID-19 Programs
53
Table 11: Funding Allocated to U.S. Territories for Department of
Health and Human Services COVID-19 Programs
54
Table 12: Funding Allocated to U.S. Territories for Department of
Homeland Security COVID-19 Programs
57
Table 13: Funding Allocated to U.S. Territories for Department of
Housing and Urban Development COVID-19 Programs
57
Table 14: Funding Allocated to U.S. Territories for Department of
the Interior COVID-19 Programs
58
Table 15: Funding Allocated to U.S. Territories for Institute of
Museum and Library Services COVID-19 Programs
58
Table 16: Funding Allocated to U.S. Territories for Department of
Justice COVID-19 Programs
58
Table 17: Funding Allocated to U.S. Territories for Department of
Labor COVID-19 Programs
59
Table 18: Funding Allocated to U.S. Territories for National
Endowment for the Arts COVID-19 Programs
60
Table 19: Funding Allocated to U.S. Territories for Department of
Transportation COVID-19 Programs
60
Table 20: Funding Allocated to U.S. Territories for Department of
the Treasury COVID-19 Programs
60
Figures
Figure 1: Geographic Locations of U.S. Territories
4
Figure 2: Timeline of COVID-19 Relief Laws
6
Figure 3: Federal Agencies with the Largest Allocations of COVID-
19 Relief Funds to U.S. Territory Governments
17
Figure 4: Conceptual Plan for New Guam Medical Campus
20
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GAO-23-106050 COVID-19
Figure 5: Screenshot of Guam’s Publicly Available American
Rescue Plan Allocations, June 2023
23
Figure 6: Levels of Government that Received CSLFRF Funding
in Each Territory
31
Abbreviations
ARPA
American Rescue Plan Act
CDC
Centers for Disease Control and Prevention
CFDA
Catalog of Federal Domestic Assistance
CNMI
Commonwealth of the Northern Mariana Islands
CSLFRF
Coronavirus State and Local Fiscal Recovery Funds
DEFC
Disaster Emergency Fund Code
DOT
Department of Transportation
FABS
Financial Assistance Broker Submission
FAQ
Frequently Asked Question
FCC
Federal Communications Commission
FEMA
Federal Emergency Management Agency
HHS
Department of Health and Human Services
IIJA
Infrastructure Investment and Jobs Act
OIG
Office of Inspector General
OMB
Office of Management and Budget
TAS
Treasury Account Symbol
UTF
Unemployment Trust Fund
USDA
U.S. Department of Agriculture
USVI
U.S. Virgin Islands
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GAO-23-106050 COVID-19
441 G St. N.W.
Washington, DC 20548
September 19, 2023
Congressional Committees
The federal government has provided more than $4 trillion to help the
nation respond to and recover from the COVID-19 pandemic.1 A portion
of those funds went to U.S. territories through various federal programs,
including increased funding for healthcare, education, and transportation
infrastructure as well as new funding with broad allowable uses such as
the Coronavirus Relief Fund and Coronavirus State and Local Fiscal
Recovery Funds. Territories were tasked with quickly using this funding to
combat the pandemic while also planning for and administering funding
that would be available for several years.
The CARES Act includes a provision for us to conduct monitoring and
oversight of the use of funds made available to prepare for, respond to,
and recover from the pandemic.2 This report focuses on COVID-19 relief
provided to the five permanently inhabited U.S. territories—American
Samoa, the Commonwealth of the Northern Mariana Islands (CNMI),
Guam, Puerto Rico, and the U.S. Virgin Islands (USVI). We reviewed (1)
how much funding was allocated to the territories and how territories
reported that those funds were used; (2) territories’ experiences
administering COVID-19 relief funding; and (3) how selected federal
agencies helped territories administer COVID-19 relief funding and what
themes can inform future federal relief to the territories.
To describe the funding provided to the territories and how those funds
were used, we reviewed the six COVID-19 relief laws enacted in 2020
1This is the cumulative amount of funding provided in the six COVID-19 relief laws as of
April 30, 2023. This amount does not reflect any changes resulting from the Fiscal
Responsibility Act of 2023, which rescinded unobligated funds in a number of COVID-19
relief programs. See Pub. L. No. 118-5, div. B, tit. I, 137 Stat. 10, 23-30 (2023). The six
COVID-19 relief laws are the American Rescue Plan Act of 2021 (ARPA), Pub. L. No.
117-2, 135 Stat. 4 (2021); Consolidated Appropriations Act, 2021, Pub. L. No. 116-260,
div. M and N, 134 Stat. 1182 (2020); Paycheck Protection Program and Health Care
Enhancement Act, Pub. L. No. 116-139, 134 Stat. 620 (2020); CARES Act, Pub. L. No.
116-136, 134 Stat. 281 (2020); Families First Coronavirus Response Act, Pub. L. No. 116-
127, 134 Stat. 178 (2020); and the Coronavirus Preparedness and Response
Supplemental Appropriations Act, 2020, Pub. L. No. 116-123, 134 Stat. 146 (2020).
2Pub. L. No. 116-136, § 19010(b), 134 Stat. 281, 580 (2020). More information on our
COVID-19-related work is available at https://www.gao.gov/coronavirus.
Letter
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GAO-23-106050 COVID-19
and 2021. We also identified appropriation and allocation amounts for the
programs for which territory governments were eligible recipients.3 We
then reviewed data on obligations and disbursements of COVID-19 relief
funding programs from USAspending.gov and confirmed any
inconsistencies with the appropriate federal agencies. We found the data
on USAspending.gov to be generally reliable for presenting publicly
available information on obligations and disbursements of COVID-19
relief funding.4 We also reviewed reports by the territories to federal
agencies and the public to identify major uses of COVID-19 relief funding,
as well as applicable Office of Inspector General reports. We interviewed
territory agency officials about their priorities in using federal COVID-19
relief funding. We did not evaluate whether territory uses of federal
COVID-19 relief funding complied with allowable uses.
To describe the experiences of territories administering COVID-19 relief
funding, we reviewed documentation provided by territory governments
and interviewed territory government officials about their experiences
administering 11 selected programs administered by five federal
3Appropriations are budget authority granted to federal agencies through legislation to
incur obligations and to make payments from the Treasury for specified purposes. An
allocation is a further subdivision of an apportionment, which divides amounts available for
obligation by specific time periods, activities, projects, objects, or a combination thereof. In
this report, we are specifically referring to funds available for obligation that federal
agencies set aside for use by each territory. GAO, A Glossary of Terms Used in the
Federal Budget Process, GAO-05-734SP (Washington, D.C.: September 2005).
The Fiscal Responsibility Act of 2023, which rescinded unobligated funds in a number of
COVID relief programs, was enacted subsequent to our analysis. See Pub. L. No. 118-5,
div. B, tit. I, 137 Stat. 10, 23-30 (2023). According to preliminary estimates from the
Congressional Budget Office, the Fiscal Responsibility Act of 2023 would result in the
rescission of $27.1 billion of budget authority for unobligated funds under 87 COVID relief
programs. See letter from Phillip L. Swagel, Director, Congressional Budget Office, to
Hon. Kevin McCarthy, Speaker of the House of the House of Representatives, re: CBO’s
Estimate of the Budgetary Effects of H.R. 3746, the Fiscal Responsibility Act of 2023 (May
30, 2023).
4USAspending.gov is the official source for spending data for the U.S. government, and
has features that allow for tracking of COVID-19 spending. In prior work we identified
limitations in the reliability of USAspending.gov data for some agencies or programs.
Throughout this report, we note these limitations wherever USAspending.gov data are
used. See Federal Spending Transparency: OIGs Identified a Variety of Issues with the
Quality of Agencies’ Data Submissions, GAO-22-105427 (Washington, D.C.: July 12,
2022); and Federal Spending Transparency: Opportunities Exist to Further Improve the
Information Available on USAspending.gov, GAO-22-104702 (Washington, D.C.: Nov. 8,
2021).
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GAO-23-106050 COVID-19
agencies.5 We conducted site visits with territory agency officials in
Puerto Rico and USVI, and video conferences with officials in American
Samoa, CNMI, and Guam.
To describe actions taken by the five selected federal agencies to
address any needs of the territories in their administration of COVID-19
relief funding and themes that may inform future federal funding to the
territories, we reviewed program guidance provided by federal agencies
and interviewed federal agency officials that administered the selected
programs. We also interviewed territory agency officials. To identify and
describe themes that could inform future federal relief programs, we
conducted a content analysis of interview statements from federal agency
and territory government agency officials. For more detailed information
about our objectives, scope, and methodology, see appendix I.
We conducted this performance audit from May 2022 to September 2023
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
The United States has five permanently inhabited territories: American
Samoa, CNMI, Guam, Puerto Rico, and USVI. Three territories–American
Samoa, CNMI, and Guam—are located in the Pacific Ocean. Puerto Rico
and USVI are located in the Caribbean.
5We selected programs that allocated more than $100 million to the territories and were
implemented by federal agencies that administered the largest COVID-19 relief programs
for Tribes, states, localities, and territories—those that received direct appropriations for
more than $10 billion exclusively or primarily for Tribes, states, the District of Columbia,
localities, and U.S. territories—in at least one of the six COVID-19 relief laws. For the list
of selected programs, see table 4 in appendix I.
Background
U.S. Territories
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GAO-23-106050 COVID-19
Figure 1: Geographic Locations of U.S. Territories
The five permanently inhabited U.S. territories have elected governors,
territorial legislatures, and nonvoting members in the U.S. House of
Representatives.
American Samoa. American Samoa, with a population of 49,710 in 2020,
lies about 2,600 miles southwest of Hawaii. It consists of seven islands
covering a land area of 76 square miles. Most of American Samoa’s
economic activity—primarily tuna canning—and government operations
take place on the territory’s main island, Tutuila. Tourism is limited by the
island’s remote location and lack of tourist-related facilities.
CNMI. CNMI, with a population of 47,329 in 2020, lies just north of Guam
and about 3,300 miles from Hawaii. Part of the Mariana Islands
Archipelago, the territory is a chain of 14 islands with a total land area of
183 square miles. CNMI’s population resides primarily on the island of
Saipan, with additional residents on the islands of Rota and Tinian.
CNMI’s economy depends on tourism.
Guam. Guam, with a population of 153,836 in 2020, is located about 50
miles south of the southernmost island of CNMI, 3,700 miles west of
Hawaii. It has a total land area of 212 square miles. Guam has long been
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GAO-23-106050 COVID-19
a strategic location for the U.S. military, and Guam’s economy depends
largely on U.S. military spending and tourism.6
Puerto Rico. Puerto Rico, with a population of 3.3 million in 2021, is the
largest U.S. territory. It consists of a main island and several smaller
ones—a total of 3,425 square miles. Puerto Rico’s economy is mainly
driven by manufacturing goods, such as pharmaceuticals, textiles,
petrochemicals, and electronics. The service industry, including the
finance, insurance, and tourism sectors, is also a key contributor to the
economy.
USVI. USVI, with a population of 87,146 in 2020, is composed of three
main islands—St. Croix, St. John, and St. Thomas—and many other
surrounding islands, comprising 134 square miles. Most of the population
of USVI resides on St. Thomas and St. Croix. Tourism is the territory’s
leading industry, accounting for about 60 percent of USVI’s gross
domestic product, according to USVI officials.
Territory governments—like other Tribal, state, and local governments—
experienced economic loss resulting from the COVID-19 pandemic. To
limit social contact and slow the spread of the virus, nearly all U.S. states
and territories implemented policies that restricted certain economic
activities—in particular closures of nonessential businesses. Businesses
that depend on in-person contact for providing goods and services were
severely affected, including businesses in the leisure, tourism, and
hospitality sector. Several of the territories rely heavily on revenue and
jobs in the hospitality and tourism industry for their respective economies.
6More than 21,000 service members and families currently reside on Navy and Air Force
bases on Guam. With the opening of a new U.S. Marine Corps base, 15,000 more military
personnel and dependents are expected to move to Guam over the next few years.
Federal COVID-19 Relief
and Oversight
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GAO-23-106050 COVID-19
Further, natural disasters, such as hurricanes, have limited economic
growth in these territories in recent years.7 Natural disasters have hit
each of the five territories in the last 6 years.8
The COVID-19 relief laws enacted between March 2020 and March 2021
provided more than $1 trillion to federal agencies to provide assistance
related to the pandemic to Tribes, states, the District of Columbia,
localities, and U.S. territories, through existing and newly created
programs and funds.9 See figure 2 for a timeline of federal funding
provided through the COVID-19 relief laws.
Figure 2: Timeline of COVID-19 Relief Laws
Note: In June 2023, the Fiscal Responsibility Act of 2023 rescinded some of the funding provided
through the COVID-19 relief laws.
7We review the territories’ public debt every 2 years, including trends in public debt, trends
in revenue and expenses, and risk factors that may affect each territory’s ability to repay
public debt. See U.S. Territories: Public Debt Outlook - 2023 Update, GAO-23-106045
(Washington, D.C.: June 29, 2023).
8American Samoa was hit with Tropical Storm Gita in February 2018. CNMI was hit by
Typhoon Mawar in May 2023, Typhoons Hagibis and Bualoi in October 2019, Super
Typhoon Yutu in October 2018, and Typhoon Mangkhut in September 2018. Guam was
also hit by Typhoons Mawar and Mangkhut as well as Typhoon Wutip in February 2019.
Puerto Rico was hit with Hurricane Fiona in September 2022, Tropical Storms Laura and
Isaias in summer 2020, earthquakes in 2019 and 2020, and Tropical Storm Dorian in
August 2019. USVI was hit with Hurricane Dorian in August 2019.
9In June 2023, some of these funds were rescinded under the Fiscal Responsibility Act of
2023. According to preliminary estimates from the Congressional Budget Office, this
would result in the rescission of $27.1 billion of budget authority for unobligated funds
under 87 COVID-19 relief programs. See letter from Phillip L. Swagel, Director,
Congressional Budget Office, to Hon. Kevin McCarthy, Speaker of the House of the
House of Representatives, re: CBO’s Estimate of the Budgetary Effects of H.R. 3746, the
Fiscal Responsibility Act of 2023 (May 30, 2023).
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Various Offices of Inspector General (OIG) have published reports
regarding the territories’ uses of COVID-19 relief funding. For example,
the Department of the Treasury OIG sent a letter to American Samoa
regarding specific uses of Coronavirus Relief Funds. In addition, the U.S.
Election Assistance Commission OIG published a report on the use of
CARES Act awards for unsupported direct costs by the CNMI
Commonwealth Election Commissions.10 The Department of the Interior
OIG also sent management advisory letters to the auditing bodies of the
three Pacific territories offering guidance and support in overseeing
territories’ uses of COVID-19 relief funds.11
American Samoa, CNMI, Guam, and USVI also submit single audit
reports. The Single Audit Act requires that nonfederal entities that expend
$750,000 or more in federal awards during their fiscal year must have a
single audit or program-specific audit conducted for that year and
submitted to the Federal Audit Clearinghouse within the earlier of 30
calendar days after receipt of the auditor’s report(s) or 9 months after the
end of the audit period.12 Puerto Rico releases audited financial
10Office of the Inspector General U.S. Election Assistance Commission, Audit of the Help
America Vote Act Grants Awarded to the Commonwealth of the Northern Mariana Islands,
G22MP0005-23-04 (Feb. 24, 2023.); and Office of the Inspector General Department of
the Treasury, American Samoa Uses of Coronavirus Relief Fund Payment, OIG-CA-20-
023 (July 14, 2020).
11Office of Inspector General U.S. Department of the Interior, Management Advisory –
Coronavirus Aid, Relief and Economic Security Act Funds Awarded to American Samoa,
Report No. 2020-WR-041-A (October 2020); Management Advisory – Coronavirus Aid,
Relief and Economic Security Act Funds Awarded to the Commonwealth of the Northern
Mariana Islands, Report No 2020-WR-041-B (October 2020); and Management Advisory –
Coronavirus Aid, Relief and Economic Security Act Funds Awarded to Guam, Report No
2020-WR-041-D (October 2020).
12The Single Audit Act requires all nonfederal entities that expend $750,000 or more in
federal awards, including grants and other assistance, during their fiscal year to conduct
either a single audit or program-specific audit of the entity’s financial statements and
federal awards (or program-specific audit, in limited circumstances) by an independent
auditor in accordance with generally accepted government auditing standards. See Pub.
L. No. 98-502, 98 Stat. 2327 (1984), codified as amended at 31 U.S.C. §§ 7501-7506.
Under the Office of Management and Budget’s Uniform Guidance, the threshold requiring
a single audit or program-specific audit is expenditure of $750,000 or more. 2 C.F.R. §
200.501(a). Single audit reports provide information about the reliability of the financial
statements and of the schedule of grant expenditures; adequacy of internal controls over
financial reporting; compliance with relevant grant laws and regulations, and awards terms
for each major program; and findings and questioned amounts. 2 C.F.R. § 200.515. Single
audits are an important mechanism that federal agencies use to help ensure the
accountability of federal funds.
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statements for the government and its component units in accordance
with generally accepted accounting principles.
Some territories have been delayed in releasing their audited financial
statements. As of June 2023, the territories most recent audited financial
statements are from 2021 (American Samoa, Guam, Puerto Rico), 2020
(CNMI) and 2019 (USVI). We have previously reported that some of the
territories have long-standing challenges with financial accountability,
including late submission of annual audited financial statements.13
Additionally, auditors identified material weaknesses in internal controls
over financial reporting and compliance for several of the territories.14 For
example, auditors identified material weaknesses with CNMI’s
compliance with the Coronavirus Relief Fund, Education Stabilization
Funds, and the Federal Emergency Management Agency Public
Assistance Disaster Relief Funds.15 Similarly, auditors identified material
weaknesses with Guam’s compliance with the Coronavirus Relief Fund,
Emergency Rental Assistance Programs, and the Coronavirus State and
Local Fiscal Recovery Funds.16 CNMI and Guam government officials
responded to the auditors’ findings in their corrective action plans.
13See GAO-23-106045.
14A material weakness in internal control over financial reporting is a deficiency, or a
combination of deficiencies, in internal control such that there is a reasonable possibility
that a material misstatement of the entity’s financial statements will not be prevented, or
detected and corrected on a timely basis. A material weakness in internal control over
compliance is a deficiency, or a combination of deficiencies, in internal control over
compliance such that there is a reasonable possibility that material noncompliance with a
type of compliance requirement of a federal program will not be prevented or detected and
corrected on a timely basis.
15Commonwealth of the Northern Mariana Islands, Independent Auditors’ Reports on
Internal Control and on Compliance Year Ended September 30, 2020 (Jan. 30, 2023).
16Government of Guam, Single Audit Reports Year Ended September 30, 2021 (July 13,
2022).
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Federal agencies allocated more than $32 billion of their COVID-19 relief
appropriations to territory governments.17 As shown in table 1, total
allocations as of May 2023 for each territory ranged from $1.3 billion
(American Samoa) to $24.8 billion (Puerto Rico).18 For some territories—
American Samoa and CNMI—allocations exceeded their pre-pandemic
(fiscal year 2019) gross domestic product.
17Our analysis of allocations included any COVID-19 relief funding that federal agencies
allocated or obligated directly to territory-level government agencies. This includes select
instances where funding initially designated for units of local government were ultimately
disbursed to the territory-level government. We did not include funding that federal
agencies directly allocated or obligated to other types of recipients, such as individuals,
private businesses, public institutions of higher education, or municipalities. In some
cases, allocations were determined by statute. See e.g., 42 U.S.C. § 802(b)(1); Pub. L.
No. 116-260, div. M, tit. IV, 134 Stat. 1182, 1941-42 (2020). This number was calculated
prior to the rescissions of unobligated funds for a number of COVID-19 relief programs
under the Fiscal Responsibility Act of 2023 in June 2023.
For funds control purposes, an allocation is a further subdivision of an apportionment. See
GAO-05-734SP.
18American Samoa, Guam, and USVI received all COVID-19 relief funding designated to
governments at the territory level. CNMI and Puerto Rico have governments at both the
territory and local levels. COVID-19 relief funding awarded at local levels in CNMI and
Puerto Rico are not included.
Federal Agencies
Provided More Than
$32 Billion in COVID-
19 Relief Funding to
U.S. Territories
through More Than
100 Programs
Federal Agencies
Allocated More Than $32
Billion in COVID-19 Relief
Funding to U.S. Territory
Governments
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GAO-23-106050 COVID-19
Table 1: COVID-19 Relief Funding Allocated to U.S. Territory Governments as of May 2023
Total allocations
(in billions)
Allocations per capita
(in thousands)
Allocations as a percentage
of territory’s fiscal year 2019
gross domestic product
American Samoa
$1.3
$25.6
197%
Commonwealth of the Northern
Mariana Islands
$1.9
$39.1
157%
Guam
$2.7
$17.6
42%
Puerto Rico
$24.8
$7.5
22%
U.S. Virgin Islands
$1.5
$17.2
36%
Total
$32.1
Source: GAO analysis of appropriation and federal agency allocation data. | GAO-23-106050
Notes: Allocation data were collected from May 2022 through May 2023, prior to the rescission of
unobligated funds in a number of COVID-19 relief programs under the Fiscal Responsibility Act of
2023 in June 2023. See Pub. L. No. 118-5, div. B, tit. I, 137 Stat. 10, 23-30 (2023). Total allocations
include COVID-19 relief funding for which U.S. territory government agencies were the recipient. The
Commonwealth of the Northern Mariana Islands and Puerto Rico have governments at both the
territory and local levels. COVID-19 relief funding awarded at local levels is not included in the table.
Allocations do not sum to total due to rounding. Allocations per capita are calculated using Census
Bureau population information from the 2020 Census. Allocations as a percentage of each territory’s
gross domestic product are based on the fiscal year 2019 gross domestic product reported in the
most recent report by the Bureau of Economic Analysis for each territory.
Federal agencies report to USAspending.gov the amount of COVID-19
relief funding they awarded and disbursed to the territories.19 According to
USAspending.gov data, 16 federal agencies provided COVID-19 relief
funding to U.S. territories. As of February 28, 2023—the cutoff date for
this review —these 16 federal agencies had awarded, or obligated, 89
percent of the more than $32 billion in COVID-19 relief allocations to
territory governments that we identified.20 See table 2. At that time,
19In past work, we identified that the quality of data on USAspending.gov varies by federal
agency. We chose to use it in this report, because USAspending.gov data are widely
available to the public and we determined these data were sufficiently reliable for our
purposes. See GAO-22-105427 and GAO-22-104702.
20With the passage of the Fiscal Responsibility Act of 2023 in June 2023, the total
allocation amount may be reduced. In turn, the obligation percentages may increase. An
obligation generally refers to a definite commitment that creates a legal liability of the
government for the payment of goods and services ordered or received, or a legal duty on
the part of the United States that could mature into a legal liability by virtue of actions on
the part of the other party beyond the control of the United States. Payment may be made
immediately or in the future. An agency incurs an obligation, for example, when it places
an order, signs a contract, awards a grant, purchases a service, or takes other actions that
require the government to make payments to the public or from one government account
to another. See GAO-05-734SP.
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according to USAspending.gov and agency data from the Departments of
Homeland Security and Labor:
•
Eight agencies had obligated all or almost all of the funding allocated
to territory governments.
•
Five agencies had obligated between 81 percent and 88 percent of
the funding allocated to territory governments.
•
Two agencies—the Departments of Transportation (DOT) and
Housing and Urban Development—had obligated 45 percent and 64
percent, respectively, of the funding allocated to territory
governments.
•
The Federal Communications Commission (FCC) had obligated 3
percent, according to USAspending.gov. However, for agency-specific
reasons, our analysis of USAspending.gov data underreports their
COVID-19 obligations. FCC officials explained that, for its Emergency
Connectivity Fund program, territory agencies could ask FCC to pay
broadband providers directly. Obligations not made directly to territory
governments were not captured in our analysis of obligations and
disbursements.
According to USAspending.gov, as of February 28, 2023, federal
agencies had outlayed, or disbursed, more than $23.6 billion to territory
governments.21 Based on data from USAspending.gov, two agencies—
the Department of Agriculture (USDA) and Treasury—appear to have
disbursed more funds than they obligated. Officials at both agencies
attributed this discrepancy, in part, to inconsistencies in the use of
Disaster Emergency Fund Codes (DEFC).22 According to USDA officials,
USDA did not label all of its COVID-19 relief funding with the appropriate
21Disbursements are the issuance of checks, payment of cash, or electronic transfer of
funds made to liquidate a federal obligation. “Disbursement” is used interchangeably with
the term “outlay.” See GAO-05-734SP.
22DEFCs are used to track the spending of funding for disasters and emergencies such as
COVID-19. Each code links to one or more laws that authorized the funding. The Office of
Management and Budget (OMB) establishes a new DEFC value for each enacted
appropriation with disaster or emergency funding. The corresponding title for each DEFC
value generally identifies the associated public law number(s) and whether the funding is
disaster or emergency. In some cases, OMB also establishes DEFC values for
nonemergency funding. OMB required agencies to use DEFCs to track their COVID-19
supplemental funding on USAspending.gov beginning in June 2020. See OMB, M-20-21,
Memorandum For the Heads of Departments and Agencies: Implementation Guidance for
Supplemental Funding Provided in Response to the Coronavirus Disease 2019 (COVID-
19) (Washington, D.C.: Apr. 10, 2020).
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GAO-23-106050 COVID-19
DEFC. So, USAspending.gov shows less COVID-19 relief funding
obligated than what USDA actually obligated. USDA resolved this labeling
problem moving forward, including when reporting disbursements. As a
result, for USDA, disbursements exceed obligations on
USAspending.gov. Similarly, Treasury officials told us that Treasury
underreported COVID-19 related obligations in USAspending.gov in part
because of inconsistencies in the use of DEFC.23 Treasury officials told
us they are taking steps to correct their data on USAspending.gov.
Table 2: COVID-19 Relief Allocations as of May 2023 and USAspending.gov Data on Obligations and Disbursements to U.S.
Territory Governments by Federal Agency as of February 28, 2023
Federal Agency
Total Allocations
to Territory
Governments
(in millions)
Total Federal
Obligations to
Territory
Governments
(in millions)
Total Federal
Disbursements to
Territory
Governments
(in millions)
Department of Laborb
$10,907
$9,617e
$9,521
Department of the Treasurya
$8,605d
$7,345f
$7,867f
Department of Educationa
$6,408d
$6,408
$1,950
Department of Agricultureb
$3,061d
$2,624g
$3,122
Department of Health and Human Servicesa
$1,621d
$1,600
$702.7
Department of Transportationa
$486.7d
$220.3
$80.7
Department of Homeland Securityb
$460.5
$451h
$233.6
Department of Housing and Urban Developmenta
$298.5d
$191.7
$91.9
Federal Communications Commissionb
$122.3
$3.1i
$1.8
Department of Commercea
$57.9d
$47.1
$0
Department of the Interiora
$33
$33
$20.5
Department of Justicea
$18.4
$18.4
$12.9
Election Assistance Commissionb
$6.3
$6.3
$6.2
Institute of Museum and Library Servicesc
$3.7d
$3.7
$0.8
National Endowment for the Artsa
$2.5d
$2.1
$1
Environmental Protection Agencya
$0.2
$0.2
$0
Total
$32,093
$28,571
$23,612
Source: GAO analysis of agency and USAspending.gov data. | GAO-23-106050
Notes: U.S. Territories refers to American Samoa, the Commonwealth of the Northern Mariana
Islands (CNMI), Guam, Puerto Rico, and the U.S. Virgin Islands (USVI). Allocation data were
compiled from publicly available documents on individual agency websites or provided by agency
23Treasury officials also said that USAspending.gov does not currently reflect prior year
adjustments and disbursements that were returned to Treasury as a result of
reallocations, which contributes to underreported COVID-19 obligations and over reported
disbursements.
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GAO-23-106050 COVID-19
officials between May 2022 and May 2023, prior to the rescission of unobligated funds in a number of
COVID-19 relief programs under the Fiscal Responsibility Act of 2023 in June 2023. We downloaded
award obligation and disbursement data through February 28, 2023 from USAspending.gov on April
20, 2023. Agencies report the data on USAspending.gov. We and agencies’ Offices of Inspector
General (OIG) determined that reliability of data submitted to USAspending.gov varied among federal
agencies. See GAO-22-105427 and GAO-22-104702. The amounts presented here include funding
for which territory government agencies were the recipient. Funding awarded to other recipients
including individuals, private businesses, public institutions of higher education, and municipalities is
excluded.
aOIGs found these federal agencies to have reasonably reliable USAspending.gov data.
bOIGs found these federal agencies to have less reliable USAspending.gov data. These five federal
agencies account for $12.7 billion of the total obligations and $12.9 billion of the total disbursements
to all five territory governments. Disbursements exceed obligations because this group contains the
Department of Agriculture (USDA), which mislabeled certain COVID-19 award obligations.
cThe Institute of Museum and Library Services does not have an Office of Inspector General
evaluation of its USAspending.gov data.
dIn June 2023, the Fiscal Responsibility Act of 2023 provided for rescissions of unobligated funds for
programs administered by this agency. Therefore, the ultimate allocation amounts may be reduced.
See Pub. L. No. 118-5, div. B, tit. I, 137 Stat. 10, 23-30 (2023).
eObligation and disbursement data for pandemic unemployment benefits paid to Puerto Rico and
USVI were provided by the Department of Labor in June 2023. According to Labor officials,
USAspending.gov data we collected includes only the grant funding made to the territories, including
both benefits for American Samoa, CNMI, and Guam and administrative funding for each of the
territories. It does not include funding provided through the Treasury managed Unemployment Trust
Fund (UTF). UTF funding is provided to USAspending.gov as a national aggregate amount.
According to Labor officials, since Puerto Rico and USVI have existing Unemployment Compensation
programs and access benefits funding through the UTF, UTF funds received by these two territories
are reported as part of the national aggregate amounts to USAspending.gov due to the site’s
reporting requirements. Labor was able to provide the information at the individual territory level for
our use here.
fDepartment of the Treasury officials told us that three limitations affected their obligations and
disbursement data at the award level on the USAspending.gov COVID-19 pages. First, prior-year
adjustments to the Coronavirus State and Local Fiscal Recovery Funds, Emergency Rental
Assistance 2, and the Homeowner Assistance Fund are not reflected in obligation data at the award
level on the USAspending.gov COVID-19 pages. Second, there were some inconsistencies in the use
of Disaster Emergency Fund Codes that led to an underreporting of COVID-19 obligations in
USAspending.gov. Third, disbursements on USAspending.gov do not reflect funds that were returned
to Treasury as a result of reallocation on or before September 21, 2022. Therefore, disbursements
may appear higher than they should.
gUSDA officials told us that the department labeled some COVID-19 award obligations with the wrong
Disaster Emergency Fund Code. Therefore, those obligations do not appear as COVID-19 funding on
USAspending.gov. Therefore, on USAspending.gov, disbursements appear higher than obligations
for USDA. USDA corrected this error for awards moving forward. USDA provided allocation data in
April 2023. When asked why disbursement data through February 2023 exceeded these allocations,
USDA officials told us that allocations occur at a single point in time and may have been updated to
allow for further obligations and disbursements on multiyear funds.
hThe Public Assistance Disaster Relief Funds component of this total came from reports provided by
the Federal Emergency Management Agency as of March 2023, rather than USAspending.gov.
Funding provided to the Disaster Relief Fund is generally not specific to individual disasters.
Therefore, Treasury’s methodology for determining COVID-19-related obligations and disbursements
on USAspending.gov does not capture obligations and disbursements for the COVID-19 response
based on funding other than what was provided in the COVID-19 relief laws. Further,
USAspending.gov’s methodology includes all obligations and disbursements based on funding in the
COVID-19 relief laws, including those for other disasters.
iOfficials at the Federal Communications Commission (FCC) explained that, for their Emergency
Connectivity Fund program, territory agencies could either request the funds as reimbursement after
paying broadband providers, or ask FCC to pay broadband providers directly. Payments FCC made
to broadband providers directly on behalf of territory government agencies were not captured in our
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GAO-23-106050 COVID-19
analysis of obligations and disbursements. Therefore, obligations and disbursements as reported
here do not reflect all obligations and disbursements FCC made on behalf of territory governments.
The FCC noted that over 98 percent of the FCC related funds that it allocated to U.S. territories came
from the Emergency Connectivity Fund Program. Pursuant to public information provided by the FCC
using the Universal Service Administrative Company’s Emergency Connectivity Fund Program Open
Data Tool, which includes obligations and disbursements made directly to service providers on behalf
of territory governments, the FCC has obligated approximately 69 percent and disbursed
approximately 16.6 percent of these Emergency Connectivity Funds through its accepted invoicing
processes.
The timing and availability of funds varies across COVID-19 relief
programs. For example, Coronavirus Relief Funds were no longer
available for obligation or disbursement by territory governments after
December 31, 2021. However, funding for the State Small Business
Credit Initiative may be available for disbursement until as late as
September 2030.
Territory governments received COVID-19 relief funding from 16 federal
agencies and more than 100 federal programs. As shown in table 3, 15
federal programs allocated more than $100 million to territory
governments, as of May 2023.24 In total, these 15 programs accounted for
96 percent of the total amount of COVID-19 relief funding allocated to
territory governments. For the full list of federal programs and allocations
to each territory’s government, see appendix II.
Table 3: COVID-19 Relief Programs that Allocated More Than $100 Million to U.S. Territory Governments, as of May 2023
Programs and funds
Description
Amount Allocated to
Territory Governments
(millions)
Unemployment Insurancea
(Department of Labor)
COVID-19 legislation created federally funded temporary
unemployment insurance programs that expanded benefit
eligibility and enhanced benefits for eligible workers who
became unemployed through no fault of their own during the
pandemic.
$10,899
Education Stabilization Fund
(Department of Education)
This program, comprised of multiple subprograms, generally
provides formula grants to states and U.S. territories for
education-related needs to address the effect of the COVID-19
pandemic.
$6,369b
Coronavirus State and Local Fiscal
Recovery Funds
(Department of the Treasury)
These funds provide payments to Tribal governments, states,
the District of Columbia, U.S. territories, and localities to
mitigate the fiscal effects stemming from the COVID-19
pandemic.
$4,728
24This amount does not account for any subsequent rescissions provided under the Fiscal
Responsibility Act of 2023.
Territories Received
COVID-19 Relief Funding
through More Than 100
Federal Programs
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GAO-23-106050 COVID-19
Programs and funds
Description
Amount Allocated to
Territory Governments
(millions)
Coronavirus Relief Fund
(Department of the Treasury)
This fund provides payments to Tribal governments, states,
the District of Columbia, localities with more than 500,000
residents, and U.S. territories to help with necessary
expenditures incurred due to the COVID-19 pandemic.
$2,505
Nutrition Assistance
(Department of Agriculture)
This program provides block grants to American Samoa, the
Commonwealth of the Northern Mariana Islands, and Puerto
Rico to provide food assistance to low-income households.
$1,914
Pandemic Electronic Benefit Transfer
(Department of Agriculture)
This program provides benefits, administered by states and
U.S. territories, for purchasing food for households with
children who would have received free or reduced-price school
meals—if not for COVID-19-related school closures—as well
as for households with children in child care.
$1,052
Emergency Rental Assistance Programs
(Department of the Treasury)
These programs (Emergency Rental Assistance 1 and 2)
provide assistance to states, the District of Columbia, U.S.
territories, and localities with more than 200,000 residents to
assist eligible households with rent, utilities and home energy
costs, other expenses related to housing, and housing stability
services. Emergency Rental Assistance 1 funds were also
available to Tribes or their Tribally Designated Housing Entities
and the Department of Hawaiian Home Lands. Emergency
Rental Assistance 2 also provides assistance to cover the
costs for other affordable rental housing and eviction
prevention activities for eligible households.
$705b
Child Care and Development Fund
(Department of Health and Human
Services)
This program provides funds to Tribes, states, the District of
Columbia, and U.S. territories to subsidize the cost of child
care for low-income families and to improve the quality of care
for all families. COVID-19 relief funds have supported access
to child care, reduced parent fees, supported providers
through unstable enrollment, and supported assistance to
health care and other essential workers without regard to
income eligibility requirements. Additional funding was
provided for sub-grants to eligible child care providers to
support the stability of the child care sector during and after
the COVID-19 pandemic.
$679b
Public Assistance Disaster Relief Fund
(Department of Homeland Security)
Administered by the Federal Emergency Management Agency,
this fund provides federal disaster recovery assistance for
Tribal, state, U.S. territory, and local governments when a
major disaster occurs.
$448
Epidemiology and Laboratory Capacity for
Prevention and Control of Emerging
Infectious Diseases Cooperative
Agreement
(Department of Health and Human
Services)
Administered by the Centers for Disease Control and
Prevention, this funding provides for states, U.S. territories,
and localities to support COVID-19 testing, surveillance, and
contact tracing, among other uses.
$445b
State Small Business Credit Initiative
(Department of the Treasury)
This program provides funds to Tribal governments, states, the
District of Columbia, and U.S. territories for small business
credit support and investment programs.
$346b
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GAO-23-106050 COVID-19
Programs and funds
Description
Amount Allocated to
Territory Governments
(millions)
Transit Grants
(Department of Transportation)
Administered by the Federal Transit Administration, these
funds are distributed through existing grant programs to
provide assistance to Tribes, states, U.S. territories, and
localities to prevent, prepare for, and respond to the COVID-19
pandemic.
$342
Coronavirus Capital Projects Fund
(Department of the Treasury)
This fund provides payments to Tribal governments, states,
the District of Columbia, U.S. territories, and freely associated
states for critical capital projects that directly enable work,
education, and health monitoring, in response to the COVID-
19 pandemic.
$215
Emergency Connectivity Fund
(Federal Communications Commission)
This program provides funding to help schools and libraries
offer the tools and services their communities need for remote
learning during COVID-19.
$120
Homeowner Assistance Fund
(Department of the Treasury)
This program provides assistance to Tribes or their Tribally
Designated Housing Entities, states, the District of Columbia,
U.S. territories, and the Department of Hawaiian Home Lands
to assist eligible homeowners with qualified expenses related
to mortgages and housing.
$106
Source: GAO analysis of COVID-19 relief legislation and allocation data. | GAO-23-106050
Notes: Allocations refer to funds available for obligation that federal agencies set aside for use by
each territory. U.S. Territories refers to American Samoa, the Commonwealth of the Northern
Mariana Islands, Guam, Puerto Rico, and the U.S. Virgin Islands. Allocation data were collected from
publicly available documents or provided by federal agencies from May 2022 to May 2023. Federal
agencies confirmed the allocation data between February 2023 and May 2023.
aIncludes funding related to Pandemic Unemployment Assistance, Federal Pandemic Unemployment
Compensation, Pandemic Emergency Unemployment Compensation, Mixed Earner Unemployment
Compensation, the emergency increase in federal funding of unemployment compensation benefits
and administration, and efforts to combat fraud in these programs.
bIn June 2023, the Fiscal Responsibility Act of 2023 provided for rescissions of unobligated funds in
this program. Therefore, the allocation amount may be reduced. See Pub. L. No. 118-5, div. B, tit. I,
137 Stat. 10, 23-30 (2023).
As shown in figure 3, the federal agencies that allocated the largest
amounts of COVID-19 relief funding to the territories were the
Departments of Labor, Treasury, and Education.
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GAO-23-106050 COVID-19
Figure 3: Federal Agencies with the Largest Allocations of COVID-19 Relief Funds
to U.S. Territory Governments
Note: U.S. Territory governments refers to the governments of American Samoa, the Commonwealth
of the Northern Mariana Islands, Guam, Puerto Rico, and the U.S. Virgin Islands. Allocation amounts
do not reflect rescissions of unobligated funds under the Fiscal Responsibility Act of 2023. See Pub.
L. No. 118-5, div. B, tit. I, 137 Stat. 10, 23-30 (2023). Allocation amounts for the Departments of the
Treasury, Education, Agriculture, and Health and Human Services, as well as several federal
agencies combined under “Other” may be reduced.
The federal government used a combination of new and existing
programs to distribute COVID-19 relief funds to territory governments, as
well as other recipients.
•
New programs. In some cases, COVID-19 relief legislation created
new programs to distribute COVID-19 relief funds. For example, the
Coronavirus Relief Fund was a new program established by the
CARES Act in March 2020 to assist with certain necessary
expenditures incurred due to the COVID-19 pandemic.25 Through this
program, Treasury allocated more than $2.5 billion to territory
25See Pub. L. No. 116-136, § 5001, 134 Stat. 281, 501 (2020), codified at 42 U.S.C. §
801.
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GAO-23-106050 COVID-19
governments for expenditures such as COVID-19 testing and contact
tracing. Treasury also administers the Emergency Rental Assistance
programs—new programs to assist households experiencing financial
hardship during or due—directly or indirectly—to the COVID-19
pandemic. This assistance included rent, utilities, home energy costs,
and other expenses related to housing stability services. Additionally,
legislation created the Education Stabilization Fund program, which
allocated funding to territory education departments through six grant
programs.26
•
Existing programs. Federal agencies also distributed COVID-19
relief funding through programs that existed before the pandemic. For
example, DOT allocated $342 million in supplemental COVID-19
appropriations to territory transportation agencies via existing Federal
Transit Administration grant programs. Similarly, the Department of
Health and Human Services (HHS) allocated an additional $679
million in supplemental COVID-19 appropriations to territories through
the Child Care and Development Fund.
The way that federal agencies made COVID-19 relief funding available to
territory government agencies varied. For some COVID-19 relief
programs, federal agencies allocated and awarded COVID-19 relief
funding and then made it immediately available to territory agencies. For
example, according to territory officials, COVID-19 relief funding for
HHS’s Child Care and Development Fund was immediately available to
territory agencies. For other programs, federal agencies allocated
COVID-19 relief funding for a specific purpose and used that allocation to
reimburse recipients, including territories, for allowable expenses
incurred. For example, the Federal Emergency Management Agency
(FEMA) reimbursed territory governments for eligible COVID-19
expenses under its approved Public Assistance projects using the
Disaster Relief Fund. This approach is consistent with how FEMA
reimburses recipients, including territories, through the Disaster Relief
Fund for other emergencies. Similarly, DOT reimbursed territory
26Puerto Rico received Education Stabilization Funds through the Elementary and
Secondary Education Emergency Relief; Emergency Assistances for Non-public Schools;
Governor’s Emergency Education Relief; American Rescue Plan Elementary and
Secondary School Emergency Relief – Homeless Children and Youth; and Higher
Education Emergency Relief programs. American Samoa, CNMI, Guam, and USVI
received Education Stabilization Funds through the Outlying Areas program, which was
comprised of State Educational Agency and Governor funds. See Pub. L. No. 116-136, §§
18001-18004, 134 Stat. 281, 564-568 (2020); Pub. L. No. 116-260, div. M, tit. III, §§ 311-
313, 134 Stat. 1182, 1924-1932 (2020); Pub. L. No. 117-2, §§ 2001-2002, 2005, 135 Stat.
4, 19-23, 27 (2021).
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GAO-23-106050 COVID-19
transportation agencies for eligible expenses with COVID-19 Transit
Grants, consistent with how DOT reimburses recipients through annual
transit grants.
Territory governments used different approaches to manage and track
uses of COVID-19 relief funds. Some territories made efforts to manage
and track COVID-19 relief funding government-wide to facilitate decision-
making on how to use funding.
•
For example, the governors of American Samoa and CNMI each
created a task force that managed a portion of the COVID-19 relief
funding. These task forces included members from across the
territories’ governments and, in American Samoa, members of the
private sector.
•
In USVI, officials told us two offices tracked all COVID-19 relief
funding through a shared spreadsheet. USVI Office of Management
and Budget and Office of Disaster Recovery officials told us they held
regular meetings to discuss the content of the spreadsheet tracker
and make recommendations about how to use each source of federal
funding.
•
In Guam, officials told us the Bureau of Budget and Management
Research and the Guam State Clearing House collaborated to track
and manage COVID-19 funding.
•
In Puerto Rico, a Disbursement Oversight Committee oversaw the
uses of Coronavirus Relief Funds and the Coronavirus State and
Local Fiscal Recovery Funds (CSLFRF). Funding for other COVID-19
relief programs was managed directly by the recipient agency within
the territory government.
Territory government officials told us that the COVID-19 funding helped
them meet key priorities, including:
•
Public health response to COVID-19. Territory governments used
COVID-19 relief funds for public health measures to mitigate
community spread and combat COVID-19. All five territories received
COVID-19 funding specifically for vaccination efforts, such as FEMA
Public Assistance funds and the Immunization and Vaccines for
Children cooperative agreements from the Centers for Disease
Control and Prevention (CDC). FEMA also directly paid for National
Guard mission assignments to help set up public vaccination sites in
some U.S. territories. Additionally, territories used funds to purchase
Management and Uses of
COVID-19 Relief Funding
Vary across the U.S.
Territories
Page 20
GAO-23-106050 COVID-19
personal protective equipment and COVID-19 tests to supplement the
supplies they received directly from federal agencies.
•
Health care infrastructure and access. American Samoa and Guam
both allocated COVID-19 relief funding for construction of new
medical facilities, including hospitals and a public health laboratory.
Officials from American Samoa said they prioritized improving access
to health care and preventing the disruption of health care service
delivery because American Samoa currently has only one hospital to
serve nearly 50,000 residents. According to planning documents,
Guam plans to reserve $300 million of its CSLFRF allocation—which
Treasury has already obligated to the Government of Guam—for
construction of a campus that includes a medical center, public health
center, and a CDC lab (see fig. 4).
Figure 4: Conceptual Plan for New Guam Medical Campus
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GAO-23-106050 COVID-19
•
Revenue replacement. Using CSLFRF for revenue replacement
allowed some territories to continue government services.27 According
to their CSLFRF Recovery Plans, the governments of CNMI, Puerto
Rico, and USVI planned to use the largest share of their CSLFRF
allocations to address the budget shortfalls caused by the reduction in
government revenue due to the COVID-19 pandemic. These territory
governments rely on tax revenue from tourism, which diminished
significantly during the pandemic.
•
Infrastructure development. Territory governments used COVID-19
relief funding to address infrastructure development needs, such as
those related to prior natural disasters that were worsened by the
pandemic. For example, the government of Puerto Rico used
CSLFRF to invest in hydraulic pumping infrastructure to prevent
dangerous flooding and the displacement and overcrowding that can
occur as a result. American Samoa, CNMI, and Guam allocated
CSLFRF to clean water infrastructure projects such as improving
drinking water systems and making necessary repairs, upgrades, and
investments in water and sewer infrastructure.28 USVI government
officials told us they plan to use their Coronavirus Capital Projects
Fund allocation for broadband infrastructure development, which
officials said is a significant need in the territory.29
The amount of information from individual program reporting
requirements that federal agencies make publicly available, including
27Recipients may use CSLFRF awards for government services up to their amount of
revenue loss due to the pandemic. Governments could select a standard amount of up to
$10 million, not to exceed a recipient’s CSLFRF award amount, or complete a full revenue
loss calculation. 31 C.F.R. § 35.6(d); Coronavirus State and Local Fiscal Recovery Funds,
87 Fed. Reg. 4338, 4402-03 (Jan. 27, 2022); 42 U.S.C. § 802(c)(1)(C).
28One of the allowable uses of CSLFRF funds is to make necessary investments in water,
sewer, or broadband infrastructure. See Pub. L. No. 117-2, tit. IX, subtit. M, § 9901, 135
Stat. 4, 223 (2021), codified at 42 U.S.C. §§ 802-803.
29The Coronavirus Capital Projects Fund, enacted through the American Rescue Plan Act
of 2021, provides payments to Tribal governments, states (defined in the statute to include
the District of Columbia and Puerto Rico), and U.S. territories for critical capital projects
that directly enable work, education, and health monitoring in response to the COVID-19
pandemic. See Pub. L. No. 117-2, tit. IX, subtit. M, § 9901(a), 135 Stat. 4, 233 (2021),
codified at 42 U.S.C. § 804.
Public Availability of
Information on How
COVID-19 Relief Funds
Were Used Varied
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GAO-23-106050 COVID-19
information about territories’ use of funds, varies.30 Some federal
agencies administering COVID-19 relief programs publish recipients’
reporting on their websites. For example, Treasury publishes recipients’
CSLFRF Recovery Plans—that are submitted annually—as well as
quarterly and annual project and expenditure reporting data on its
website.31
Other administering federal agencies compile the data that recipients
report into their own program-wide reporting documents. For example, the
Department of Education created a dashboard that summarizes data on
recipients and their expenditures of Education Stabilization Funds.32
There are also administering agencies that do not publish the reporting
data submitted by recipients in a detailed form on their websites. For
example, Federal Transit Administration officials told us the agency does
not publish information about recipients’ uses of COVID-19 relief funds on
its websites. FEMA provides only high-level obligation and operational
data on its Public Assistance Program.
In some cases, territory governments also publish information about their
uses of COVID-19 relief funds on their websites. For example, the
government of Guam’s website lists the multiple sources of COVID-19
relief funding the territory received and describes how it used each
source, including individual projects such as small business support and
recovery of the tourism industry (see fig. 5).
30Territories were required to submit a variety of reports to comply with individual COVID-
19 relief programs.
31Guam does not have a Recovery Plan available on Treasury’s website. According to
Treasury officials, Guam is required to provide a Recovery Plan and submitted one for
2022. However, Treasury received the plan after it had had posted data publicly. CNMI
was not included in Treasury’s quarterly data through October 2022 because, according to
Treasury officials, CNMI did not submit its Project and Expenditure reports for the first 3
quarters of fiscal year 2022. According to Treasury officials, CNMI submitted its Project
and Expenditure reports in fiscal year 2021, as well as for quarter 4 of fiscal year 2022
and quarter 1 of fiscal year 2023. CNMI is included in the January 2023 quarterly reporting
data on Treasury’s website.
32The Education Stabilization Fund program generally provided formula grants to states
and U.S. territories for education-related needs to address the effect of the COVID-19
pandemic. See the U.S. Department of Education’s Education Stabilization Fund
Transparency Portal at https://covid-relief-data.ed.gov/.
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GAO-23-106050 COVID-19
Figure 5: Screenshot of Guam’s Publicly Available American Rescue Plan Allocations, June 2023
Page 24
GAO-23-106050 COVID-19
According to territory officials, territories did not always have sufficient
administrative capacity within their existing grant and program
administration structures to receive, oversee, and report on the large
amount of COVID-19 relief funding.33 Territory officials told us they
responded by creating new offices, hiring additional staff, when possible,
and hiring contractors.
Officials from American Samoa, CNMI, and Puerto Rico told us they
created new offices or committees to manage new programs
administered by Treasury, such as the Coronavirus Relief Fund and
CSLFRF. American Samoa created the American Rescue Plan Act
(ARPA) Oversight Office to oversee CSLFRF because, according to
territory officials, its CSLFRF award was the largest federal award the
territory had ever received. This office works closely with all subrecipients
that received CSLFRF funds and submits required reporting on uses of
CSLFRF funds to Treasury.34
CNMI officials also cited the significant amount of funding the territory
received in its decision to establish an office focused solely on managing
COVID-19 relief funding. Officials told us that this office included a team
tasked with familiarizing themselves with Treasury guidance for multiple
COVID-19 relief programs and leading communications with Treasury.
Likewise, Puerto Rico established its Disbursement Oversight Committee
to monitor processing of the Coronavirus Relief Fund and CSLFRF
33We previously reported that some of the states and localities that responded to our
survey about CSLFRF said that they had insufficient capacity to manage their CSLFRF
allocations in accordance with federal requirements. GAO, COVID-19: Additional Actions
Needed to Improve Accountability and Program Effectiveness of Federal Response,
GAO-22-105051 (Washington, D.C.: Oct. 27, 2021).
34A subrecipient is a nonfederal entity that receives a subaward from a pass-through entity
to carry out part of a federal award, but does not include an individual that is a beneficiary
of such award. A subrecipient may also be a recipient of other federal awards directly from
a federal awarding agency.
Territory Agencies
Identified Challenges
in Administering
Selected COVID-19
Relief Programs
Territories Increased
Administrative Capacity to
Administer Some COVID-
19 Relief Programs
Page 25
GAO-23-106050 COVID-19
disbursements while working to ensure adherence to Treasury’s
compliance standards.35 This committee is comprised of officials from the
Puerto Rico Fiscal Agency and Financial Advisory Authority, Puerto
Rico’s Office of Management and Budget, and Puerto Rico’s Treasury
Department.
In Guam and USVI, existing territory agencies were given responsibility to
manage COVID-19 relief funds. To do this, the agencies hired additional
staff or created a new team within their agency structure. For example,
Guam officials told us that the Guam Department of Administration
expanded its existing federal accounting branch to manage the incoming
federal COVID-19 funds. USVI officials told us they established an ARPA
office within USVI’s Office of Management and Budget to oversee
CSLFRF and subrecipients of those funds. According to USVI officials,
the office includes six USVI government employees and a team of
contractors, all of whom are paid using CSLFRF funds available for
administrative expenses.
Multiple territory officials stated that their agencies did not have enough
staff to provide the desired support for COVID-19 relief programs.
Territory agencies were not always able to hire additional staff to
administer these programs due to challenges such as a limited pool of
potential candidates with appropriate expertise, competition for talent with
other employers, and short-term funding for positions. For example,
officials at USVI’s Housing Finance Authority told us they initially intended
to hire 20 administrative staff to help with case management, eligibility
processing, and check processing for the Emergency Rental Assistance
and Homeowner Assistance Fund programs. However, in December
2022, officials told us that only 10 total administrative staff had been hired
at any one time and that they ultimately hired a contractor to fulfill some of
these functions. At the Puerto Rico Department of Family Affairs, officials
said the department used recruiters to find candidates because they
faced challenges in hiring staff to manage the COVID-19 Child Care and
Development Fund and Child Care Stabilization Funds programs. CNMI
officials told us that because of the challenges they faced recruiting
35Unlike other territories, Puerto Rico municipalities and metropolitan cities received $1.55
billion in CSLFRF funding directly at the local (municipal) level. Puerto Rico territory
officials did not oversee this funding. Therefore, in this report, we are referring only to the
state component of CSLFRF funding. Puerto Rico officials referred to the program they
oversaw as Coronavirus State Fiscal Recovery Funds.
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GAO-23-106050 COVID-19
project managers, they frequently had to ask for exemptions and
extensions to meet federal program requirements.
In some cases, territory agencies hired contractors to help them
implement COVID-19 relief programs when they were unable to hire
sufficient staff. Agencies in American Samoa, Puerto Rico, and USVI
hired contractors to provide case management for the Emergency Rental
Assistance programs, Homeowner Assistance Fund program, or both,
according to territory officials. Similarly, officials at Puerto Rico’s
Department of Family Affairs said it used consultants for case
management services for the Child Care and Development Fund and
Child Care Stabilization Funds programs.
Territory officials told us that they faced challenges clearly determining
allowable uses of COVID-19 relief funding and, in some cases, meeting
the needs of the territory while complying with the allowable uses.
•
Unclear or delayed guidance: Some territory officials told us that
federal agency guidance on allowable uses was not always initially
clear, especially for new programs or for existing programs that had to
meet new needs.36 For example, FEMA’s existing guidance included
limited reference to infectious diseases. Guidance specific to eligible
emergency protective measures taken in response to COVID-19 was
developed after the start of the public health emergency. Because of
this, Puerto Rico officials told us there was initial confusion about what
expenses would be considered allowable. Additionally, in some cases
it took several months for agencies to publish corresponding
36In our prior work, we reported that states experienced similar challenges. See GAO,
COVID-19: Current and Future Federal Preparedness Requires Fixes to Improve Health
Data and Address Improper Payments, GAO-22-105397 (Washington, D.C.: Apr. 27,
2022).
Territories Faced
Challenges Related to
Allowable Uses of COVID-
19 Relief Funding
Page 27
GAO-23-106050 COVID-19
guidance, such as Treasury publishing the final rule for allowable uses
for CSLFRF.37
According to territory officials, ambiguous eligibility guidance
sometimes delayed territory agencies in expending federal funds.
When guidance was unclear, territory officials reached out to the
administering federal agency to obtain clarity on whether a proposed
use would be eligible. This correspondence took time, and in some
cases, required further clarification.
USVI territory officials told us it took about a year to determine
whether their desired uses for governor’s education stabilization
funding were allowable. Department of Education officials attributed
this delay to a disagreement between the department and USVI about
how to interpret guidance related to the use of federal funds for non-
public schools and non-public entities. They also said that they
communicated with USVI to discuss their proposed uses. Ultimately,
officials told us, USVI was able to use the funding in compliance with
Department of Education guidance.
Officials at Puerto Rico’s Department of Health told us the need to
clarify whether each potential use was allowable impeded their
progress in using Epidemiology and Laboratory Capacity for
Prevention and Control of Emerging Infectious Diseases cooperative
agreements. In some instances, national associations facilitated
communication with federal agencies regarding allowable uses for
COVID-19 relief programs. Officials from one territory told us that
when they faced challenges with Treasury answering their questions,
they began relaying questions and providing feedback through two
national associations that represent states and territories.
37Treasury’s interim final rule for Coronavirus State and Local Fiscal Recovery Funds was
published in May 2021. See Coronavirus State and Local Fiscal Recovery Funds, 86 Fed.
Reg. 26786 (May 17, 2021). Treasury officials told us they sought feedback on the rules
from the public and received more than 1,500 comments during the 60-day comment
period that closed mid-July 2021. Officials told us they worked to review and incorporate
these comments into the final rule. Between publication of the 2021 interim final rule and
the 2022 final rule, Treasury also published Frequently Asked Questions (FAQ) to guide
recipients as they implemented the program pursuant to the 2021 interim final rule. The
final rule was published in January 2022. See Coronavirus State and Local Fiscal
Recovery Funds, 87 Fed Reg. 4338 (Jan. 27, 2022); GAO-22-105397; GAO-22-105051;
COVID-19: Significant Improvements Are Needed for Overseeing Relief Funds and
Leading Responses to Public Health Emergencies, GAO-22-105291 (Washington, D.C.:
Jan. 27, 2022); and COVID-19: Continued Attention Needed to Enhance Federal
Preparedness, Response, Service Delivery, and Program Integrity, GAO-21-551
(Washington, D.C.: July 19, 2021).
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GAO-23-106050 COVID-19
•
Changing guidance. In several cases, territory officials stated that
interpretations of allowable uses or agency advice on uses for new
programs changed while territories were implementing those
programs. As a result, territory agencies could no longer use the
funds in the way they initially planned or could use funds in new ways.
For example, CNMI officials said that they originally planned to use
Coronavirus Relief Funds to pay for CNMI’s share of Medicaid
expenditures, but Treasury guidance issued in January 2021 stated
they could not.38 CNMI officials also told us Treasury advised them to
change their intended uses of Coronavirus Capital Projects Fund
amounts to maximize the territory’s use of federal funding after
passage of the Infrastructure Investment and Jobs Act (IIJA), which
provided additional funding opportunities to territories.39 CNMI officials
said they originally planned to use the Coronavirus Capital Projects
Fund amounts for water, sewer, and broadband infrastructure
projects, but amended their plan to include only broadband projects
due to IIJA funding becoming available for the other types of
infrastructure projects.
•
Restrictions on allowable uses. According to several territory
agency officials, allowable uses sometimes did not meet territories’
needs. Statutory language in the COVID-19 relief laws often restricted
allowable uses of funds to areas directly related to COVID-19.40
These restrictions were challenging for territories managing multiple
ongoing public health emergencies. For example, Puerto Rico
Department of Health officials shared that CDC funding was restricted
to COVID-19, even though they were also trying to manage an mpox
outbreak.41 CDC officials said that, for some jurisdictions, they
approved expansions to include mpox activities if the activities were
38Coronavirus Relief Fund for States, Tribal Governments, and Certain Eligible Local
Governments, Coronavirus Relief Fund Program Guidance. 86 Fed. Reg. 4182 (Jan. 15,
2021). Treasury officials told us that Treasury did not change its guidance on Medicaid
expenditures and that the timing of the publication of the guidance was affected by factors
including consultation with HHS and other federal agencies on allowable uses of CRF
funds.
39Pub. L. No. 117-58, 135 Stat. 429 (2021). According to Treasury officials, Coronavirus
Capital Projects Fund staff provide recipients with guidance on how these funds can best
be leveraged with other federal programs.
40See, e.g., Pub. L. No. 116-136, § 5001, 134 Stat. 281, 503 (2020): Pub. L. No. 117-2, §
9901, 135 Stat. 4, 226 (2021).
41Mpox was formerly known as monkeypox. The World Health Organization renamed the
disease in November 2022.
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GAO-23-106050 COVID-19
connected to the existing COVID-19 activities and within the
appropriated purpose of the funding.
In other cases, specific eligibility criteria prevented territories from
being able to use funds in accordance with their preferences. For
example, the ferry between St. John and St. Thomas in USVI is
operated by a private vendor. According to DOT officials, based on
how that vendor was selected, the operational costs for that specific
ferry route were ineligible to receive funding from Transit Grants.42
Ultimately, USVI officials told us they were able to use CSLFRF to
meet this need.
Territory officials told us they faced challenges accessing and managing
some COVID-19 funds due to pre-existing financial challenges and
unique territory government structures.
•
Reimbursement programs. Some of the territories said that having
sufficient funds to make use of reimbursable programs was
challenging. For example, according to Puerto Rico officials, some
subrecipients did not pursue FEMA’s Public Assistance Disaster
Relief funding for certain allowable uses because the funding was
available as a reimbursement. These subrecipients instead used
programs with immediately available funding, such as Coronavirus
Relief Funds. American Samoa officials said that the territory lacks
funds to pay for disaster related expenses in advance and that they
are still waiting on some reimbursement from FEMA for a vaccination
project they paid for in May 2022.43 Similarly, officials in CNMI said
that, as of May 2023, CNMI was waiting for reimbursement from
FEMA for costs associated with the COVID-19 response, which FEMA
is still reviewing. FEMA confirmed that it has $58 million pending in
reimbursements for CNMI.
•
Private capital requirements. Several territory officials told us that a
lack of sufficient sources of potential private capital investment may
42Department of Transportation officials told us that the Federal Transit Administration has
historically participated in certain capital costs associated with USVI’s provided ferry
service.
43According to American Samoa officials, $1.79 million of the $2.4 million in outstanding
reimbursements for the vaccination project was released to American Samoa in April
2023. As of May 2023, American Samoa officials told us FEMA is still validating the
remaining amount for reimbursement. Prior to this, FEMA released $3.4 million in March
2021 and an additional $1.5 million in March 2022.
Territories Faced
Challenges Accessing
Funds
Page 30
GAO-23-106050 COVID-19
make it more difficult for the territories to meet the requirements for
the State Small Business Credit Initiative program. This program
requires jurisdictions to show potential for private capital to match
federal investment at a 10:1 ratio.44 American Samoa has one local
bank, and officials told us they are awaiting a final decision to
determine if this bank will qualify as an eligible source of private
matching capital. USVI officials told us they were consulting with
Treasury to work with external lenders, as they anticipated challenges
obtaining investments from local banks required to make full use of
available State Small Business Credit Initiative funds.
•
Funding for localities. Unlike states, some of the territories do not
have local units of government that receive federal funding. Three
territories—American Samoa, Guam, and USVI—faced some
challenges accessing their full allocation of CSLFRF, which allocated
some funding directly to counties, non-entitlement units of local
government, and metropolitan cities.45
Officials in American Samoa, Guam, and USVI worked with Treasury
officials to describe their government structure. According to Treasury
officials, following consultation with territories, Treasury determined
that there were no eligible non-entitlement units or units of local
government eligible for distribution of funds. Treasury acknowledged
that it took some time to understand the structure of the territories’
governments before Treasury could allocate funding as provided
44Participating jurisdictions must demonstrate that, at a minimum, $1 of public investment
by a program will cause and result in $1 of private financing for each other credit support
program such as loan guarantee, collateral support, or loan participation program or for
each fund within venture capital fund programs. See 12 U.S.C. § 5705(c)(1). In order to
obtain approval of its State Small Business Credit Initiative other credit support programs,
a jurisdiction must also demonstrate a reasonable expectation that the jurisdiction’s
programs, considered together, will generate small business lending and investment at
least 10 times the federal contribution amount (achieve a 10:1 leverage ratio). See 12
U.S.C. § 5705(c)(2). For additional information on Treasury’s State Small Business Credit
Initiative, see GAO, State Small Business Credit Initiative: Improved Planning Could Help
Treasury Limit Additional Delays, GAO-23-105293 (Washington, D.C.: Feb. 2, 2023).
45The CSLFRF statute provided funding for states and territories to distribute to their non-
entitlement units of local government. The statute also appropriated funds to counties and
county equivalents as defined by the Census Bureau. For counties that are not units of
general local government, the county’s allocation was to be paid to the state or territory for
distribution to the units of local government within the county. Non-entitlement units of
local government are units of general local governments typically serving populations of
fewer than 50,000 and may include towns or townships. See 42 U.S.C. §§ 803(g)(5),
5302(a)(5). A metropolitan city is defined as the central city within a metropolitan area
(i.e., a standard metropolitan statistical area as established by the Office of Management
and Budget) or any other city within a metropolitan area that has a population of 50,000 or
more. 42 U.S.C. §§ 803(g)(4), 5302(a)(4).
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GAO-23-106050 COVID-19
under statute. These territories ultimately received all of the territory
and locality allocated CSLFRF funding at the territory government
level (see fig. 6).
According to American Samoa’s ARPA Oversight Office, it took
several months before Treasury approved American Samoa’s receipt
of county and non-entitlement unit CSLFRF funding. USVI officials
said it took approximately a year to receive their full allocation.
Treasury officials told us that, while Treasury distributed the territory-
level allocation in one tranche, the locality allocations were distributed
in two tranches, consistent with the statute. Second tranche payments
became available 12-months after recipients received their first
tranche payment.
Figure 6: Levels of Government that Received CSLFRF Funding in Each Territory
aNon-entitlement units of local government are units of general local governments typically serving
populations of less than 50,000 and may include towns or townships.
bA metropolitan city is defined as the central city within a metropolitan area (i.e., a standard
metropolitan statistical area as established by the Office of Management and Budget) or any other
city within a metropolitan area that has a population of 50,000 or more.
Territory officials shared that, in some cases, it was challenging to spend
the amount of funding allocated to them within funding time frames.
These challenges were due to both territory-specific circumstances and
broader challenges facing all jurisdictions, such as supply chain delays.
•
Funding exceeding needs. For certain programs, officials at several
territories told us they received allocations that exceeded their needs
as a result of circumstances specific to each territory. For example,
American Samoa officials said they struggled to use all of their Child
Care and Development Funds and Child Care Stabilization Funds.
Territories Could Not
Always Spend Funds
within Allotted Time
Frames
Page 32
GAO-23-106050 COVID-19
Low rates of COVID-19 and early measures to maintain the supply of
child care made it difficult for them to use the child care relief funding
awarded in later COVID-19 relief laws. In addition to receiving
supplemental COVID-19 relief funding for child care, all five territories
were included in the annual Child Care and Development Fund
mandatory formula grants provided to states for the first time in grant
year 2021. Some territory officials said they received these mandatory
annual funds too late in the fiscal year to use them before they
expired.46
Conversely, territories’ inability to use all of their Emergency Rental
Assistance funds reflected a broader program challenge. Officials
from several territories told us that even if all eligible renters applied
for and received funding, the limit to how long each individual could
receive assistance would prevent the territories from expending all of
their allocated funds.47 Treasury reallocated Emergency Rental
Assistance funds from several of the territories because they were
unable to spend them.48 We have previously reported that initial
46The annual mandatory funds were appropriated in March 2021 as part of ARPA roughly
halfway through fiscal year 2021. See Pub. L. No. 117-2, § 9801, 135 Stat. 4, 207 (2021),
codified at 42 U.S.C. 618. The Office of Child Care’s redistribution process for annual
mandatory Child Care and Development Funds effectively allows unused funds that are
allotted to territories to be made available for child care assistance in a subsequent fiscal
year. See 42 U.S.C. § 618(a)(4)(C). HHS Office of Child Care officials told us that they
made themselves available to explain the redistribution process to territory officials.
47The period of assistance for households is subject to statutory limitations. See 15 U.S.C.
§§ 9058a(c)(2), 9058c(d)(1)(A)(ii).
48The Consolidated Appropriations Act, 2021 provided that beginning September 30,
2021, Treasury must recapture excess funds, as determined by the Secretary, not
obligated by a grantee for eligible Emergency Rental Assistance purposes. In addition,
Treasury must reallocate those funds to grantees that, at the time of the reallocation, have
obligated at least 65 percent of their initial Emergency Rental Assistance allocation. See
Pub. L. No. 1160-260, div. N, tit. V, subtit. A, § 501(d), 134 Stat. 1182, 2074 (2020). The
American Rescue Plan provides for a similar reallocation requirement beginning March
31, 2022. See Pub. L. No. 117-2, § 3201(e), 135 Stat. 4, 57 (2021).Treasury issued
guidance addressing reallocation procedures for Emergency Rental Assistance authorized
under both of these statutes. See Department of the Treasury, Emergency Rental
Assistance Under the Consolidated Appropriations Act, 2021: Notice Regarding
Unobligated ERA1 Funds (Washington, D.C.: Sept. 13, 2022); and Department of the
Treasury, Emergency Rental Assistance Under the American Rescue Plan Act of 2021
(ERA2) Reallocation Guidance (Washington, D.C.: Nov. 15, 2022). This program is also
subject to rescissions of unobligated balances under the Fiscal Responsibility Act of 2023.
See Pub. L. No. 118-5, div. B, tit. I, 137 Stat. 10, 23-30 (2023).
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GAO-23-106050 COVID-19
allocations required by statute exceeded local need in many
jurisdictions for the Emergency Rental Assistance programs.49
•
Supply chain delays. While jurisdictions across the U.S. experienced
supply chain challenges during the pandemic, territory officials told us
their isolated geography contributed to additional delays. According to
some territory officials, these delays made it difficult for territory
agencies to receive items they ordered with federal funds and affected
territories’ ability to liquidate funds in a timely way. For example,
officials told us that technological equipment ordered by the American
Samoa Department of Education in 2020 arrived in summer 2022.
Similarly, according to officials from Guam, vendors continue to
request extensions or cancel deliveries due to global supply
challenges as well as the extended delivery time and resources
required to reach Guam.
In addition, officials at one territory told us they were sometimes at a
disadvantage when competing with other jurisdictions—such as state
and city governments—for the same products because their orders
were often smaller. For example, USVI’s Department of Public Works
has had trouble procuring buses and service vehicles with its Transit
Grant funding due to competition with other jurisdictions with larger
orders.
Several territory agency officials told us that in some cases it was
challenging to track reporting requirements for the federal COVID-19
relief funding they received. Various COVID-19 relief programs were
subject to different reporting periods and deadlines. Some programs
required annual or quarterly reports, while others required monthly
reporting. In addition, some programs also required one-time interim or
closeout reports. To address this challenge, officials at USVI’s Office of
Management and Budget shared that they built a new tool to keep track
of the reporting requirements for COVID-19 relief programs. Two territory
As of April 2023, Treasury reallocated the following amounts from the territories: American
Samoa $6.2 million of $18 million, Guam $7.2 million of $62.6 million, Puerto Rico $145.2
million of $565.4 million, USVI $16.4 million of $39.7 million. As of April 2023, CNMI did
not have Emergency Rental Assistance funds reallocated.
49We previously reported that some states received allocations that were too large relative
to their population of eligible renters and that the program effectively provided more
funding per household to states with lower populations. The Emergency Rental Assistance
programs used each territory’s total population and share of the overall population across
the territories to calculate allocation amounts, which overestimated the number of eligible
renters in the territories. GAO, Emergency Rental Assistance: Treasury’s Oversight is
Limited by Incomplete Data and Risk Assessment, GAO-23-105410 (Washington, D.C.:
Dec. 20, 2022).
Territories Faced
Challenges Managing
Reporting Requirements
Page 34
GAO-23-106050 COVID-19
departments of health told us that managing the financial reporting
requirements for the numerous awards received under their Epidemiology
and Laboratory Capacity for Prevention and Control of Emerging
Infectious Diseases cooperative agreement was especially challenging
because they had to report separately on each individual subaccount. For
example, Puerto Rico Department of Health officials stated that some
awards were divided into as many as 20 subaccounts.
In addition to challenges tracking reporting requirements, officials with
some territory agencies told us they had difficulty collecting required data
for certain federal programs from subrecipients. For example, officials at
Puerto Rico’s Fiscal Recovery Program office acknowledged challenges
in their Coronavirus Relief Fund and CSLFRF subrecipient reporting.
They attributed the challenges to a variety of issues including staff
turnover at subrecipient entities as well as the timeliness and accuracy of
subrecipient reports. These officials also noted that often the
subrecipients for these programs were also recipients for other federal
funding sources with different reporting requirements, further limiting
capacity to complete all required reporting.
Officials at several territories told us they also faced challenges using
federal web-based portals to submit federal reporting.50 For example,
multiple territory officials told us that at times the Treasury Office of the
Inspector General’s portal for the Coronavirus Relief Fund program was
unavailable when they were trying to submit data. Specifically, American
Samoa officials told us they had to request a reporting extension as a
result of these challenges with the reporting portal. Treasury officials
confirmed this, stating that they received general feedback that the
territories experienced technical challenges using the portal. In another
case, officials at the Puerto Rico Department of Health said that a third-
party reporting system used for certain Department of Health and Human
Services (HHS) awards did not update account balances when Puerto
Rico redirected funds between accounts, which posed challenges when
trying to submit accurate reporting.51 HHS officials confirmed that this is a
50We have previously reported that selected states also reported challenges using federal
online reporting portals. See GAO-22-105397.
51According to HHS officials, some CDC programs use this system to monitor recipient-
reported spending, progress toward approved activities, and requests for assistance
throughout the performance period. However, GrantSolutions is the official system of
record for CDC grants and cooperative agreements.
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GAO-23-106050 COVID-19
limitation of the system and that account balances must be updated
manually to ensure accurate reporting.
Federal and territory agency officials identified actions taken by federal
agencies that mitigated the territories’ challenges in administering and
using COVID-19 relief funding.
•
Technical assistance. Agencies provided support or technical
assistance to recipients of COVID-19 funds in a variety of formats.
These formats include online reporting guidance, frequently updated
Frequently Asked Questions (FAQ) documents, documents
summarizing promising or best practices, regularly scheduled
webinars, and video-conference sessions. Some federal agencies,
including CDC and the Federal Transit Administration, provided a new
webinar or updated FAQ document each time a new appropriation
was available. Several federal agencies made particular efforts to
accommodate the Pacific territories’ time zones, including in some
cases stationing project officers or other staff in the Pacific territories.
Federal agencies often identified designated points of contact for
territories who, in some cases, had previously worked with territory
agencies on existing federal programs. For example, regional office
staff from HHS’s Office of Child Care worked with territory agencies to
review Child Care Stabilization Funds applications and held regular
office hours to address territory agency concerns and questions.
Several territory agency officials told us about similar regularly
scheduled meetings with other federal agencies as part of technical
assistance for COVID-19 relief programs. The availability of a direct
contact varied by individual program. For example, according to
officials from two territories, Treasury provided a direct point of
contact for the State Small Business Credit Initiative and officials from
one territory told us they had a point of contact for the Emergency
Rental Assistance programs. By contrast, Treasury offered a general
mailbox for recipients of awards under the Coronavirus Relief Fund
and CSLFRF programs.
Federal Actions
Helped Mitigate
Challenges and
Could Inform Future
Federal Funding
Federal Actions Helped
Territory Agencies Mitigate
Certain Challenges in
Implementing COVID-19
Relief Programs
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GAO-23-106050 COVID-19
Additionally, in some cases, federal agencies provided information on
other available federal funding opportunities. For example, FEMA
regional officials also helped the Pacific territories manage across
available federal funding by creating a database of federal grant
opportunities, according to FEMA officials.52
•
Flexibility in allowable uses. Federal agencies demonstrated
flexibilities in modifying allowable uses of funds to accommodate
territory needs, when determined available under statute. Some
territory government officials shared examples in which they
successfully engaged with federal agencies to expand the allowable
uses of program funds for specific relief programs. For example,
partially in response to feedback from territories, Treasury included
specific capital expenditures as allowable in its final rule for
CSLFRF.53 Guam officials told us they specifically requested Treasury
to make this change so that they would be able to use CSLFRF to
build a hospital.
•
Facilitating access to federal funds. Officials at federal agencies
were aware that certain funding mechanisms posed difficulties for
many of the territories and, when allowable, some federal agencies
used flexibilities to make federal funds more easily accessible. For
example, according to USVI officials, Treasury is helping them work
with off-island lenders to meet the private capital requirement for the
State Small Business Credit Initiative program. Treasury officials told
us they also tried to connect territories with as many private lenders
52See the Recovery and Resilience Resource Library, https://www.fema.gov/emergency-
managers/practitioners/recovery-resilience-resource-library.
53See Coronavirus State and Local Fiscal Recovery Funds, 87 Fed. Reg. 4338, 4450
(Jan. 27, 2022), codified at 31 C.F.R. § 35.6(b)(3).
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GAO-23-106050 COVID-19
as possible during the original State Small Business Credit Initiative
program.54
Federal agencies administering reimbursable programs used
flexibilities to allow territories to access funds more quickly under
certain circumstances. For example, FEMA deemed several territory
emergency projects as “expedited.” This enabled those territories to
receive advanced payments for 50 percent of the projects’ obligated
funding without having to go through the reimbursement process.
Additionally, USVI officials told us they were able to submit invoices
rather than receipts for reimbursement, enabling them to move
projects forward more easily.
•
Time frame flexibility. In limited instances, federal agencies were
able to extend timeframes for obligating or liquidating funding to
accommodate situations specific to the territories. For example, the
Department of Education allowed recipients of Education Stabilization
Funds to apply for a 14-month extension to liquidate funds that were
properly obligated.55 Additionally, HHS’s Office of Child Care granted
waivers to the territories that extended the obligation and liquidation
periods for some COVID-19 supplemental child care funds.
In several cases, territory officials told us that federal agencies also
allowed reporting extensions, especially when reporting delays were
due to technical or logistical issues with the reporting portals.
According to Puerto Rico Department of Health officials, CDC
provided a 3-day extension to submit its annual report for one
Epidemiology and Laboratory Capacity for Prevention and Control of
54Congress first authorized the State Small Business Credit Initiative in the Small
Business Jobs Act of 2010, appropriating $1.5 billion in funding following the 2007–2009
financial crisis: See Pub. L. No. 111-240, tit. III, 124 Stat. 2504, 2568-2582 (2010). GAO
issued four reports on the program and made recommendations to Treasury on improving
oversight and enhancing performance measurement and evaluation. Treasury
implemented our recommendations. See Small Business Credit Programs: Treasury
Continues to Enhance Performance Measurement and Evaluation but Could Better
Communicate and Update Results, GAO-15-105 (Washington, D.C.: Dec. 11, 2014); State
Small Business Credit Initiative: Opportunities Exist to Enhance Performance
Measurement and Evaluation, GAO-14-97 (Washington, D.C.: Dec. 18, 2013); Small
Business Lending: Opportunities Exist to Improve Performance Reporting of Treasury’s
Programs, GAO-13-76 (Washington, D.C.: Dec. 5, 2012); and GAO, State Small Business
Credit Initiative: Opportunities Exist to Improve Program Oversight, GAO-12-173
(Washington, D.C.: Dec. 7, 2011).
55Recipients of Elementary and Secondary School Emergency Relief, Governor’s
Emergency Education Relief, Emergency Assistance to Nonpublic Schools, and Outlying
Area State Educational Agency and Governor’s funds under the CARES Act and
Coronavirus Response and Relief Supplemental Appropriations Act were eligible to apply
for this extension.
Page 38
GAO-23-106050 COVID-19
Emerging Infectious Diseases award because of a delay in the
reporting system displaying correct information. Similarly, American
Samoa officials said they received an extension when they faced
technical problems submitting their Coronavirus Relief Fund report.
Outside of portal challenges, Puerto Rico territory officials shared how
Treasury officials immediately granted extensions on Coronavirus
Relief Fund reporting deadlines in the wake of Hurricane Fiona in
September 2022.
The administration of COVID-19 relief programs highlighted ways in
which the federal government met the needs of the territories to quickly
disburse federal funding. We identified the following themes based on
territory government officials’ experiences that could inform future federal
relief programs to U.S. territories.
•
Leveraging pre-existing programs. According to our interviews with
territory officials, they experienced fewer challenges administering
and reporting on pre-existing federal programs that received
additional money when compared to programs newly created in
COVID-19 relief funding legislation.56 For example, as noted above,
territory officials told us determining allowable uses for new programs
was not always clear. Additionally, several territory officials who
managed awards under Treasury’s programs shared how they
experienced initial difficulties in submitting required reporting data due
to issues with the Coronavirus Relief Fund reporting portal. In
contrast, officials at one territory department of public works
commented on the ease of administering Transit Grants because the
process was similar to annual transit grants.
•
Providing high levels of technical assistance. Several territory
officials we interviewed faced fewer challenges when implementing
programs where there was strong coordination and communication
between the federal agency and the territory. For example, territory
officials from USVI’s Office of Disaster Recovery highlighted the
benefits of having a direct point of contact at FEMA for Public
Assistance Disaster Relief Funds. On the other hand, government
officials at one territory observed a high level of staff turnover at
Treasury. In addition, officials at another territory noted that Treasury
did not appoint a specific territory point of contact for some of its
56We previously reported that officials from associations representing state and local
governments and three states told us it is more challenging for states and localities to
manage newly created programs than programs that already existed and received
additional funding under the COVID-19 relief laws. GAO-22-105397.
Territory Experiences
Could Inform Future
Federal Relief to the
Territories
Page 39
GAO-23-106050 COVID-19
largest COVID-19 relief programs, Coronavirus Relief Fund and
CSLFRF. Territories noted that this hindered communication between
them and Treasury.
•
Providing funding flexibilities. COVID-19 relief included programs
with relatively flexible allowable uses, such as CSLFRF. According to
several territory officials, these flexibilities allowed territory
governments to meet needs that might not be considered allowable
under other federal programs. For example, as previously discussed,
USVI needed to fund operating costs for the ferry between St.
Thomas and St. John, which the territory deemed crucial to its
economic recovery. The ferry is operated by a private vendor and
Department of Transportation officials told us that, based on how that
vendor was selected, operational costs for that ferry route were
ineligible to receive funding from Transit Grants. However, USVI used
CSLFRF to fund the ferry’s operation during the pandemic since USVI
officials found these funds to be more flexible.
•
Use of immediately available funding. Representatives of several
territory governments shared how immediately available funding was
beneficial, enabling them to plan, schedule, and expend funds for
eligible and approved projects. CSLFRF, in particular, was singled out
by territory government officials as a program whose funds were
quickly distributed and allocated for use.
We provided a draft of this report to the Departments of Education, Health
and Human Services, Homeland Security, the Interior, Transportation,
and the Treasury, as well as the governments of American Samoa,
Guam, the Commonwealth of the Northern Mariana Islands, Puerto Rico,
and the U.S. Virgin Islands for review and comment. We received written
letters from American Samoa and Puerto Rico, which are reprinted in
appendixes III and IV. We received technical comments from the
Departments of Education, Health and Human Services, Homeland
Security, Transportation and the Treasury, as well as the governments of
American Samoa and Puerto Rico, which we incorporated as appropriate.
We did not receive comments from the governments of the
Commonwealth of the Northern Mariana Islands, Guam, and the U.S.
Virgin Islands.
We are sending copies of this report to the appropriate congressional
committees, the Secretaries of Education, Health and Human Services,
the Interior, Transportation, and the Treasury, as well as the Governors of
American Samoa, Guam, the Commonwealth of the Northern Mariana
Islands, Puerto Rico, and the U.S. Virgin Islands, and other interested
Agency Comments
Page 40
GAO-23-106050 COVID-19
parties. In addition, the report is available at no charge on the GAO
website at https://www.gao.gov.
If you or your staff have any questions about this report, please contact
Jeff Arkin at 202-512-6806 or arkinj@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. GAO staff who made key contributions to this
report are listed in appendix V.
Jeff Arkin
Director, Strategic Issues
Page 41
GAO-23-106050 COVID-19
List of Committees
The Honorable Patty Murray
Chair
The Honorable Susan Collins
Vice Chair
Committee on Appropriations
United States Senate
The Honorable Ron Wyden
Chairman
The Honorable Mike Crapo
Ranking Member
Committee on Finance
United States Senate
The Honorable Bernard Sanders
Chair
The Honorable Bill Cassidy
Ranking Member
Committee on Health, Education, Labor, and Pensions
United States Senate
The Honorable Gary C. Peters
Chairman
The Honorable Rand Paul, M.D.
Ranking Member
Committee on Homeland Security and Governmental Affairs
United States Senate
The Honorable Kay Granger
Chair
The Honorable Rosa L. DeLauro
Ranking Member
Committee on Appropriations
House of Representatives
Page 42
GAO-23-106050 COVID-19
The Honorable Cathy McMorris Rodgers
Chair
The Honorable Frank Pallone, Jr.
Ranking Member
Committee on Energy and Commerce
House of Representatives
The Honorable Mark E. Green, MD
Chairman
The Honorable Bennie G. Thompson
Ranking Member
Committee on Homeland Security
House of Representatives
The Honorable James Comer
Chairman
The Honorable Jamie Raskin
Ranking Member
Committee on Oversight and Accountability
House of Representatives
The Honorable Jason Smith
Chairman
The Honorable Richard Neal
Ranking Member
Committee on Ways and Means
House of Representatives
Appendix I: Objectives, Scope, and
Methodology
Page 43
GAO-23-106050 COVID-19
The CARES Act includes a provision for us to conduct monitoring and
oversight of the use of funds made available to prepare for, respond to,
and recover from the COVID-19 pandemic.1 This report focuses on
COVID-19 relief provided to the five permanently inhabited U.S.
territories—American Samoa, Guam, the Commonwealth of the Northern
Mariana Islands (CNMI), Puerto Rico, and the U.S. Virgin Islands (USVI).
We reviewed (1) how much funding was allocated to the territories and
how those funds were used; (2) territories’ experiences administering
COVID-19 relief funding; and (3) how selected federal agencies helped
territories administer COVID-19 relief funding and what themes can
inform future federal relief to the territories.
To describe the amount of COVID-19 relief funding that federal agencies
allocated to the territories, we reviewed the six COVID-19 relief laws
enacted in 2020 and 2021 and identified appropriations that funded
programs for which territory governments were eligible recipients.2 We
then collected allocation data for these programs by reviewing federal
agency websites for publicly available allocation data between May 2022
and May 2023. We confirmed these publicly available data with federal
agencies, as needed, between February 2023 and May 2023. When
allocation data for a COVID-19 relief program were unavailable publicly
we requested the data from the administering federal agency between
January 2023 and March 2023. We shared the allocation data we
collected with each territory for review by territory officials. Subsequent to
our review, President Biden signed the Fiscal Responsibility Act of 2023,
which according to preliminary estimates from the Congressional Budget
Office, would rescind approximately $27.1 billion in budget authority of
unobligated funds under 87 COVID relief programs.3
1Pub. L. No. 116-136, § 19010(b), 134 Stat. 281, 580 (2020).More information on GAO’s
COVID-19-related work is available at https://www.gao.gov/coronavirus.
2These six laws are the American Rescue Plan Act of 2021 (ARPA), Pub. L. No. 117-2,
135 Stat. 4 (2021); Consolidated Appropriations Act, 2021, Pub. L. No. 116-260, div. M
and N, 134 Stat. 1182 (2020); Paycheck Protection Program and Health Care
Enhancement Act, Pub. L. No. 116-139, 134 Stat. 620 (2020); CARES Act, Pub. L. No.
116-136, 134 Stat. 281 (2020); Families First Coronavirus Response Act, Pub. L. No. 116-
127, 134 Stat. 178 (2020); and the Coronavirus Preparedness and Response
Supplemental Appropriations Act, 2020, Pub. L. No. 116-123, 134 Stat. 146 (2020).
3See Pub. L. No. 118-5, div. B, tit. I, 137 Stat. 10, 23-30 (2023); Letter from Phillip L.
Swagel, Director, Congressional Budget Office, to Hon. Kevin McCarthy, Speaker of the
House of the House of Representatives, re: CBO’s Estimate of the Budgetary Effects of
H.R. 3746, the Fiscal Responsibility Act of 2023 (May 30, 2023).
Appendix I: Objectives, Scope, and
Methodology
Allocation Data and
Uses of Federal
Funding
Appendix I: Objectives, Scope, and
Methodology
Page 44
GAO-23-106050 COVID-19
We included allocations of COVID-19 relief funding that were directed to
territory government recipients. We excluded any allocations that were
directly disbursed to other types of recipients, such as individuals, private
businesses, public institutions of higher education, local governments, or
municipalities. If a program did not allocate any COVID-19 relief funding
to territory government recipients, we excluded the program from our
analysis. We also excluded appropriations in the COVID-19 relief laws
that increased or created new annual mandatory funding for territories or
that extended the period of availability for prior funds, such as formula
changes to Medicaid for territories.
To identify ways in which territories used COVID-19 relief funding, we
reviewed documents that territories submitted to federal agencies as part
of reporting for individual COVID-19 relief programs, including
Coronavirus State and Local Fiscal Recovery Funds Recovery Plans. We
also reviewed applicable Office of Inspector General (OIG) reports and
interviewed territory agency officials about their priorities in using federal
COVID-19 relief funding. We did not evaluate whether territory uses of
federal COVID-19 relief funding complied with allowable uses.
To identify ways in which territories’ uses of COVID-19 relief funds were
made publicly available, we reviewed the websites for COVID-19 relief
programs that allocated more than $100 million to the territories. We also
reviewed the main website for each territory’s government for reports that
were made available to the public.
To describe publicly available information on obligations and
disbursements of COVID-19 relief funding to territory governments, we
collected and analyzed data from USAspending.gov. We obtained
financial assistance award data from USAspending.gov Custom Award
Download on April 20, 2023 reflecting award data through February 28,
2023. Using our list of COVID-19 relief programs for which territory
governments received allocations, we identified the Catalog of Federal
Domestic Assistance (CFDA) number for each program. We confirmed
the CFDA numbers with federal agencies as needed. We downloaded
data from USAspending.gov for awards made to these CFDA numbers
that were also associated with the COVID-19 Disaster Emergency Fund
Codes (DEFC) and had a Primary Place of Performance or Recipient
Obligation and
Disbursement Data
from
USAspending.gov
Appendix I: Objectives, Scope, and
Methodology
Page 45
GAO-23-106050 COVID-19
Location in one of the territories.4 We reviewed the list of recipients that
this search yielded and identified which recipients were territory
government agencies to create a final list of awards to include. Two
analysts reviewed the list independently to determine which recipients
were a territory government agency and should be included based on the
recipient name and publicly available information on the recipient name.
In cases where the team members disagreed or were uncertain, the team
members did additional research, such as reviewing the recipient name’s
individual page on USAspending.gov, to determine whether the recipient
should be included. We used these awards to calculate the obligations
and disbursements for COVID-19 relief programs to the U.S. territories.
Because we filtered award data for specific DEFCs, our obligation and
disbursement amounts will not include awards that are erroneously or
inadvertently unlinked and therefore are not connected to a DEFC.
Additionally, the Office of Management and Budget requirement to use
the DEFC for disbursements did not apply until the June 2020 reporting
period.5
Award data on USAspending.gov comes from two distinct data sets—File
C and File D2.
File C contains the financial aspects of awards, including obligation and
disbursement data, which agencies must submit to USAspending.gov
monthly from agency financial systems. It also includes the DEFC, which
tracks spending from supplemental appropriation bills such as those
related to COVID-19 relief and infrastructure investment.
File D2 contains both financial information (e.g., award amount) and other
non-financial details (e.g., recipient name, recipient location, and place of
4Disaster Emergency Fund Codes are used to track the spending of funding for disasters
and emergencies such as COVID-19. Each code links to one or more laws that authorized
the funding. The Office of Management and Budget (OMB) establishes a new DEFC value
for each enacted appropriation with disaster or emergency funding. The corresponding
title for each DEFC value generally identifies the associated public law number(s) and
whether the funding is disaster or emergency. In some cases, OMB also establishes
DEFCs for nonemergency funding.
5Agencies were required to begin reporting DEFC values for obligations during the
reporting period ending March 2018. See OMB, M-18-08, Memorandum, For Chief
Financial Officers and Budget Officers: Guidance on Disaster and Emergency Funding
Tracking (Washington, D.C.: Feb. 2, 2018). In 2020, OMB updated its guidance and
required agencies with COVID-19 relief spending to use the DEFC for disbursements
beginning with the June 2020 reporting period. See OMB, M-20-21.
USAspending.gov Data
Completeness
Appendix I: Objectives, Scope, and
Methodology
Page 46
GAO-23-106050 COVID-19
performance) for financial assistance awards that agencies submit to the
Financial Assistance Broker Submission (FABS) module of the
USAspending.gov DATA Act Broker.
Complete information about any given award is only possible if that award
is “linked” across the two sources. If an award appears in agency financial
systems (File C) but not in FABS (File D2), then it will lack information
such as recipient, location, industry, and assistance listing (formerly
known as CFDA program). On the other hand, if an award appears in
FABS but not in agency financial systems, then it will lack information
such as treasury account symbol, program activity, object class, DEFC,
and outlays.
To determine the reliability of USAspending.gov for our purposes, we
reviewed our past work assessing the quality of available data. The data
quality, as assessed by agency OIGs and summarized by GAO, was
reasonably reliable for some agencies, and less reliable for others. We
determined that, when reporting data for these agencies, we would
indicate whether they were from agencies with reasonably reliable, or less
reliable data.
Additionally, in prior work, we identified limitations in the reliability of
USAspending.gov data for some agencies or programs. For example,
according to OIG reports from 2021, some federal agencies did not
submit data to USAspending.gov within established time frames. So the
information available on the website for those agencies may not reflect
current levels of spending. In other cases, some agencies faced
challenges implementing the data element that designates spending as
COVID-19 related. So, some spending may be mislabeled.6 For example,
Departments of Agriculture (USDA) and Treasury officials told us that
DEFC values were used inconsistently when submitting obligation data to
USAspending.gov. This resulted in COVID-19 obligations that are not
labeled as COVID-19-related on USAspending.gov. USDA and Treasury
corrected this error for data moving forward. Thus, in some cases
6We, OIGs, and the Pandemic Response Accountability Council reported that agencies
faced challenges reporting COVID-19 disbursements. During their review of 2021 data,
seven OIGs reported their agencies had issues with its COVID-19 disbursement
information. An additional four OIGs reported their agencies’ COVID-19 disbursement
data were incomplete, inaccurate, and untimely. See GAO-22-105427. The Pandemic
Response Accountability Council discovered that some agencies were not reporting any
disbursement data from COVID-19 awards more than 19 months after the onset of the
pandemic. Pandemic Advisory Council, Increasing Transparency into COVID-19 Spending
(Washington, D.C.: Oct. 19, 2021).
Agency-Specific
USAspending.gov Data
Limitations
Appendix I: Objectives, Scope, and
Methodology
Page 47
GAO-23-106050 COVID-19
USAspending.gov shows that these agencies have disbursed more
funding for a program than was obligated, because the disbursement was
labeled with the correct DEFC, but the obligation was not. According to
agency officials, USDA does not plan to correct and resubmit past data.
Treasury officials told us they are working to make any necessary
corrections to USAspending.gov.
We did not use USAspending.gov for the obligation and disbursement
totals for pandemic unemployment benefits paid to Puerto Rico or USVI.
We used data provided by the Department of Labor in June 2023.
Officials at the Department of Labor told us obligations and
disbursements for benefit payments to Puerto Rico and USVI are not
shown on USAspending.gov under grant awards to states. According to
Department of Labor officials, these funds to Puerto Rico and USVI are
not shown on USAspending.gov under grants awarded to states because
the funds are provided to those territories through the Unemployment
Trust Fund (UTF), not through individual grants, and UTF funds are only
reported as national aggregate amounts on USAspending.gov. Data on
benefits are shown for the other territories that do not receive funds
through the UTF because the Department of Labor awarded individual
grants to those territories specifically for pandemic unemployment
insurance.
We did not use USAspending.gov for the obligation and disbursement
totals for the Federal Emergency Management Agency’s (FEMA) Public
Assistance Disaster Relief Fund. We used reports provided by FEMA as
of March 2023. Funding provided to the Disaster Relief Fund is generally
not specific to individual disasters. Therefore, the Department of the
Treasury’s methodology for determining COVID-19-related obligations
and disbursements on USAspending.gov does not capture obligations
and disbursements for the COVID-19 response based on funding other
than what was provided in the COVID-19 relief laws. Further,
USAspending.gov’s methodology includes all obligations and
disbursements based on funding in the COVID-19 relief laws, including
those for other disasters.
We were also unable to capture all relevant obligations and
disbursements for the Federal Communications Commission (FCC) in our
dataset. FCC officials told us that territory governments can either request
Emergency Connectivity Funds as a reimbursement for payments made
to broadband service providers, or that FCC pay the broadband service
provider directly. Our data set did not capture obligations and
Appendix I: Objectives, Scope, and
Methodology
Page 48
GAO-23-106050 COVID-19
disbursements made directly to broadband service providers on behalf of
territory governments.
Throughout this report, we note that there are challenges with the
reliability of the data. Ultimately, we determined that the quality of data
submitted to USAspending.gov varied by federal agency, but was
sufficient for our use because it is widely and publicly available. We
confirmed inconsistencies we identified with the appropriate federal
agencies. In cases where data differed from agency sources, we used the
federal agency’s data. We also confirmed the obligation and
disbursement data available on USAspending.gov with all agencies
administering programs that allocated more than $100 million to U.S.
territories (Departments of Agriculture, Education, Health and Human
Services, Homeland Security, Labor, Transportation and the Treasury,
and the Federal Communications Commission).
To describe territories’ experiences administering COVID-19 relief
funding, we reviewed program guidance provided by federal agencies
and interviewed relevant territory agencies about their experiences
working with 11 selected programs. We selected these programs by first
identifying federal agencies that administered the largest COVID-19 relief
programs—those that received direct appropriations for more than $10
billion exclusively or primarily for Tribes, states, the District of Columbia,
localities, and U.S. territories—in at least one of the six COVID-19 relief
laws.
This analysis resulted in five federal agencies: the Departments of
Education, Health and Human Services, Homeland Security,
Transportation, and the Treasury. We then identified any programs that
these agencies administered for which territory governments were eligible
recipients. Using publicly available allocation data for these programs on
federal agency websites, we identified those programs that allocated
more than $100 million to the territories. This resulted in a list of 11
programs. See table 4.
Territory Experiences,
Federal Agency
Actions, and Themes
to Inform Future
Federal Funding
Appendix I: Objectives, Scope, and
Methodology
Page 49
GAO-23-106050 COVID-19
Table 4: Selected COVID-19 Relief Programs
Federal Agency
Program Name
Department of Education
Education Stabilization Funds
Puerto Rico Received Education Stabilization Funds through the Elementary and
Secondary Education Emergency Relief; Emergency Assistances for Non-public
Schools; Governor’s Emergency Education Relief; American Rescue Plan
Elementary and Secondary School Emergency Relief – Homeless Children and
Youth; and Higher Education Emergency Relief programs. American Samoa, the
Commonwealth of the Northern Mariana Islands, Guam, and the U.S. Virgin Islands
received Education Stabilization Funds through the Outlying Areas program.
Department of Health and Human Services
Child Care and Development Fund
Includes supplemental funding for the Child Care and Development Fund and the
Child Care Stabilization Funds
Department of Health and Human Services
Epidemiology and Laboratory Capacity for Prevention and Control of Emerging
Infectious Diseases Cooperative Agreement
Department of Homeland Security
Public Assistance Disaster Relief Funds
Department of Transportation
Transit Grants
Department of the Treasury
Coronavirus State and Local Fiscal Recovery Funds
Department of the Treasury
Coronavirus Relief Fund
Department of the Treasury
Emergency Rental Assistance
Department of the Treasury
State Small Business Credit Initiative
Department of the Treasury
Coronavirus Capital Projects Fund
Department of the Treasury
Homeowner Assistance Fund
Source: GAO analysis of COVID-19 relief laws and publicly available allocation data. | GAO-23-106050
We also reviewed documentation provided by territory governments. We
conducted site visits with territory agency officials in Puerto Rico and
USVI, and video conferences with officials in American Samoa, CNMI,
and Guam.
To describe how selected federal agencies helped territories administer
COVID-19 relief funding, we reviewed program guidance provided by
federal agencies and interviewed federal agency officials that
administered the 11 selected programs. We also reviewed documentation
provided by territory governments and interviewed territory government
agencies responsible for administering the selected COVID-19 relief
programs. To identify and describe themes that could inform future
federal relief programs, we conducted a content analysis of interview
statements from federal agency and territory government agency officials.
We then asked targeted follow-up interview questions to confirm that
identified themes were consistent across the territories.
Appendix I: Objectives, Scope, and
Methodology
Page 50
GAO-23-106050 COVID-19
We conducted this performance audit from May 2022 to September 2023
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
Appendix II: COVID-19 Relief Funding
Allocated to U.S. Territories by Program as
of May 2023
Page 51
GAO-23-106050 COVID-19
Table 5: Funding Allocated to U.S. Territories for Department of Agriculture COVID-19 Programs
Program Name
American
Samoa
Commonwealth
of the Northern
Mariana Islands
Guam
Puerto Rico
U.S. Virgin Islands
Child Nutrition Programs
$0
$0
$2,861,211
$48,601,131
$211,209
Commodity Supplemental Food
Program
$0
$0
$0
$150,262
$0
Emergency Rural Development
Grants for Health Carea
$1,752,700
$0
$1,175,000
$3,774,200
$1,175,000
Farming Opportunities Training and
Outreach Programa
$0
$0
$0
$876,133
$0
Food System Transformation
$10,000,000
$0
$0
$0
$0
Meat and Poultry Processing
Workforce Development Centers of
Excellence
$0
$0
$475,001
$1,424,999
$0
Nutrition Assistance
$7,477,000
$45,861,000
$0
$1,860,662,000
$0
Pandemic-EBT
$22,842,226
$30,129,893
$802,111
$997,325,959
$773,651
Specialty Crop Block Grantsa
$357,278
$325,378
$326,712
$641,132
$325,454
Special Supplemental Nutrition
Program for Women, Infants, and
Children (WIC)
$586,141
$372,868
$823,944
$16,437,983
$481,872
Support for Farm Stress Programs
$500,000
$0
$500,000
$500,000
$500,000
Source: GAO analysis of Department of Agriculture data. | GAO-23-106050
Note: Allocation data were provided by the Department of Agriculture in April 2023.
aIn June 2023, the Fiscal Responsibility Act of 2023 provided for rescissions of unobligated funds in
this program. See Pub. L. No. 118-5, div. B, tit. I, 137 Stat. 10, 23-30 (2023). Therefore, the ultimate
allocation amounts may be reduced.
Appendix II: COVID-19 Relief Funding
Allocated to U.S. Territories by Program as
of May 2023
Appendix II: COVID-19 Relief Funding
Allocated to U.S. Territories by Program as
of May 2023
Page 52
GAO-23-106050 COVID-19
Table 6: Funding Allocated to U.S. Territories for Department of Commerce COVID-19 Programs
Program Name
American
Samoa
Commonwealth
of the Northern
Mariana Islands
Guam
Puerto Rico
U.S. Virgin
Islands
Assistance to Fisheries Participants
$5,553,194
$1,411,002
$1,796,082
$4,000,000
$4,000,000
Broadband Infrastructure Deployment
Programa
$0
$0
$12,770,692
$0
$0
Economic Adjustment Assistance
$4,395,492
$2,436,555
$4,820,636
$5,720,968
$11,024,426
Source: GAO analysis of Department of Commerce data. | GAO-23-106050
Note: Allocation data were collected between June 2022 and April 2023 and reflect data published as
early as May 2020. Allocation data were confirmed by the Department of Commerce in April 2023.
aIn June 2023, the Fiscal Responsibility Act of 2023 provided for rescissions of unobligated funds in
this program. See Pub. L. No. 118-5, div. B, tit. I, 137 Stat. 10, 23-30 (2023). Therefore, the ultimate
allocation amounts may be reduced.
Table 7: Funding Allocated to U.S. Territories for Department of Education COVID-19 Programs
Program Name
American
Samoa
Commonwealth
of the Northern
Mariana Islands
Guam
Puerto Rico
U.S. Virgin
Islands
Education Stabilization Funda, b
$431,826,890
$262,415,669
$484,810,330
$4,955,682,324
$234,097,111
Funding for Individuals with Disabilities
Education Act (IDEA)
$1,390,312
$1,055,623
$3,385,571
$31,713,834
$1,756,253
Source: GAO analysis of Department of Education data. | GAO-23-106050
Note: Allocation data were collected between June 2022 and May 2023 and confirmed by the
Department of Education in May 2023.
aPuerto Rico received Education Stabilization Funds through the Elementary and Secondary
Education Emergency Relief; Emergency Assistances for Non-public Schools; Governor’s Emergency
Education Relief; American Rescue Plan Elementary and Secondary School Emergency Relief -
Homeless Children and Youth; and Higher Education Emergency Relief programs. American Samoa,
the Commonwealth of the Northern Mariana Islands, Guam, and the U.S. Virgin Islands received
Education Stabilization Funds through the Outlying Areas program.
bIn June 2023, the Fiscal Responsibility Act of 2023 provided for rescissions of unobligated funds in
this program. See Pub. L. No. 118-5, div. B, tit. I, 137 Stat. 10, 23-30 (2023). Therefore, the ultimate
allocation amounts may be reduced.
Appendix II: COVID-19 Relief Funding
Allocated to U.S. Territories by Program as
of May 2023
Page 53
GAO-23-106050 COVID-19
Table 8: Funding Allocated to U.S. Territories for U.S. Election Assistance Commission COVID-19 Programs
Program Name
American
Samoa
Commonwealth
of the Northern
Mariana Islands
Guam
Puerto Rico
U.S. Virgin
Islands
Election Security Grants
$600,000
$600,000
$600,000
$3,881,359
$600,000
Source: GAO analysis of U.S. Election Assistance Commission data. | GAO-23-106050
Note: Allocation data were collected from the U.S. Election Assistance Commission’s website in
February 2023.
Table 9: Funding Allocated to U.S. Territories for Environmental Protection Agency COVID-19 Programs
Program Name
American
Samoa
Commonwealth
of the Northern
Mariana Islands
Guam
Puerto Rico
U.S. Virgin
Islands
Environmental Justice Government-to-
Government (EJG2G) Program
$200,000
$0
$0
$0
$0
Source: GAO analysis of Environmental Protection Agency data. | GAO-23-106050
Note: Allocation data were collected and confirmed by the Environmental Protection Agency in
February 2023.
Table 10: Funding Allocated to U.S. Territories for Federal Communications Commission COVID-19 Programs
Program Name
American
Samoa
Commonwealth of
the Northern
Mariana Islands
Guam
Puerto Rico
U.S. Virgin
Islands
COVID-19 Telehealth Program
$521,816
$522,752
$1,043,244
$0
$0
Emergency Connectivity Fund
$4,148,000
$1,385,625,
$6,327,126
$103,569,086
$4,768,800
Source: GAO analysis of Federal Communications Commission data. | GAO-23-106050
Note: Allocation data were collected from the Federal Communications Commission’s website in
October 2022. Data were confirmed by the Federal Communications Commission in May 2023.
Appendix II: COVID-19 Relief Funding
Allocated to U.S. Territories by Program as
of May 2023
Page 54
GAO-23-106050 COVID-19
Table 11: Funding Allocated to U.S. Territories for Department of Health and Human Services COVID-19 Programs
Program Name
American
Samoa
Commonwealth of
the Northern
Mariana Islands
Guam
Puerto Rico
U.S. Virgin
Islands
ACL Assistive Technology
$80,000
$80,000
$80,000
$80,000
$80,000
ACL Centers for Independent Living
$154,427
$0
$0
$0
$0
ACL Independent Living State
Grants
$0
$0
$0
$0
$121,081
Activities to Support State, Tribal,
Local and Territorial Health
Department Response to Public
Health or Healthcare Crises
$583, 215
$699,772
$6,590,558
$10,162,773
$3,114,521
Behavioral Risk Factor Surveillance
System
$11,479
$0
$16,274
$11,479
$36,479
Block Grants for Community Mental
Health Services
$567,903
$578,080
$4,586,980
$33,335,403
$1,057,207
Block Grants for Prevention and
Treatment of Substance Abuse
$730,300
$744,210
$2,123,040
$39,858,551
$1,399,017
CDC’s Collaboration with Academia
to Strengthen Public Health
$2,975,316
$3,038,408
$4,268,572
$34,908,260
$3,602,578
Child Abuse and Neglect State
Grantsa
$31,825
$23,259
$70,949
$776,776
$36,654
Child Care and Development Funda
$66,793,659
$48,769,172
$96,245,107
$416,452,395
$50,517,062
Community Health Workers for
Public Health Response and
Resilient
$0
$1,200,000
$1,200,000
$0
$0
Community Services Block Grant
$1,300,126
$770,378
$1,229,850
$42,122,412
$1,699,646
Community-Based Child Abuse
Prevention Grants
$175,000
$175,000
$175,000
$1,910,286
$175,000
Developmental Disabilities Basic
Support and Advocacy Grants
$244,467
$223,221
$244,467
$95,319
$223,221
Emergency Grants to Address
Mental and Substance Use
Disorders During COVID-19
$0
$1,214,912
$1,995,318
$1,214,912
$0
Epidemiology and Laboratory
Capacity for Infectious Diseases
Cooperative Agreementa
$13,651,609
$14,609,159
$26,451,387
$369,548,085
$20,710,118
Family Planning Servicesa
$0
$0
$0
$0
$419,485
Family Violence Prevention and
Services/Discretionary
$278,357
$241,594
$241,594
$2,133,353
$241,594
Family Violence Prevention and
Services/Domestic Violence Shelter
and Supportive Services
$605,773
$562,188
$562,188
$4,611,483
$562,188
Appendix II: COVID-19 Relief Funding
Allocated to U.S. Territories by Program as
of May 2023
Page 55
GAO-23-106050 COVID-19
Program Name
American
Samoa
Commonwealth of
the Northern
Mariana Islands
Guam
Puerto Rico
U.S. Virgin
Islands
Family Violence Prevention and
Services/Sexual Assault/Rape
Crisis Services and Supports
$198,000
$198,000
$198,000
$1,818,069
$198,000
Grants to States for Loan
Replacement
$0
$205,500
$275,423
$0
$446,052
Head Start
$3,165,201
$688,836
$1,361,574
$10,049,274
$1,994,181
Health Center Program
(Community Health Centers,
Migrant Health Centers, Health
Care for the Homeless, and Public
Housing Primary Care)
$4,338,511
$0
$3,501,095
$0
$0
HIV Care Formula Grants
$0
$0
$20,000
$582,162
$50,000
Immunization Cooperative
Agreementsa
$3,371,292
$3,535,806
$5,063,863
$66,769,505
$3,920,979
Injury Prevention and Control
Research and State and
Community Based Programs
$0
$0
$0
$36,552
$0
Low-Income Home Energy
Assistance Program
$488,668
$372,119
$1,071,387
$26,594,708
$1,013,115
Maternal and Child Health Federal
Consolidated Programs
$0
$445,000
$0
$0
$890,000
Maternal, Infant and Early
Childhood Home Visiting Granta
$315,527
$315,527
$315,527
$734,520
$315,527
National Bioterrorism Hospital
Preparedness Program
$176,567
$176,352
$181,862
$1,127,286
$179,198
National Ebola Training and
Education Center
$0
$0
$0
$0
$179,198
National Family Caregiver Support,
Title III, Part E
$152,672
$152,672
$610,688
$3,126,211
$610,688
Promote the Survival and
Continuing Vitality of Native
American Languagesa
$0
$311,939
$311,939
$0
$0
Public Health Crisis Response
Cooperative Agreement
$ 1,583,532
$ 1,526,113
$ 2,575,396
$ 27,562,837
$2,018,043
Public Health Training Centers
Program
$0
$0
$0
$0
$2,574,418
Section 223 Demonstration
Programs to Improve Community
Mental Health Services
$0
$0
$3,651,771
$0
$0
Sexually Transmitted Diseases
Prevention and Control Grants
$0
$0
$0
$5,753,043
$3,000,000
Appendix II: COVID-19 Relief Funding
Allocated to U.S. Territories by Program as
of May 2023
Page 56
GAO-23-106050 COVID-19
Program Name
American
Samoa
Commonwealth of
the Northern
Mariana Islands
Guam
Puerto Rico
U.S. Virgin
Islands
Special Programs for the Aging,
Title III, Part B, Grants for
Supportive Services and Senior
Centers
$442,313
$520,923
$1,847,860
$8,246,998
$1,847,860
Special Programs for the Aging,
Title III, Part C, Nutrition Services
$1,115,287
$1,115,287
$4,179,505
$19,728,373
$4,179,505
Special Programs for the Aging,
Title III, Part D, Disease Prevention
and Health Promotion Services
$27,363
$27,363
$109,450
$500,006
$109,450
Special Programs for the Aging,
Title IV, and Title II, Discretionary
Projects
$249,706
$829,785
$829,785
$4,223,251
$249,706
Special Programs for the Aging,
Title VII, Chapter 2, Long Term
Care Ombudsman Services for
Older Individuals
$18,719
$18,719
$74,875
$342,778
$74,875
State Health Insurance Assistance
Program
$0
$0
$116,757
$116,757
$116,757
Stephanie Tubbs Jones Child
Welfare Services Program
$19,097
$7,457
$32,099
$497,821
$0
Substance Abuse and Mental
Health Services Projects of
Regional and National Significance
$250,000
$250,000
$250,000
$250,000
$250,000
Temporary Assistance for Needy
Familiesa
$494,816
$486,157
$893,483
$18,450,515
$733,912
Source: GAO analysis of Department of Health and Human Services data. | GAO-23-106050
Note: Allocation data were provided by the Department of Health and Human Services (HHS) as of
December 5, 2022. The allocation data were confirmed by HHS in May 2023.
aIn June 2023, the Fiscal Responsibility Act of 2023 provided for rescissions of unobligated funds in
this program. See Pub. L. No. 118-5, div. B, tit. I, 137 Stat. 10, 23-30 (2023). Therefore, the ultimate
allocation amounts may be reduced.
Appendix II: COVID-19 Relief Funding
Allocated to U.S. Territories by Program as
of May 2023
Page 57
GAO-23-106050 COVID-19
Table 12: Funding Allocated to U.S. Territories for Department of Homeland Security COVID-19 Programs
Program Name
American
Samoa
Commonwealth
of the Northern
Mariana Islands
Guam
Puerto Rico
U.S. Virgin
Islands
Disaster Relief Fund - Public Assistance
$14,658,472
$64,232,993
$57,962,320
$197,889,893
$113,079,443
Emergency Food and Shelter Program
$579,600
$358,800
$552,000
$5,625,818
$772,800
Emergency Management Performance
Grants
$517,604
$518,693
$560,758
$2,670,269
$538,431
Source: GAO analysis of Department of Homeland Security data. | GAO-23-106050
Note: Allocation data were collected between October 2022 and March 2023. The data were
confirmed by Department of Homeland Security in May 2023.
Table 13: Funding Allocated to U.S. Territories for Department of Housing and Urban Development COVID-19 Programs
Program Name
American
Samoa
Commonwealth
of the Northern
Mariana Islands
Guam
Puerto Rico
U.S. Virgin
Islands
Community Development Fund
$1,327,836
$1,369,763
$4,453,410
$66,191,759
$2,824,145
Emergency Housing Vouchers
$0
$2,392,590
$2,492,867
$7,710,814
$601,068
Homeless Assistance Grants
$1,066,142
$1,090,639
$3,360,550
$39,468,437
$1,658,089
Homelessness Assistance and
Supportive Services Program
$950,062
$1,692,522
$3,881,538
$81,623,024
$3,325,878
Housing for Persons with Disabilitiesa
$0
$0
$0
$32,979
$25,126
Housing Opportunities for Persons with
AIDS
$0
$0
$0
$1,216,014
$160,086
Project-Based Rental Assistancea
$0
$89,700
$42,060
$9,958,900
$801,347
Public Housing Operating Fund
$0
$0
$745,204
$42,771,226
$3,236,293
Tenant-Based Rental Assistancea
$0
$159,496
$1,158,426
$10,001,669
$669,060
Source: GAO analysis of Department of Housing and Urban Development data. | GAO-23-106050
Note: Allocation data were provided by the Department of Housing and Urban Development in
February 2023.
aIn June 2023, the Fiscal Responsibility Act of 2023 provided for rescissions of unobligated funds in
this program. See Pub. L. No. 118-5, div. B, tit. I, 137 Stat. 10, 23-30 (2023). Therefore, the ultimate
allocation amounts may be reduced.
Appendix II: COVID-19 Relief Funding
Allocated to U.S. Territories by Program as
of May 2023
Page 58
GAO-23-106050 COVID-19
Table 14: Funding Allocated to U.S. Territories for Department of the Interior COVID-19 Programs
Program Name
American
Samoa
Commonwealth
of the Northern
Mariana Islands
Guam
Puerto Rico
U.S. Virgin
Islands
Assistance to Territories
$5,857,325
$7,208,482
$12,039,565
$0
$7,863,776
Source: GAO analysis of Department of the Interior data. | GAO-23-106050
Note: Allocation data were collected in June 2022.Data were confirmed by the Department of the
Interior in March 2023.
Table 15: Funding Allocated to U.S. Territories for Institute of Museum and Library Services COVID-19 Programs
Program Name
American
Samoa
Commonwealth
of the Northern
Mariana Islands
Guam
Puerto Rico
U.S. Virgin
Islands
Grants to Statesa
$0
$215,903
$252,003
$2,973,345
$232,667
Source: GAO analysis of Institute of Museum and Library Services data. | GAO-23-106050
Note: Allocation data were collected from the Institute of Museum and Library Services’ website in
June 2022.
aIn June 2023, the Fiscal Responsibility Act of 2023 provided for rescissions of unobligated funds in
this program. See Pub. L. No. 118-5, div. B, tit. I, 137 Stat. 10, 23-30 (2023). Therefore, the ultimate
allocation amounts may be reduced.
Table 16: Funding Allocated to U.S. Territories for Department of Justice COVID-19 Programs
Program Name
American
Samoa
Commonwealth
of the Northern
Mariana Islands
Guam
Puerto Rico
U.S. Virgin
Islands
State and Local Law Enforcement
Assistance
$2,231,620
$1,509,123
$2,932,867
$8,823,415
$2,932,867
Source: GAO analysis of Department of Justice data. | GAO-23-106050
Note: Allocation data were collected from the Department of Justice’s website in June 2022.
Appendix II: COVID-19 Relief Funding
Allocated to U.S. Territories by Program as
of May 2023
Page 59
GAO-23-106050 COVID-19
Table 17: Funding Allocated to U.S. Territories for Department of Labor COVID-19 Programs
Program Name
American
Samoa
Commonwealth
of the Northern
Mariana Islands
Guam
Puerto Rico
U.S. Virgin
Islands
Administrative Funding for Pandemic
Unemployment Programs
$1,354,300
$9,796,423
$8,292,241
$74,046,433
$5,275,684
Benefits Funding for Emergency
Increase in Unemployment
Compensation Benefits/Federal
Pandemic Unemployment
Compensation
$10,200,000
$301,400,000
$485,900,000
$0
$0
Benefits Funding for Pandemic
Unemployment Assistance
$5,700,000
$405,029,600
$534,585,000
$0
$0
Dislocated Workers Assistance
National Reserve
$0
$1,500,000
$5,034,344
$0
$1,500,000
Emergency Increase in Unemployment
Compensation Benefits/Federal
Pandemic Unemployment
Compensation
$0
$0
$0
$7,223,737,775
$110,612,140
Emergency Unemployment Relief for
Governmental Entities and Nonprofit
Organizations
$0
$0
$0
$0
$727,480
Full Federal Funding of Extended
Unemployment Compensation for a
Limited Period (Benefit Payments)
$0
$0
$0
$9,868,925
$2,641,660
Mixed Earner Unemployment
Compensation
$0
$0
$0
$24,050,000
$300,000
Pandemic Emergency Unemployment
Compensation (Benefits Funding)
$0
$0
$0
$489,311,006
$27,425,401
Pandemic Unemployment Assistance
(Benefits Funding)
$0
$0
$0
$1,123,187,552
$33,462,704
Temporary Full Federal Funding of Full
Week of Compensable Regular
Unemployment for States with No
Waiting Week (Benefits Funding)
$0
$0
$0
$9,861,127
$2,641,660
Source: GAO analysis of Department of Labor data. | GAO-23-106050
Note: Allocation data were provided by the Department of Labor in February 2023.
Appendix II: COVID-19 Relief Funding
Allocated to U.S. Territories by Program as
of May 2023
Page 60
GAO-23-106050 COVID-19
Table 18: Funding Allocated to U.S. Territories for National Endowment for the Arts COVID-19 Programs
Program Name
American Samoa
Commonwealth of the
Northern Mariana Islands
Guam
Puerto Rico
U.S. Virgin
Islands
Arts Grantsa
$336,400
$171,900
$338,300
$1,230,200
$411,900
Source: GAO analysis of National Endowment for the Arts data. | GAO-23-106050
Note: Allocation data were collected from the National Endowment for the Arts’ website between
November 2022 and February 2023.
aIn June 2023, the Fiscal Responsibility Act of 2023 provided for rescissions of unobligated funds in
this program. See Pub. L. No. 118-5, div. B, tit. I, 137 Stat. 10, 23-30 (2023). Therefore, the ultimate
allocation amounts may be reduced.
Table 19: Funding Allocated to U.S. Territories for Department of Transportation COVID-19 Programs
Program Name
American Samoa
Commonwealth
of the Northern
Mariana Islands
Guam
Puerto Rico
U.S. Virgin
Islands
Highway Infrastructure Programsa
$951,897
$951,897
$3,807,588
$35,809,462
$3,807,588
Relief for Airportsa
$5,657,351
$764,746
$1,869,689
$37,377,249
$53,393,607
Transit Grants
$1,210,814
$1,137,836
$5,602,974
$328,159,105
$6,231,801
Source: GAO analysis of Department of Transportation data. | GAO-23-106050
Note: Allocation data were collected between May 2022 and March 2023. Data were confirmed by the
Department of Transportation in May 2023.
aIn June 2023, the Fiscal Responsibility Act of 2023 provided for rescissions of unobligated funds in
this program. Therefore, the ultimate allocation amounts may be reduced.
Table 20: Funding Allocated to U.S. Territories for Department of the Treasury COVID-19 Programs
Program Name
American
Samoa
Commonwealth of
the Northern
Mariana Islands
Guam
Puerto Rico
U.S. Virgin
Islands
Coronavirus Capital Projects Fund
$14,285,714
$14,285,714
$14,285,714
$158,310,056
$14,285,714
Coronavirus Relief Fund
$35,173,620
$36,284,218
$117,968,258
$2,240,625,864
$74,809,978
Coronavirus State and Local Fiscal
Recovery Funds
$494,990,988
$487,324,310
$603,843,132
$2,594,911,607
$547,176,884
Emergency Rental Assistance
Programsa
$18,029,532
$19,366,046
$62,564,965
$565,350,000
$39,689,455
Homeowner Assistance Fund
$3,732,211
$4,158,268
$13,587,562
$75,637,542
$8,521,959
State Small Business Credit
Initiativea
$57,553,073
$57,526,433
$59,243,899
$113,259,009
$58,381,658
Source: GAO analysis of Department of the Treasury data. | GAO-23-106050
Note: Allocation data were collected between May and October 2022. Data were confirmed by the
Department of the Treasury in May 2023.
aIn June 2023, the Fiscal Responsibility Act of 2023 provided for rescissions of unobligated funds in
this program. See Pub. L. No. 118-5, div. B, tit. I, 137 Stat. 10, 23-30 (2023). Therefore, the ultimate
allocation amounts may be reduced.
Appendix III: Comments from Government of
Puerto Rico
Page 61
GAO-23-106050 COVID-19
Appendix III: Comments from Government of
Puerto Rico
Appendix III: Comments from Government of
Puerto Rico
Page 62
GAO-23-106050 COVID-19
Appendix IV: Comments from the Office of the
Governor, American Samoa Government
Page 63
GAO-23-106050 COVID-19
Appendix IV: Comments from the Office of
the Governor, American Samoa Government
Appendix IV: Comments from the Office of the
Governor, American Samoa Government
Page 64
GAO-23-106050 COVID-19
Appendix IV: Comments from the Office of the
Governor, American Samoa Government
Page 65
GAO-23-106050 COVID-19
Appendix IV: Comments from the Office of the
Governor, American Samoa Government
Page 66
GAO-23-106050 COVID-19
Appendix IV: Comments from the Office of the
Governor, American Samoa Government
Page 67
GAO-23-106050 COVID-19
Appendix V: GAO Contact and Staff
Acknowledgments
Page 68
GAO-23-106050 COVID-19
Jeff Arkin at 202-512-6806 or arkinj@gao.gov
In addition to the contact named above, Alexandra Edwards (Assistant
Director), Kerstin Meyer (Analyst in Charge), Jose Altamirano, Mike
Bechetti, Joseph Carney, Shelby Kain, Amy Konstas, Krista Loose,
Latesha Love-Grayer, Steven Putansu, Tyler Spunaugle, Emily Tomsick
and Clarette Yen made key contributions to this report.
Appendix V: GAO Contact and Staff
Acknowledgments
GAO Contact
Staff
Acknowledgements
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