GAO-24-106152, COVID-19 Relief Funds: State Experience Could Inform Future Federal Relief Funding

Report — GAO-24-106152, COVID-19 Relief Funds: State Experience Could Inform Future Federal Relief Funding, dated 2023-10-31, issued by Government Accountability Office.

Full text

COVID-19 RELIEF
FUNDS
State Experiences
Could Inform Future
Federal Relief
Funding

Report to Congressional Committees
November 2023

GAO-24-106152

United States Government Accountability Office

 United States Government Accountability Office

Highlights of GAO-24-106152, a report to
congressional committees

November 2023
COVID-19 RELIEF FUNDS
State Experiences Could Inform Future Federal Relief
Funding
What GAO Found
Budget office staff in eight states told GAO they worked with state legislatures,
agencies, and other stakeholders to plan the use of COVID-19 relief funds. While
budget staff said state legislatures typically were responsible for appropriating
the funds, some legislatures allowed state officials to make or change plans
when the legislatures were not in session. Budget staff in selected states said
they were generally responsible for implementing newly created programs, while
state agencies implemented pre-existing programs. Staff also said they used
existing structures and processes to implement the funds, such as those for
natural disasters or reimbursement. According to state auditors, selected states
used existing processes to mitigate fraud and improper payments.
State budget staff told GAO they used a variety of actions to address challenges
when planning, using, and reporting on the COVID-19 relief funds.
•
Staff capacity challenges. Budget staff hired and reassigned staff, worked
with officials in state agencies, and used contractors to address capacity
challenges with using COVID-19 relief funds.
•
Timing of funding and guidance. Budget staff said that when additional
COVID-19 relief funding was provided or guidance on allowable uses was
delayed or changed, they waited to use these funds or substituted other
funds with overlapping allowable uses.
•
Communication and technical assistance challenges. Budget staff said
that federal agency officials addressed questions on program guidance and
the need for technical assistance by increasing information sharing and
working with national organizations representing states.
•
Compliance with reporting requirements. Budget staff leveraged existing
reporting systems or developed new systems to allow them to meet reporting
deadlines, address changes to reporting requirements, or provide data they
had not previously collected.
GAO identified several experiences from the selected states that could inform
future federal relief.
•
Leveraging pre-existing programs. Budget staff in some states said they
were often able to use funding for existing programs more efficiently by using
existing structures and processes. However, staff also noted that new, more
flexible programs were key to addressing the pandemic’s unique challenges.
•
Leveraging existing expertise and processes. States leveraged staff
expertise and processes from implementing previous significant federal
funding, such as from the American Recovery and Reinvestment Act of 2009,
to plan and use the COVID-19 relief funds. Additionally, some states said
their staff experience and capacity with the funds grew over time.
•
Establishing new units and processes for federal relief funds. Budget
staff said they established specific units and processes for COVID-19 relief
funds. They plan to leverage these units and processes for future federal
relief funds.
View GAO-24-106152. For more information,
contact Jeff Arkin at (202) 512-6806 or
arkinj@gao.gov.
Why GAO Did This Study
The federal government provided over
$4.6 trillion to help the nation respond
to the COVID-19 pandemic. A
substantial portion of that amount went
to state governments, which had to
manage the influx of federal relief and
quickly determine priorities to respond
to the public health and economic
emergency.
The CARES Act includes a provision
for GAO to conduct monitoring and
oversight of the use of funds made
available to prepare for, respond to,
and recover from the COVID-19
pandemic. This report describes (1)
how selected states planned for, used,
and reported on COVID-19 relief funds;
(2) challenges selected states
experienced in using COVID-19 relief
funds and any actions taken to address
those challenges; and (3) how the
experiences of the selected states
could inform future federal relief
funding.
This report is part of a series of reports
on COVID-19 relief funds to the states.
GAO reviewed previously issued
reports on individual COVID-19 relief
programs. GAO also interviewed
federal agency officials who
implemented COVID-19 relief
programs that received $10 billion or
more for Tribes, states, localities, and
U.S. territories.
GAO reviewed plans for the use of the
COVID-19 relief funds for eight
states—California, Florida, Illinois,
Minnesota, New York, Pennsylvania,
Texas, and Washington—and
interviewed staff from state budget
offices and auditor offices. GAO
selected these states based on total
COVID-19 relief funding, population
size, and geographic region.

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GAO-24-106152  COVID-19 Relief Funds
Letter

1
Background
5
Selected States Leveraged Various Entities and Processes to
Implement COVID-19 Relief Funds
10
Selected States Took Various Approaches to Address Challenges
in Planning, Using, and Reporting on COVID-19 Relief Funds
20
Selected State Experiences Using COVID-19 Relief Funding
Could Inform Future Federal Relief
31
Agency Comments and Third-Party Views
35
Appendix I
GAO Contact and Staff Acknowledgments
38

Table
Table 1: COVID-19 Relief Funding for Federal Programs that
Received $10 billion or More in Aid for Tribes, States, the
District of Columbia, Localities, and U.S. Territories
7

Figures
Figure 1: COVID-19 Relief Funding Data for Selected States from
USAspending.gov, as of October 31, 2023
4
Figure 2: Timeline of Funding Provided through the COVID-19
Relief Laws to States for Selected Programs
6
Figure 3: Screenshot of Washington Office of Financial
Management’s COVID-19 Website
19

Contents

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GAO-24-106152  COVID-19 Relief Funds

Abbreviations

ARPA

American Rescue Plan Act of 2021
DHS

Department of Homeland Security
DOT

Department of Transportation
FAQ

frequently asked questions
FEMA

Federal Emergency Management Agency
FTE

full-time equivalents
HHS

Department of Health and Human Services
Recovery Act
American Recovery and Reinvestment Act of 2009
USDA

U.S. Department of Agriculture

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GAO-24-106152  COVID-19 Relief Funds
441 G St. N.W.
Washington, DC 20548
November 15, 2023
Congressional Committees
The federal government has provided over $4.6 trillion to help the nation
respond to and recover from the COVID-19 pandemic.1 A substantial
portion of these funds went to state governments. We reported previously
that the federal government provided more than $1 trillion to federal
agencies to provide assistance to Tribes, states, the District of Columbia,
localities, and U.S. territories.2 During a time of national emergency, state
governments had to manage the influx of federal relief from multiple new
and existing funding streams and quickly determine priorities for the relief
funding.
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.3 This report is part of a series
of reports on COVID-19 relief funds to the states and focuses on state
experiences implementing COVID-19 relief funding. We reviewed (1) how
selected states planned for, used, and reported on COVID-19 relief funds
provided across selected programs; (2) challenges selected states
experienced in using COVID-19 relief funds across selected programs
and any actions taken to address those challenges; and (3) how the
experiences of the selected states could inform future federal relief
funding.

1This amount reflects appropriations, as well as transfers, adjustments, recoveries,
rescissions, and returns of unused indefinite appropriations. 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, 137
Stat. 10 (2023). The six COVID-19 relief laws are the American Rescue Plan Act of 2021
(ARPA), Pub. L. No. 117-2, 135 Stat. 4; 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.
2See GAO, COVID-19: Current and Future Federal Preparedness Requires Fixes to
Improve Health Data and Address Improper Payments, GAO-22-105397, appendix 25
(Washington, D.C.: Apr. 27, 2022).
3Pub. 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-24-106152  COVID-19 Relief Funds
To address all three objectives, we reviewed reports examining individual
COVID-19 relief programs that were issued by us, the Pandemic
Response Accountability Committee, relevant federal agency inspectors
general, and national organizations representing state governments. We
interviewed agency officials at the Departments of Education, Health and
Human Services, Homeland Security, Transportation, and the Treasury
about states’ experiences and challenges in planning, using, and
reporting on individual COVID-19 programs and funds and actions taken
to address the challenges. We selected these departments because they
received $10 billion or more in COVID-19 relief for programs and funds to
Tribes, states, localities, and U.S. territories.4 For the purposes of this
report, we excluded Medicaid and Unemployment Insurance from our
selected programs.5 We also met with officials from national organizations
that represent state governments.6
To report on states’ experiences planning for, using, and reporting on
COVID-19 relief funding, we selected eight states—California, Florida,
Illinois, Minnesota, New York, Pennsylvania, Texas, and Washington. We
selected these eight states because they represent
•
various geographic regions within the U.S.;

4The individual programs and funds received $10 billion or more in at least one of the six
COVID-19 relief laws. The COVID-19 relief laws provided funding to new and existing
programs and funds. For the purposes of this report, we refer to both programs and funds
that received COVID-19 relief funds as programs.
5We excluded appropriations in the COVID-19 relief laws that increased or created new
annual mandatory funding, or that extended the period of availability for prior funds.
Several provisions in the Families First Coronavirus Response Act and the American
Rescue Plan Act of 2021 authorized increases in Medicaid payments to states and U.S.
territories. The increase to federal Medicaid spending is based on a temporary funding
formula change rather than a specific appropriated amount. Similarly, the COVID-19 relief
laws did not provide a specific appropriated amount for Unemployment Insurance.
Instead, several provisions in the COVID-19 relief laws authorized, for example,
Unemployment Insurance benefits for individuals not otherwise eligible for Unemployment
Insurance benefits and an additional weekly benefit for individuals who were eligible for
weekly benefits under the permanent Unemployment Insurance programs and the
temporary CARES Act Unemployment Insurance programs.
6We spoke with officials from the National Association of State Auditors, Comptrollers, and
Treasurers; the National Association of State Budget Officers; the National Conference of
State Legislatures; and the National Governors Association.

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GAO-24-106152  COVID-19 Relief Funds
•
the largest total COVID-19 relief funding obligated to states within
their respective geographic region, based on data downloaded from
USAspending.gov on November 3, 2022;7 and
•
the largest total population size among states in their respective
geographic regions, based on data downloaded from
USAspending.gov on November 3, 2022.8
Figure 1 provides specific location, population, and funding information for
the eight selected states. These selection criteria aligned with a similar
methodology used in our other COVID-19 relief work focused on states’
experiences.9

7USAspending.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 past work we identified that
the quality of data on USAspending.gov varies by federal agency. We chose to use
USAspending data in this report because they are widely available to the public and we
determined they were sufficiently reliable for our purposes in state selection criteria. See
GAO, Federal Spending Transparency: OIGs Identified a Variety of Issues with the Quality
of Agencies’ Data Submissions, GAO-22-105427 (Washington, D.C.: Jul. 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).
8In instances where the state with the largest total COVID-19 relief funding obligation and
population size were the same, we selected the state with the second largest total COVID-
19 relief funding obligation in a geographic region.
9States selected in our forthcoming work on states’ uses of the Coronavirus State and
Local Fiscal Recovery Funds represent a range of populations, unemployment rates,
geographic regions, and Coronavirus State and Local Fiscal Recovery Funds allocations
received. Collectively, the selected states for that work represent about 60 percent of the
U.S. population and were allocated about 60 percent of the Coronavirus State and Local
Fiscal Recovery Fund allocations provided to states.

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GAO-24-106152  COVID-19 Relief Funds
Figure 1: COVID-19 Relief Funding Data of Selected States from USAspending.gov, as of October 31, 2023

Notes: USAspending.gov information provided by place of performance. Information on
USAspending.gov is based on data provided by federal agencies. In prior work, the Offices of
Inspector Generals determined that the reliability of data submitted to USAspending.gov varied. See
GAO-22-105427. The six COVID-19 relief laws are the American Rescue Plan Act of 2021 (ARPA),
Pub. L. No. 117-2, 135 Stat. 4; 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. Numbers for population are rounded to the nearest hundred thousand, numbers
for total relief are rounded to the nearest billion, and numbers for relief per capital are rounded to the
nearest dollar.

For the eight selected states, we reviewed reports and other documents
on each state’s plans for using COVID-19 relief funding. We also
reviewed available state single audit reports for fiscal years 2020 to

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GAO-24-106152  COVID-19 Relief Funds
2022.10 We interviewed staff from the selected states’ budget offices,
COVID-19 recovery offices, governor’s offices, grants management
offices, state auditor offices, and other relevant legislative and program
offices. The interviews covered the states’ experiences, challenges, and
actions taken to address challenges in planning for, using, and reporting
on COVID-19 relief funds received across programs. We use the terms
“some” and “several” throughout this report when at least three states
raised a particular challenge or action. To identify and describe state
experiences that could inform future federal relief funding to states, we
conducted a content analysis of interviews with federal agency officials
and staff from the eight states.
We conducted this performance audit from July 2022 to November 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 COVID-19 pandemic had a rapid and severe effect on the U.S.
economy. Early in the pandemic, state and local governments
experienced fiscal pressures resulting from changes in revenues and
expenditures.11 To address the public health and economic effects posed
by the COVID-19 pandemic, Congress passed, and the President signed,
six COVID-19 relief laws, totaling over $4.6 trillion of federal funding (see
fig. 2).

10A single audit is an audit of an entity’s financial statements and federal awards, or a
program-specific audit. Nonfederal entities that receive federal awards are required to
undergo single audits (or, in limited circumstances, program-specific audits) of those
awards annually (unless a specific exception applies) when they spend at least $750,000
in federal awards in their fiscal year. 2 C.F.R. pt.200.
11See GAO, State and Local Governments: Fiscal Conditions During the COVID-19
Pandemic in Selected States, GAO-21-562 (Washington, D.C.: July 15, 2021).
Background

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GAO-24-106152  COVID-19 Relief Funds
Figure 2: Timeline of Funding Provided through the COVID-19 Relief Laws to States
for Selected Programs

aPub. L. No. 116-123, 134 Stat. 146 (2020).
bPub. L. No. 116-127, 134 Stat. 178 (2020).
cPub. L. No. 116-136, 134 Stat. 281 (2020).
dPub. L. No. 116-139, 134 Stat. 620 (2020).
ePub. L. No. 116-260, 134 Stat. 1182 (2020).
fPub. L. No. 117-2, 135 Stat. 4 (2021).

More than $1 trillion of these funds were appropriated to federal agencies
to provide assistance related to the COVID-19 pandemic to Tribes, states,

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GAO-24-106152  COVID-19 Relief Funds
the District of Columbia, localities, and U.S. territories.12 The table below
lists 13 programs that each received $10 billion or more exclusively or
primarily for Tribes, states, the District of Columbia, localities, and U.S.
territories in at least one of the six laws (see table 1).
Table 1: COVID-19 Relief Funding for Federal Programs that Received $10 billion or More in Aid for Tribes, States, the District
of Columbia, Localities, and U.S. Territories
Program
Description
Appropriation
 ($ in billions)

Coronavirus State
and Local Fiscal
Recovery Fund
Administered by the 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, among other
things.

350

Elementary and
Secondary School
Emergency Relief
Fund
Administered by the Department of Education, this fund generally
provides formula grants to states (including the District of
Columbia and Puerto Rico) for education-related needs to
address the impact of the COVID-19 pandemic.

190.3a

Coronavirus Relief
Fund
Administered by 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.

150

Disaster Relief Fund 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.

95b

12This total is based on (1) an analysis of the appropriated amounts in the six COVID-19
relief laws that are available to agencies for assistance to Tribes, states, the District of
Columbia, localities, and U.S. territories; and (2) the Congressional Budget Office’s
estimated outlays for Medicaid resulting from authorized increases in payments to states
and U.S. territories under those laws. 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, 137 Stat. 10 (2023).

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GAO-24-106152  COVID-19 Relief Funds
Program
Description
Appropriation
 ($ in billions)

Medicaidc
Administered by states and U.S. territories according to plans
approved by the Centers for Medicare & Medicaid Services,
which oversees Medicaid at the federal level. This program
finances health care for certain low-income and medically needy
individuals through federal matching of states’ and U.S.
territories’ health care expenditures. The Families First
Coronavirus Response Act and the American Rescue Plan Act of
2021 temporarily increased federal Medicaid matching rates
under specified circumstances, among other changes.
76.9

Transit Grants
Administered by the Federal Transit Administration, these funds
are distributed through existing grant programs to provide
assistance to Tribes, states, localities, and U.S. territories to
prevent, prepare for, and respond to the COVID-19 pandemic.

69.5

Child Care and
Development Fundd
Administered by the Department of Health and Human Services
(HHS), this fund 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 regards to income eligibility
requirements. Additional funding was provided for subgrants to
eligible child care providers to support the stability of the child
care sector during and after the COVID-19 pandemic.
52.5a

Emergency Rental
Assistance
Administered by 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, and other expenses related to housing and
housing stability services.e
46.6a

Public Health and
Social Services
Emergency Fund
Administered by HHS, this fund provides for grants to Tribal
governments, states, U.S. territories, and localities to support
COVID-19 testing, surveillance, and contact tracing, among other
uses.

33.4a

Airport Grantsf
Administered by the Federal Aviation Administration, these
grants provide funds for eligible airports to prevent, prepare for,
and respond to the effects of the COVID-19 pandemic.

20

Highway
Infrastructure
Administered by the Federal Highway Administration, these
programs provide funds to Tribal governments, states, the District
of Columbia, and U.S. territories for highway construction and
authorize the use of these funds for maintenance, personnel, and
other purposes to prevent, prepare for, and respond to the
COVID-19 pandemic.
10a

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Program
Description
Appropriation
 ($ in billions)

Coronavirus Capital
Projects Fund
Administered by 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.

10a

State Small
Business Credit
Initiative
Administered by Treasury, this program provides funds to Tribal
governments, states, the District of Columbia, and U.S. territories
to fund small business credit support and investment programs
and to provide technical assistance to eligible small businesses.

10a
Source: GAO analysis of federal laws and data from the Congressional Budget Office; GAO (icons). | GAO-24-106152
Note: The COVID-19 relief laws providing the appropriations shown are the American Rescue Plan
Act of 2021 (ARPA), Pub. L. No. 117-2, 135 Stat. 4 (2021), the Consolidated Appropriations Act,
2021, Pub. L. No. 116-260, div. M and N, 134 Stat. 1182 (2020), the Paycheck Protection Program
and Health Care Enhancement Act, Pub. L. No. 116-139, 134 Stat. 620 (2020), the CARES Act, Pub.
L. No. 116-136, 134 Stat. 281 (2020), and the Families First Coronavirus Response Act, Pub. L. No.
116-127, 134 Stat. 178 (2020). The Coronavirus Preparedness and Response Supplemental
Appropriations Act, 2020, Pub. L. No. 116-123, 134 Stat. 146, did not provide any specified amounts
for these programs or funds for Tribal governments, states, the District of Columbia, localities, or U.S.
territories. The amounts shown are the cumulative amounts for each program or fund under the other
five laws. Some appropriation amounts include an amount available for administration expenses or
for the relevant federal agency inspector general. The amounts do 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, 137 Stat. 10 (2023).
aThe Fiscal Responsibility Act of 2023 rescinded certain unobligated funds provided to these COVID-
19 relief programs. See Pub. L. No. 118-5, 137 Stat. 10 (2023).
bAppropriations for the Disaster Relief Fund generally are not specific to individual disasters and may
be used for various disaster assistance programs, including the Public Assistance program, which
provides assistance to Tribal, state, local, and territorial governments.
cSeveral provisions in the Families First Coronavirus Response Act and ARPA authorized increases
in Medicaid payments to states and U.S. territories. The Congressional Budget Office estimated that
federal expenditures from these provisions would be approximately $76.9 billion through fiscal year
2030. The largest increase to federal Medicaid spending is based on a temporary funding formula
change rather than a specific appropriated amount. Some of the estimated costs in this total are for
the Children’s Health Insurance Program, permanent changes to Medicaid, and changes not
specifically related to COVID-19.
dThe Child Care and Development Fund is made up of two funding streams: mandatory and matching
funding authorized under section 418 of the Social Security Act and discretionary funding authorized
under the Child Care and Development Block Grant Act of 1990, as amended. See 42 U.S.C. §§ 618,
9858m.
eEmergency 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
provides assistance to cover the costs of other affordable rental housing and eviction prevention
activities for eligible households.
fFunds are available to eligible sponsors of airports. Nearly all of these airports are under city, state,
county, or public-authority ownership.

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As the selected states planned for and used their COVID-19 relief funds,
the roles of the state legislatures, budget offices, and state agencies
involved varied.
•
Role of state legislatures. In all the selected states, state
legislatures were responsible for appropriating COVID-19 relief
funds—within program requirements—through state budget
processes. However, the legislatures had varying roles in planning the
use of the funds, according to budget office staff. For example, budget
office staff in Pennsylvania told us that the General Assembly planned
the use of all of the state’s COVID-19 relief funds. In Illinois, state
budget office staff told us that the state legislature helped decide how
certain award amounts for new programs—including the Coronavirus
Relief Fund and the Coronavirus State and Local Fiscal Recovery
Funds—would be used. However, they were not as involved in
planning how funds from other programs would be used. State budget
office staff in California, Florida, New York, Texas, and Washington
told us that their state legislatures worked with various groups—the
Governor’s Office, the state budget office, and relevant state
agencies—to provide input on, and plan the use of, the COVID-19
relief funds.
•
Role of state budget offices. Budget office staff in selected states
said their offices had differing levels of involvement in planning for,
using, and reporting on the COVID-19 relief funds. Budget office staff
told us that they were typically responsible for ensuring the best use
of COVID-19 relief funds by providing the state legislature, the
governor’s office, and state agencies with information about the funds,
their allowable uses, and other specific requirements.
Budget staff told us they were responsible for managing and reporting
on the COVID-19 relief funds provided through newly created
programs, such as the Coronavirus Relief Fund, the Coronavirus
Capital Projects Fund, and the Coronavirus State and Local Fiscal
Selected States
Leveraged Various
Entities and
Processes to
Implement COVID-19
Relief Funds
Selected States
Leveraged Various Entities
to Plan for, Use, and
Report on COVID-19
Relief Funds

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GAO-24-106152  COVID-19 Relief Funds
Recovery Funds. Additionally, state budget office staff in California
told us they worked with the state’s Office of Emergency Services to
manage and track COVID-19 response costs that would be
reimbursed through the Disaster Relief Fund’s Public Assistance
program. Budget office staff in New York told us their office was
responsible for centrally managing their state’s applications for
reimbursements related to COVID-19 from the Disaster Relief Fund’s
Public Assistance Program.
Budget office staff we spoke with were not directly involved in COVID-
19 relief funds that went to pre-existing federally funded programs.
However, budget office staff said they were responsible for managing
the interactions between the COVID-19 relief funds, including
tracking, monitoring, and reporting on the funds.
•
Role of state agencies. State agencies were typically responsible for
planning, using, and reporting on the COVID-19 relief funds that went
to pre-existing or agency specific programs, according to budget office
staff from selected states. These programs included the Child Care
and Development Fund, the Elementary and Secondary School
Emergency Relief Fund, the Public Health and Social Services
Emergency Fund, and Transit Grants. According to some budget staff,
state agencies were familiar with the pre-existing programs and
reporting requirements and were able to leverage both their existing
relationships with federal agency staff and processes for using and
reporting on the federal funds.
Budget office staff in the selected states also reported establishing
additional groups within and outside of their offices that were involved in
the planning process for the COVID-19 relief funds.
•
COVID-19 planning groups established within state budget
offices. Florida Governor’s Office of Policy and Budget staff told us
they established a COVID-19 unit to coordinate across all the relief
funding. The unit regularly communicated with state agencies and the
state legislature about how Florida would use its COVID-19 relief
funding. New York Division of the Budget staff said they established a
steering committee that consisted of both unit budget analysts and
leadership, such as the unit chiefs for Health, Public Safety, and
Human Services. The steering committee was responsible for
prioritizing the state’s COVID-19 response expenses to identify the
best federal relief funds to use.

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•
COVID-19 planning groups established outside of state budget
offices. In Washington, the governor created several task forces to
gather and share pandemic-related information with the governor’s
office and the state legislature, according to budget office staff. The
task forces consisted of officials from Tribal, state, and local
governments; subject matter experts in areas such as public health
and workforce support; and representatives of other relevant groups.
Minnesota Management and Budget staff said the governor
established several working groups across agencies. The working
groups focused on quickly gathering and sharing information in areas
including COVID-19 testing, vaccination, hospital surge capacity, food
security, and child care. The groups also requested state COVID-19
relief funding for the needs they identified. Budget office staff in Illinois
told us that their office established an informal COVID-19 committee
that interpreted the federal rules for the Coronavirus Relief Fund.
According to budget staff in Illinois, the informal COVID-19 committee
consisted of representatives from the Education and Public Safety
Unit and the Economic Development Unit within the budget office, as
well as staff from the Illinois Emergency Management Agency.
Budget office staff in Pennsylvania and Governor’s Office staff in Texas
told us their states did not establish new groups or use a formalized
process for planning their state’s use of the COVID-19 relief funds.
Governor’s Office staff in Texas told us the Governor’s Office held
informal meetings with state agencies to discuss plans for using the
COVID-19 relief funds. Additionally, Texas established working groups to
help manage the administrative aspects of the COVID-19 relief funding.
State legislatures were typically responsible for appropriating funds
through each state’s budget process, but some state budget office staff
told us they used new or existing processes to plan for and use the
COVID-19 relief funds when their legislatures were not in session.13
•
COVID-19 specific flexibilities granted through state budget acts.
The California Legislature used state budget acts to grant the
governor the flexibility to change state allocations for specific funding
without needing to coordinate with the legislature to pass a
supplemental appropriation.14 To increase funding programs over $1
billion, the administration needed to coordinate with the legislature to

13State legislative calendars vary. See
https://www.ncsl.org/about-state-legislatures/2020-state-legislative-session-calendar.
14Cal. Assem. Bill No. 128 (2021-2022 Reg. Sess.); Cal. Sen. Bill No. 154 (2022-2023
Reg. Sess.).
Some Selected States
Leveraged New or
Existing Legislative
Flexibilities to Use COVID-
19 Relief Funds

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GAO-24-106152  COVID-19 Relief Funds
pass supplemental appropriations, according to budget office staff in
California. Budget office staff in New York told us the legislature
granted the governor’s office the authority to spend the COVID-19
relief funds provided through the CARES Act at the governor’s
discretion in the state’s fiscal year 2021 budget, which allowed the
governor to make changes to the use of the early COVID-19 relief
funds as needed.
•
Legislative notification and review processes. The Minnesota
Legislature established a COVID-19 Response Commission, which
reviewed the Governor’s requests for spending over a certain
threshold, according to Minnesota Management and Budget staff.15
Texas Governor’s Office staff told us that their state budget allows the
Governor’s Office and the state legislature to spend federal funds
received in between legislative sessions with notification to the
legislature.16 Washington Office of Financial Management staff told us
that they leveraged their statutory “unanticipated receipts” process,
which they said allows state agency heads to submit spending
requests to the Governor and legislature for needs they did not
anticipate or include in the approved state budget. 17 Additionally,
when the legislature is not in session, staff told us Washington state
law grants the Governor the authority to approve the use of the
unanticipated receipts.18
Budget office staff told us that they leveraged existing state structures
and processes to quickly use the COVID-19 relief funds to respond to the
pandemic.
•
Leveraging existing natural disaster response staff and
structures. Budget office staff in California told us that state agencies
redirected some of their staff and existing emergency relief teams to
manage different COVID-19 relief programs. California state agencies
also hired contractors to help provide on-the-ground pandemic
response and assist in managing the state’s Disaster Relief Fund’s

152020 Minn. Laws 5. The legislature directed the Legislative COVID-19 Response
Commission to review expenditures exceeding $2.5 million. 2021 Minn. Laws 48.
162021 Tex. Gen. Laws IX-63. See Texas Government Code for additional information on
the Governor and Legislature’s authority to affect appropriations. Tex. Gov’t Code. Ann.  §
317 (2019).
17Wash. Rev. Code § 43.79.270 (2021).
18Wash. Rev. Code § 43.79.280 (2021). According to budget office staff, the Washington
State legislature is given 10 days to review requests prior to approval.
Selected States Generally
Leveraged Existing
Structures and Processes
When Using COVID-19
Relief Funds and
Mitigating Improper
Payments

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GAO-24-106152  COVID-19 Relief Funds
Public Assistance program applications. In Florida, budget office staff
told us that the Governor’s office worked with the state’s Division of
Emergency Management, Department of Health, and Department of
Economic Opportunity to identify pandemic response needs.
•
Leveraging reimbursement processes. Budget staff in Florida and
Illinois, as well as Governor’s Office staff in Texas, told us they used
reimbursement processes to provide COVID-19 relief funds to state
agencies and other recipients. For example, Illinois budget staff said
the reimbursement process allowed their office and the Governor’s
office to review COVID-19 expenditures and identify allowable uses of
the funds for reimbursement. Budget staff in Florida stated that they
leveraged processes the state required for all grant and contract
agreements funded with state or federal assistance. These processes
include monitoring and documenting contract recipient performance
and documenting contract deliverables prior to issuing payments.19
•
Leveraging existing improper payment processes and strategies.
States generally used existing fraud and improper payment mitigation
processes for COVID-19 relief funding, according to budget office staff
and state auditors.20 For example, state budget office staff in Illinois
told us that they leveraged pre and post award review for all awards,
including those funded with COVID-19 relief funds.21 Budget office
staff in Florida also told us they followed the state’s statutory
requirements for all contracts, grant agreements, and payment
processing to help reduce improper payments across all programs
and funding sources.
Some state auditors told us that the influx of COVID-19 funding
exacerbated existing internal control deficiencies or created new
issues with monitoring and reporting on the use of the funds by state

19Fla. Stat. §§ 215.971, 287.057(15), 287.058, 17.03 (2023).
20Improper payments are payments that should not have been made or were made in the
incorrect amount, and may suggest that a program is vulnerable to fraud. While an
improper payment may be the result of fraudulent activity, not all improper payments are
the result of fraud. Fraud involves obtaining something of value through willful
misrepresentation. The judicial or other adjudicative system determines whether an act is
fraud.
21These reviews are in response to the state’s Grant Accountability and Transparency Act
and are intended to increase the accountability and transparency in the use of grant funds.
Illinois’ Grant Accountability and Transparency Act required the adoption of federal
guidance and regulations applicable to federal grant funds, such as the Uniform
Administrative Requirements, Cost Principles, and Audit Requirement for Federal Awards,
codified at 2 C.F.R. pt. 200. 30 Ill. Comp. Stat. 708 (2014).

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GAO-24-106152  COVID-19 Relief Funds
agencies and subrecipients.22 Florida’s Chief Inspector General’s
Office told us it created a two-part risk readiness review for all COVID-
19 relief funds distributed to all state agencies. The risk readiness
reviews were used to assess the status of internal controls within
state agencies. Pennsylvania developed new oversight systems and
internal controls to address fraud and improper payments for some
programs that received COVID-19 relief funds, budget office staff
said. The staff are discussing incorporating the new oversight
measures and internal controls into the state’s fiscal year 2024 budget
act.
Generally, budget office staff told us that they had to balance quickly
distributing the COVID-19 relief funds with ensuring that their approach
was the best use of funds. Additionally, budget staff said that, as new
federal laws provided additional COVID-19 relief funds, they would
consider the interactions between funds with similar allowable uses. They
said they would make changes to what funds would be used to support
specific pandemic response and economic recovery activities, as needed.
•
Changes to state plans for the use of COVID-19 relief funds.
Washington Office of Financial Management staff told us the state
changed its plans for using federal funds and tapped into state funds
when updates to allowable uses or requirements for the federal funds
created a funding gap. Additionally, budget office staff in New York
said that the flexibilities the state legislature granted the governor’s
office in the first state budget during the pandemic allowed the
governor’s office to make changes to the state’s planned uses of the
COVID-19 relief funds as necessary.
Budget office staff from some states told us that they may have to
continue to change plans due to delays or concerns about fully
spending the funds by expenditure deadlines. For example,
Washington Office of Financial Management staff said that they are
experiencing delays in construction for some projects using funds
from the Coronavirus State and Local Fiscal Recovery Funds and the
Coronavirus Capital Projects Fund. They attributed these delays to
factors such as inflation, supply chain challenges, the federal plan
approval process, and the seasonality of construction. They added
that while the state may revise its budget to use flexibilities to swap

22A subrecipient is a nonfederal entity that receives a subaward from a pass-through entity
to carry out part of a federal program, but does not include an individual that is a
beneficiary of such program. A subrecipient may also be a recipient of other federal
awards directly from a federal awarding agency. 2 C.F.R. § 200.1.
Selected States Changed
Their Plans for Using
COVID-19 Relief Funds as
New Funds Became
Available, Guidance
Evolved, and Needs
Changed

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GAO-24-106152  COVID-19 Relief Funds
certain relief funds in the case of project delays, it may be challenging
to use all of its COVID-19 relief funds correctly within current
deadlines.
•
Changes to guidance for state match requirements. Over the
course of the pandemic, the President issued several memorandums
that directed the Federal Emergency Management Agency (FEMA) to
reimburse state governments and other eligible recipients for all work
eligible for emergency protective measures assistance for the
Disaster Relief Fund’s Public Assistance program.23 These
memorandums resulted in changes to the federal Disaster Relief
Fund’s Public Assistance program’s reimbursement rate from 75
percent to 100 percent for related costs incurred through July 1,
2022.24 In response, budget office staff in some of the selected states
made changes to their initial plans for other COVID-19 relief. The
changes to state-match requirements for the Disaster Relief Fund’s
Public Assistance program allowed the states to maximize the use of
other COVID-19 relief funds for other programs and state needs,
according to some state budget office staff.
•
Pivoting to supporting recovery activities. Texas Governor’s Office
staff told us they provided support to state and local agencies when
using the COVID-19 relief funding for long-term recovery efforts. For
example, staff told us the state legislature passed bills requiring
schools to pursue specific actions, such as tutoring, to support long-
term recovery in education.

23The Disaster Relief Fund’s Public Assistance program provides federal disaster
recovery assistance when a major disaster occurs. For additional information on the
federal share provided to states for the Disaster Relief Fund’s Public Assistance program,
see White House, Memorandum on Maximizing Assistance to Respond to COVID-19,
Memorandum for the Secretary of Homeland Security, the Administrator of the Federal
Emergency Management Agency (Mar. 1, 2022); Memorandum for the Secretary of
Homeland Security and the Administrator of the Federal Emergency Management Agency
on Maximizing Assistance to Respond to COVID-19 (Nov. 9, 2021); Memorandum on
Maximizing Assistance to Response to COVID-19 (Aug. 17, 2021); and Memorandum on
Maximizing Assistance from the Federal Emergency Management Agency (Feb. 2, 2021).
24See White House, Memorandum on Maximizing Assistance to Respond to COVID-19,
Memorandum for the Secretary of Homeland Security, the Administrator of the Federal
Emergency Management Agency (Mar. 1, 2022). The Consolidated Appropriations Act,
2022, directed the federal share of assistance for the COVID-19 disaster declarations to
be at least 90 percent for eligible costs. Pub. L. No. 117-103, § 311, 136 Stat. 331 (2022).
FEMA said it will apply the 90 percent federal cost share to funding for all eligible costs for
work performed and items used on or after July 2, 2022. See FEMA, Coronavirus (COVID-
19) Pandemic: Public Assistance Programmatic Deadlines, FEMA Policy #104-22-0002
(June 13, 2020).

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GAO-24-106152  COVID-19 Relief Funds
Some state budget office staff told us that their states developed new
structures and groups to support efforts to move from pandemic response
to economic recovery and better prepare for future federal funding.
•
Establishing groups focused on economic recovery from COVID-
19. Washington created the Washington Resilience Group to help set
long-term priorities and strengthen service delivery and customer
support in some state systems. Additionally, the Washington
legislature established the Pandemic After Action Report Task Force
to conduct a comprehensive review of state-wide pandemic response
and recovery.25 Florida’s Re-Open Florida Task Force was composed
of groups and representatives from sectors that would likely be most
impacted by the state’s public health emergency declaration and state
of emergency, such as education and health care.26 Budget office
staff in Florida told us that they met regularly with the state’s
investment board to discuss the state’s financial outlook, develop
plans to respond to a potential recession, and how the use of the
COVID-19 relief funds might be affected.
•
Establishing new units to manage federal funds. Some selected
states recognized a need for new centralized management of federal
funds. Minnesota established a COVID-19 Response Accountability
Office, which tracks and monitors COVID-19-related state
appropriations and federal funds. The office coordinated with state
agencies and budgeting and accounting divisions within Minnesota
Management and Budget to administer COVID-19 relief funding and
ensure the state complied with reporting requirements.
California budget office staff said they created the Federal Funds
Accountability and Cross Tracking Unit within the Department of
Finance. According to budget office staff in California, the new unit
was responsible for tracking, reporting, and providing oversight on the
spending of the Coronavirus State and Local Fiscal Recovery Funds.
The unit also tracked the receipt and expenditure of other COVID-19
relief funds by state agencies. Staff told us this unit assists in
determining the allowable uses across and between different COVID-
19 relief programs. Budget office staff plan to use the unit to

252021 Was. Sess. Laws 102.
26For additional information on Florida’s plans for recovery, see Re-Open Florida Task
Force, Safe. Smart. Step-by-Step.: Plan for Florida’s Recovery (Apr. 29, 2020).

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GAO-24-106152  COVID-19 Relief Funds
coordinate other funding provided through the Infrastructure
Investment and Jobs Act and the Inflation Reduction Act of 2022.27
Some states used websites to publicly display information detailing the
use of COVID-19 relief funds. The entities involved in managing these
websites differed in the selected states. For example, budget office staff
in California and Pennsylvania said that they developed their state’s
COVID-19 websites using data provided by state agencies on their
COVID-19 relief awards and expenditures. Washington’s Office of
Financial Management manages the state’s COVID-19 website that
includes annual recovery plans and data on how the COVID-19 relief
funds were allocated by the budget office or appropriated by the
legislature (see fig. 3).

27Infrastructure Investment and Jobs Act, Pub. L. No. 117-58, 135 Stat. 429 (2021);
Inflation Reduction Act of 2022, Pub. L. No. 117-169, 136 Stat. 1818 (2022).
Selected States Publicly
Reported on the Use of
COVID-19 Relief Funds

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GAO-24-106152  COVID-19 Relief Funds
Figure 3: Screenshot of Washington Office of Financial Management’s COVID-19
Website

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GAO-24-106152  COVID-19 Relief Funds
Florida state agencies modified internal data systems to tag all budget
information related to COVID-19, budget office staff said. These changes
allowed the staff to internally track the funds and display the information
across state websites. New York Division of the Budget staff said their
office expanded its Open Budget website to include a section on its
federal COVID-19 awards and spending.28 Staff told us the division is
responsible for gathering various state agency information that supports
the state’s COVID-19 website. They said they are working with a
consultant to review information displayed and plan to update and
maintain the content of the Open Budget website.

Budget office staff in Illinois, Minnesota, New York, Pennsylvania, and
Washington told us their offices did not have sufficient administrative
capacity within their pre-existing grants management and program
administration structures to plan for, use, and report on the large amount
of COVID-19 relief funds. For example, New York Division of the Budget
staff said prior to the pandemic, the division’s role was limited to the
review of federal legislation, award tracking, and conducting the state’s
federal single audit. Minnesota Management and Budget staff told us that
the aging workforce and a wave of retirements triggered by the pandemic
exacerbated staffing challenges. Florida Office of Policy and Budget staff
said that Florida’s Department of Health struggled to handle over 20
federal grants with varying reporting requirements, which led the agency
to hire additional staff to increase its capacity.
Some budget office staff told us they experienced challenges including
hiring, training new staff, and acquiring the technology and infrastructure

28See https://openbudget.ny.gov/covid-funding/federal-overview.html.
Selected States Took
Various Approaches
to Address
Challenges in
Planning, Using, and
Reporting on COVID-
19 Relief Funds
Selected States Hired and
Reassigned Staff,
Collaborated with State
Agencies, and Used
Contractors to Address
Capacity Challenges

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GAO-24-106152  COVID-19 Relief Funds
to manage the funds.29 For example, New York Division of the Budget
staff told us that the state initially froze hiring during the pandemic
because of economic uncertainty. The freeze was lifted in late 2021, but
staff said that New York is still struggling to hire new staff and, as of April
2023, was operating with over 10,000 less full-time equivalents (FTE)
than the state was operating with at the start of the pandemic. In
Washington, statewide workforce shortages made it difficult for state
agencies to hire new specialist staff, according to budget office staff
there.
Budget office staff in selected states told us they used a variety of
approaches to address capacity challenges.
•
Reassigning and hiring staff. Budget office staff told us they
reassigned staff from other offices or hired new temporary and
permanent staff. Washington Office of Financial Management staff
said they initially reassigned existing staff to work on the new federal
funds and then hired new staff to support the COVID-19 relief
programs.
•
Collaborating with state agencies. Some state budget office staff
told us that they leveraged state agencies and other entities’ expertise
and capacity to manage certain COVID-19 relief programs. For
example, according to state budget office staff, many California state
agencies have emergency response teams to address statewide
crises, such as wildfires. California Department of Finance staff said
they leveraged these teams during the pandemic to coordinate the
use and management of relief funds with broader allowable uses,
such as the Coronavirus Relief Fund and the Disaster Relief Fund’s
Public Assistance program.
•
Contracting. Budget office staff told us that some state agencies
used contractors to support their relief fund management activities.

29We previously reported on challenges states experienced with spending funds for
certain COVID-19 relief programs due to the lack of sufficient staff capacity needed to
design and administer new programs. See GAO-22-105397, appendix 25. We have
reported on state capacity challenges implementing Emergency Rental Assistance, see
GAO, COVID-19: Additional Actions Needed to Improve Accountability and Program
Effectiveness of Federal Response, GAO-22-105051, appendix 17 (Washington, D.C.:
Oct. 27, 2021), as well as the Public Health and Social Services Emergency Fund, see
GAO, COVID-19: HHS Funds Allocated to Support Disproportionally Affected
Communities, GAO-23-105500 (Washington, D.C.: Jan. 24, 2023). We also reported on
challenges with state technology resource capacity needed to design and administer
Emergency Rental Assistance, see GAO, Emergency Rental Assistance: Treasury’s
Oversight Is Limited by Incomplete Data and Risk Assessment, GAO-23-105410
(Washington, D.C.: Dec. 20, 2022).

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GAO-24-106152  COVID-19 Relief Funds
For example, Texas Governor’s Office staff told us that their office
was one of several state agencies that hired outside contractors to
help with monitoring, reporting, and other compliance requirement
activities for the COVID-19 relief funds. Washington’s Office of
Financial Management staff told us that although their state also hired
contractors, high demand across state agencies led to competition for
a limited pool of contractors and placed further strain on
administrative capacity.
Budget office staff told us they experienced challenges planning for and
using COVID-19 relief funds when new programs were introduced or
when allowable uses or deadlines were significantly changed.30 In these
cases, states had to consider how these changes would affect earlier
decisions about the use of the funds. Budget office staff said they were
concerned about “moving goal posts” for the various streams of COVID-
19 relief funding.
Some states experienced challenges as additional COVID-19 relief
funding was passed or new federal guidance was issued when the
legislature was not in session or the state budget process had ended. For
example, Minnesota has a part-time legislature, and budget office staff
said they struggled while waiting for guidance for various programs
funded through the American Rescue Plan Act of 2021 (ARPA), which
was enacted in March 2021. Staff said that initial guidance from Treasury
for the Coronavirus State and Local Fiscal Recovery Fund was issued in
early May 2021—shortly before the end of the state’s legislative session.

30We previously reported on challenges selected states experienced with selected
COVID-19 relief programs, including the clarity of guidance for eligible allowable activities
and uses for the funds and the timeliness of guidance for new programs. For state
challenges with guidance for the Coronavirus State and Local Fiscal Recovery Fund and
the Disaster Relief Fund, see GAO-22-105051, appendixes 31 and 36, and
GAO-22-105397, appendixes 24 and 30, respectively. We reported on state challenges
with clarity of guidance in implementing the 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); Transit Grants, see
GAO, COVID-19: Federal Efforts Could be Strengthened by Timely and Concerted
Actions, GAO-20-701, appendix 27 (Washington, D.C.: Sept. 21, 2020), and COVID-19:
Sustained Federal Action is Crucial as Pandemic Enters Its Second Year, GAO-21-387,
appendix 37 (Washington, D.C.: Mar. 31, 2021); and Emergency Rental Assistance, see
GAO-23-105410. We have also reported on challenges with the timeless of guidance
implementing Emergency Rental Assistance, see GAO-23-105410. The Pandemic
Response Accountability Committee also reported on challenges that states had with
frequently updated program guidance that created confusion about the allowable uses of
the COVID-19 relief funds. See Pandemic Response Accountability Committee, Lessons
Learned in Oversight of Pandemic Relief Funds, Updated (Washington, D.C.: June 8,
2022).
Selected States
Addressed Challenges
with the Timing of Funding
and Accompanying
Guidance by Delaying the
Use of Funds and
Substituting Funds

Page 23
GAO-24-106152  COVID-19 Relief Funds
Minnesota Management and Budget staff said this gave the legislature
limited time to engage in deliberative decision-making for the use of the
funds. Similarly, Pennsylvania State Budget Office staff said it was
difficult to plan the use of ARPA funding because the state’s budget
calendar ends in June and federal agencies continued to issue guidance
for the new funds after that date.31
State budget office staff told us that federal agency guidance on allowable
uses for new programs sometimes changed while states were
implementing those programs. In some cases, states could no longer use
the funds as they initially planned, while other changes meant they could
use funds in new ways. California Department of Finance staff said they
quickly planned the use of the Coronavirus State and Local Fiscal
Recovery Fund award funds in May 2021 based on Treasury’s interim
final rule, but had to change plans for the award funds based on the final
rule published in January 2022.32 Budget office staff in California, Illinois,
Minnesota, and Washington told us that the increased reimbursement
rates for the Disaster Relief Fund’s Public Assistance program during the
COVID-19 pandemic led them to reassess initial funding allocations to
ensure the overall best use of funding. Further, budget office staff told us
that Congress’s statutory extension of the deadline for recipients to
obligate the funds from their Coronavirus Relief Fund awards from
December 30, 2020 to December 31, 2021 created a need to quickly
reassess the use of the funds and implement contingency plans.33
States used a variety of approaches to address challenges with the timing
of funding and guidance.
•
Delaying the use of funds. Some state budget office staff said they
took a cautious approach toward using their COVID-19 relief funds,
while other states did not use any of their COVID-19 relief funds until

31Pennsylvania’s fiscal year begins on July 1 and ends on June 30 of the following year,
while the federal fiscal year beings on October 1 and ends on September 30 of the
following year.
32Treasury’s interim final rule was published in the Federal Register and took effect in May
2021. See Interim Final Rule for Coronavirus State and Local Fiscal Recovery Funds, 86
Fed Reg. 26786 (May 17, 2021). Treasury’s final rule was published in January 2022. See
Coronavirus State and Local Fiscal Recovery Funds, 87 Fed Reg. 4338 (Jan. 27, 2022).
33Consolidated Appropriations Act, 2021, Pub. L. No. 116-260 § 1001, 134 Stat. 1182,
2145 (2020). Treasury issued updated guidance and relevant frequently asked questions
regarding when a cost was considered incurred during the extension of the obligation
deadline. See Treasury, Coronavirus Relief Fund: Revision to Guidance Regarding When
a Cost is Considered Incurred (Dec. 14, 2021).

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GAO-24-106152  COVID-19 Relief Funds
federal agencies issued further guidance or implementing regulations.
For example, budget office staff in Illinois said they waited to allocate
Coronavirus Relief Fund award funds to state agencies until Treasury
issued final guidance. Illinois was able to wait because it used a
reimbursement process to distribute these funds to state agencies.
The reimbursement process allowed the budget office to review state
COVID-19 response expenditures, apply funding toward allowable
uses that aligned with the final guidance, and use other federal or
state funds for expenditures that were no longer considered allowable
uses.
•
Substituting funds. Some budget office staff told us that they were
able to leverage the overlapping allowable uses between certain
COVID-19 relief funds when federal guidance unexpectedly changed
allowable uses. For example, the Washington Legislature initially
appropriated the state’s Coronavirus Capital Projects Fund allocation
for water and sewer projects. However, it changed the appropriations
in the following session after Treasury released guidance that,
according to budget office staff in Washington, prioritized using
Coronavirus Capital Projects Fund award funds to support broadband
projects.34 In response, the state legislature approved the use of
Coronavirus State and Local Fiscal Recovery Fund award funds for
the water and sewer infrastructure projects—an eligible use under that
program.
Budget office staff in several states told us that the guidance on allowable
uses for some COVID-19 relief programs created challenges in planning
for the best use of the funds. Staff said 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. Staff also said they
had challenges with the consistency of federal guidance and technical

34See Department of the Treasury, Guidance for the Coronavirus Capital Projects Fund:
For States, Territories & Freely Associated States (September 2021).
Selected States and
Federal Agencies
Addressed Challenges
with Guidance and
Technical Assistance by
Increasing Communication
and Information Sharing

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GAO-24-106152  COVID-19 Relief Funds
assistance.35 For example, budget office staff in Florida said updates to
the frequently asked questions (FAQ) for some programs resulted in
changes from previously published guidance, causing confusion.
Additionally, budget office staff in Florida told us they experienced
challenges aligning some of the expenditures needed for the state’s
COVID-19 response with the allowable uses outlined in the guidance for
certain programs such as the Coronavirus Relief Fund. In contrast,
Pennsylvania State Budget Office staff said that the broad guidance on
allowable uses for the Coronavirus Relief Fund placed a strain on staff
capacity due to the lengthy process of identifying and prioritizing the best
use for the funds across all of the state’s unique pandemic costs.
Some state budget office staff told us they experienced challenges
receiving timely responses from federal agencies to address questions
about the COVID-19 relief programs. For example, Governor’s Office staff
in Texas said that they struggled to access Treasury staff who could
answer specific questions about online guidance for the Coronavirus
Relief Fund and the Coronavirus State and Local Fiscal Recovery Fund.
Similarly, budget office staff in both Illinois and Pennsylvania reported
they reached out to Treasury with questions and did not always receive a
response. Treasury officials told us that while the Office of Recovery
Programs adjusted its technical assistance due to administrative funding
shortfalls, it devoted significant resources to respond to recipient inquires

35We have previously reported on challenges experienced by selected states with the
guidance and technical assistance provided by federal agencies for the COVID-19 relief
funds. For example, we reported on state challenges with guidance for the State Small
Business Credit Initiative, see GAO-23-105293 and COVID-19: Significant Improvements
Are Needed for Overseeing Relief Funds and Leading Responses to Public Health
Emergencies, GAO-22-105291, appendix 12 (Washington, D.C: Jan. 27, 2022), and in the
Disaster Recovery Fund’s Public Assistance program, see GAO-22-105397, appendix 30.
In GAO-22-105051, appendix 36, we recommended that the Federal Emergency
Management Agency (FEMA) improve the consistency and application of its COVID-19
Public Assistance guidance by clarifying and communicating eligibility requirements
nationwide. In October 2021, FEMA addressed this recommendation by holding biweekly
discussions on COVID-19 policies and needs facing localities, issuing policy updates on
deadlines for COVID-19-related submissions, and holding working sessions with FEMA
headquarters staff, regional staff, and representatives from Tribes, states, and U.S.
territories. We have also reported on state challenges with technical assistance for
Emergency Rental Assistance, see GAO-23-105410.

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GAO-24-106152  COVID-19 Relief Funds
through issued FAQs, the Contact Center, and the development of self-
service materials.36
Federal agencies, states, and national organizations used a variety of
approaches to address the challenges states experienced with receiving
and interpreting federal guidance and technical assistance.
•
Providing technical assistance and support. Officials at the
Departments of Education, Health and Human Services, Homeland
Security, Transportation (DOT), and the Treasury said their agencies
provided technical assistance to recipients of COVID-19 relief funds in
a variety of formats. For example, federal agencies published
technical support resources online, including reporting guidance,
periodically updated FAQs, and published documents summarizing
best practices from the states. Officials at some federal agencies told
us they also hosted regularly scheduled webinars and video-
conference sessions to discuss guidance and answer policy
questions.37
•
Communication and feedback. Federal officials and budget office
staff identified actions they had taken to increase communication and
access to technical assistance. For some of the COVID-19 relief
funding, federal agencies provided states with a specific point of
contact to support the states and answer questions. Additionally,
some states were able to provide feedback to federal agencies on
drafts of new and updated program guidance or updated reporting
systems. For example, FEMA officials told us they used webinars and
listening sessions. They also leveraged their regional offices to share
newly drafted policies and guidance with stakeholders and recipients.

36On September 23, 2022, Treasury sent recipients of its COVID-19 relief funds a letter
outlining reductions to its administrative support operations including, among other things,
ending its call center support and reducing email response operations for several COVID-
19 relief funds including the Coronavirus State and Local Fiscal Recovery Funds, the
Coronavirus Capital Projects Fund, and the Emergency Rental Assistance Program.
Treasury reduced and shut down these activities because it said it was running out of
authorized funds to support these efforts. The Consolidated Appropriations Act, 2023,
authorized Treasury to use unobligated funds that were previously made available to it for
administrative expenses under certain provisions. Pub. L. No 117-328, div. LL, § 102(d),
136 Stat. 4459, 6097 (2022). Those funds may be used for administrative expenses
necessary to implement certain COVID-19 relief programs. According to Treasury, the
funding allowed it to reopen its call center to better support recipients by answering phone
and email inquiries.
37For example, the Department of Education’s Elementary and Secondary School
Emergency Relief Fund Resources can be found at
https://oese.ed.gov/offices/american-rescue-plan/resources/.

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GAO-24-106152  COVID-19 Relief Funds
FEMA officials said they collected and incorporated feedback into
updated versions of the guidance. Minnesota provided feedback on
Treasury’s Coronavirus State and Local Fiscal Recovery Funds
reporting portal before it was rolled out and communicated regularly
with Treasury to ask for clarification on guidance, according to budget
office staff.
•
Partnering with national organizations. Some state budget office
staff told us that national organizations, such as the National
Governors Association and the National Association of State Budget
Officers, served as resources for states or communicated with federal
agencies about the challenges states were experiencing.38 Budget
office staff in Florida, Minnesota, and Pennsylvania, and Governor’s
Office staff in Texas collaborated with national organizations to share
their experiences and learn how other states interpreted and
implemented federal guidance. They also shared technical support
information they received from federal agencies. DOT, FEMA, and
Treasury told us they shared information with states through
membership meetings held by national organizations.
State budget office staff reported challenges managing and meeting the
various reporting requirements for federal COVID-19 relief programs.39
The COVID-19 relief funds provided to states were subject to different
reporting periods and deadlines. For example, some COVID-19 relief
programs required annual or quarterly reports, while others required

38For example, the National Association of State Auditors, Comptrollers and Treasurers
Additionally hosts bimonthly COVID-19 and Infrastructure Funding Accountability Work
Group meetings at which we and officials and staff from federal agencies and their offices
of inspector general share information on implementing and overseeing COVID-19 relief
funds.
39We have previously reported on challenges experienced by selected states with the lack
of clear and timely information on reporting requirements for the Coronavirus State and
Local Fiscal Recovery Fund, see GAO-22-105051, appendix 31; Emergency Rental
Assistance, see GAO-23-105410 and GAO-22-105051, appendix 17; and the Disaster
Relief Fund’s Public Assistance program, see GAO-22-105397, appendix 30. We have
also reported on state challenges meeting different reporting requirements across the
COVID-19 relief programs and challenges when using federal online reporting portals, see
GAO-22-105397, appendix 25.
Selected States Used New
and Existing Systems to
Address Challenges
Managing Reporting
Requirements

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GAO-24-106152  COVID-19 Relief Funds
monthly reports.40 Additionally, other COVID-19 relief programs required
one-time interim or closeout reports.41
Some state agencies that received COVID-19 relief funds for existing
programs were able to use existing reporting mechanisms for the COVID-
19 relief funds’ reporting requirements, budget office staff told us. In
contrast, budget office staff told us that recipients of funds for new
programs experienced a variety of challenges managing and meeting
new reporting requirements.
•
Timing of reporting deadlines. Minnesota Management and Budget
staff told us that the reporting deadlines for certain COVID-19 relief
programs often coincided with related federal and state reporting
deadlines for other COVID-19-related programs, which further
strained staff capacity. Washington Office of Financial Management
staff told us that they struggled with the quick turnaround between the
end of a reporting period and the deadline for submitting required
reporting for Treasury-administered programs, such as the
Coronavirus State and Local Fiscal Recovery Fund. They said they
were required to collect and aggregate a large amount of detailed
information from many state agencies and hundreds of subrecipients.

40For example, Treasury reporting guidance for Emergency Rental Assistance states that
recipients were to submit monthly reports through June 30, 2022. Additionally, all
recipients must submit full compliance reports each calendar quarter throughout their
award period of performance. See
https://home.treasury.gov/policy-issues/coronavirus/assistance-for-state-local-and-tribal-g
overnments/emergency-rental-assistance-program/reporting/.
41For example, the Treasury Office of the Inspector General directed Coronavirus Relief
Fund recipients to submit an interim report for the period of March 1, 2020 through June
30, 2020, then quarterly reports for the remainder of the Coronavirus Relief Fund award
period of performance. See Department of the Treasury Office of Inspector General,
Memorandum for Coronavirus Relief Fund Recipients, OIG-CA-20-021 (Washington, D.C.:
July 2, 2020).

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GAO-24-106152  COVID-19 Relief Funds
Treasury officials told us that some of the COVID-19 relief program
reporting deadlines were set by statute.42
•
Changes to reporting requirements. Minnesota Management and
Budget staff told us that requirements for information reporting could
unexpectedly change between cycles or even midcycle. They said
such changes happened for Treasury programs such as the
Coronavirus Relief Fund, the Coronavirus Capital Projects Fund, and
the Coronavirus State and Local Fiscal Recovery Fund. They also
said that Treasury did not provide notice about the changes. As a
result, they collect additional data in a short time frame either from
state agencies or, in the case of the Coronavirus Relief Fund, the
1,600 subrecipients that received funding. Treasury officials told us
that it is their practice to notify recipients of changes to reporting
requirement guidance by email and update user guides with
summaries of highlighted changes. Additionally, Treasury officials said
they conducted an information session on new reporting requirements
for the Coronavirus Capital Projects Fund.
•
Timely reporting templates. Some budget office staff told us they
struggled to collect reporting information without timely reporting
templates from federal agencies. For example, Illinois budget staff told
us that the Coronavirus State and Local Fiscal Recovery Fund interim
report to Treasury required specific information, but states did not
receive reporting templates from Treasury in a timely manner. The

42For example, the Emergency Rental Assistance 1 statutory language required Treasury
to publish quarterly public reports on the use of the funds. 15 U.S.C. § 9058a(g)(1).
Treasury officials said that certain CARES Act reporting requirements applied to the
Coronavirus Relief Fund and Emergency Rental Assistance 1 and required the reporting
of certain data no later than 10 days after each calendar quarter. Pub. L. No. 116-136,
§15011(b)(2), 134 Stat. 281 (2020). Treasury officials told us that they negotiated an
extension to the reporting deadlines for the Emergency Rental Assistance 1 to no later
than 15 days to reduce reporting burden to the states and applied these reporting
requirements to all Treasury-administered COVID-19 relief programs authorized by the
American Rescue Plan Act of 2021 (ARPA). In GAO-23-105410, we recommended that
Treasury expediently publish complete Emergency Rental Assistance program data,
including all disaggregated performance measures required by the Consolidated
Appropriations Act, 2020 for all applicable quarters from program inception through the
end of the award performance period. No actions have been taken to address this
recommendation as of November 2023.

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GAO-24-106152  COVID-19 Relief Funds
report was due on August 31, 2021, but Treasury did not publish final
reporting templates until August 9, 2021.43
•
Subrecipient reporting and monitoring. Budget office staff told us
they had difficulty collecting required data for certain federal programs
from subrecipients. For example, Washington Office of Financial
Management staff said that some state agencies contracted with
subrecipients for direct service provisions. However, the agencies
struggled to ensure that these subrecipients collected all the relevant
data needed to meet federal reporting requirements. In addition, state
auditor’s office staff told us they found new or exacerbated pre-
existing deficiencies in state subrecipient monitoring due to the large
influx of COVID-19 relief funds. For example, the Florida Auditor
General’s Office found that the state did not have the sufficient
capacity to monitor subrecipients for the Elementary and Secondary
School Emergency Relief Fund.44
•
State financial management systems. Some budget office staff
reported that differences between state and federal accounting
systems led to challenges in interpreting and meeting reporting
requirements. For example, Minnesota Management and Budget staff
said that differences between the state and federal definitions of the
terms “allocated” and “obligations” meant state agencies were
required to alter their existing reporting approaches.45 According to
staff, they had difficulty meeting federal reporting requirements. In one
instance, they needed to request an extension to submit their report.
Illinois Governor’s Office of Management and Budget staff reported
similar challenges. Staff said they had issues when trying to use their

43Treasury officials told us they previously published several documents that included
details on the compliance and reporting required for the Coronavirus State and Local
Fiscal Recovery Fund interim report. These documents included, among other things, a
FAQ document, published on May 27, 2021, and reporting guidance, published on June
17, 2021.
44State of Florida Auditor General, State of Florida Compliance and Internal Controls Over
Financial Reporting and Federal Awards – For Fiscal Year Ended June 30, 2022, Report
No. 2023-174. Funding Number 2022-033 focuses on the Education Stabilization Fund,
which includes the Elementary and Secondary School Emergency Relief Fund and
COVID-19 awards.
45For the purposes of federal budgeting, an allocation is a delegation, authorized in law,
by one agency of its authority to obligate budget authority and outlay funds to another
agency. An obligation is a definite commitment that creates a legal liability of the
government for the payment of goods and services ordered or received. Payment may be
made immediately or in the future. An obligation occurs, for example, when an order is
placed, a contract is signed, a grant is awarded, or a service is purchased.

Page 31
GAO-24-106152  COVID-19 Relief Funds
existing grant management system for Treasury reporting because
their system did not include all of the required information.
States used a variety of approaches to address challenges meeting
reporting requirements.
•
Leveraging existing systems. Budget office staff in some states told
us that, in the absence of templates or changing reporting guidance,
the states leveraged their existing grants reporting systems for data
collection. For example, Illinois budget office staff told us that while
some state agencies that were receiving federal funds for the first time
through the Coronavirus State and Local Fiscal Relief Funds reported
information to the state’s grants solution system, it was some time
before they received a reporting template from Treasury. Illinois
ultimately relied on the information that was already collected through
its own grants solution system for reporting.
•
Developing new systems. Budget office staff in California, Florida,
and Pennsylvania told us that they developed new state systems,
portals, and templates for data collection. For example, Pennsylvania
Office of the Budget staff said they collaborated with other state
agencies to develop a reporting portal for their COVID-19 relief funds.

States were often able to use funding for pre-existing programs more
efficiently than they were able to use funding for new programs, according
to budget office staff. Staff said state agencies that received COVID-19
relief funds for existing programs were familiar with the program
structures and had mechanisms in place for using and reporting on the
funds. For example, California Department of Finance staff said state
agencies could more easily use COVID-19 relief funds for existing
programs because they could leverage their existing expertise and
capacity. However, as we have previously reported, existing programs
that received COVID-19 relief funding also experienced challenges,
Selected State
Experiences Using
COVID-19 Relief
Funding Could Inform
Future Federal Relief
Selected States Generally
Experienced More
Challenges Using COVID-
19 Relief Funds for New
Programs

Page 32
GAO-24-106152  COVID-19 Relief Funds
including insufficient staff capacity, coordinating with subrecipients, and
meeting reporting deadlines.46
In contrast to pre-existing programs, some state budget office staff said it
can take time to develop the capacity to manage new programs, including
(1) developing sufficient staff capacity, (2) understanding program
guidance and allowable uses, and (3) understanding and fulfilling
reporting requirements. State budget offices used infrastructure and
models from existing programs to address challenges with new programs.
For example, Washington Office of Financial Management staff said they
used the models from existing programs to help stand up new programs
with COVID-19 relief funds more quickly and effectively. Washington used
some of its allocation from the Coronavirus State and Local Fiscal
Recovery Funds to establish a program modeled after the U.S.
Department of Agriculture’s (USDA) Farmers to Families Food Box
Program, a short-term emergency federal program that provided local
food directly to homes in underserved communities.47 Washington Office
of Financial Management staff said that it was easier for the state to
leverage the pre-existing design of the program based off their prior
participation in it.
Despite these challenges, some states noted that newer federal programs
were a valuable part of overall relief efforts. Minnesota Management and
Budget staff said that some of the unique challenges of the pandemic
could only have been addressed through the new and more flexible
programs.
Budget office staff in several states said they addressed challenges by
leveraging staff who were experienced with using federal relief funds,
such as those authorized by the American Recovery and Reinvestment

46We have previously reported that selected states and officials from associations
representing state and local governments said it was more challenging for state and
localities to manage newly created programs than programs that previously existed and
received additional funding under the COVID-19 relief laws. See GAO-22-105397,
appendix 25.
47According to Washington Office of Financial Management staff, their original USDA
Farmers to Families Food Box program ran from April 2020 to September 2020.
Selected States
Leveraged Staff
Experienced with Federal
Relief to Enhance the Use
of COVID-19 Relief Funds

Page 33
GAO-24-106152  COVID-19 Relief Funds
Act of 2009 (Recovery Act). 48 The experienced staff helped the states
more effectively plan, use, and report on COVID-19 relief funds. For
example, budget staff in Florida said their experience with the Recovery
Act taught them the importance of having the right structure and agencies
with experience in grants management in place. As a result, Florida’s
Office of Budget and Policy and state agencies selected staff with subject
matter expertise in compliance and regulations of federal funds to
manage its COVID-19 relief funding. Staff told us that leveraging
knowledgeable staff allowed them to quickly interpret guidance, address
FAQs, and share relevant information.
Budget office staff from some of the selected states said that their
approach to implementing COVID-19 relief funding improved over time as
staff experience and capacity grew. For example, Washington Office of
Financial Management staff told us that they initially prioritized giving
some of the COVID-19 relief funds to state agencies with federal fund
experience. Over time, they provided additional support for less
experienced state agencies to use the COVID-19 relief funds.
Budget office staff in several selected states told us that, based on their
experience with the Recovery Act, they used the COVID-19 relief funds
for one-time needs to avoid potential budgetary cliffs when the COVID-19
relief funding ends. We have previously reported that some states
developed exit strategies for Recovery Act funding by using funds for
nonrecurring expenditures to avoid a “cliff effect” within state budgets at
the end of federal funding.49 Pennsylvania Office of the Budget staff said
the state avoided using COVID-19 relief funds to support ongoing costs or
new programs, as the state had used Recovery Act funds to support
programs that were not sustainable after that federal funding ended.
Pennsylvania ultimately used state dollars to continue those programs.
Washington Office of Financial Management staff said that the state
legislature is working to slowly wind down new or expanded programs

48Pub. L. No. 111-5, 123 Stat. 115 (2009). The Recovery Act was enacted to, among
other things, promote economic recovery, make investments, and minimize and avoid
reductions in state and local government services in response to the economic recession.
The Congressional Budget Office estimated that the Recovery Act would cost
approximately $840 billion over the 2009-2019 period. See Congressional Budget Office,
Estimated Impact of the American Recovery and Reinvestment Act on Employment and
Economic Output in 2014, (Washington, D.C.: Feb. 20, 2015).
49See GAO, Recovery Act: States' and Localities' Current and Planned Uses of Funds
While Facing Fiscal Stresses, GAO-09-908T (Washington, D.C.: Sept. 10, 2009).
Selected States Focused
on One-Time Uses of
COVID-19 Relief Funds to
Avoid Future Budgetary
Challenges

Page 34
GAO-24-106152  COVID-19 Relief Funds
that were funded with COVID-19 relief funds by reducing the use of
federal funds and using state funds to continue ongoing programs.
Selected States Adapted and Developed Data Reporting Systems for
COVID-19 Relief Funds Reporting Needs
Budget office staff in selected states used their experiences reporting on
early COVID-19 programs, such as those funded under the CARES Act in
2020, to anticipate reporting requirements for later COVID-19 relief funds.
For example, budget office staff in California said they relied on the
state’s experience with the Coronavirus Relief Fund to anticipate data
needs, after they experienced delays in Treasury guidance for
Coronavirus State and Local Fiscal Recovery Funds reporting. They told
us they modeled their portal for reporting on the use of the Coronavirus
State and Local Fiscal Recovery Funds after the portal they developed for
the Coronavirus Relief Fund. Similarly, the Illinois Governor’s Office of
Management and Budget staff said they asked state agencies to track
their COVID-19 related expenditures while they waited for guidance for
COVID-19 relief programs, such as the Coronavirus Relief Fund. They
said this guidance allowed Illinois to meet reporting and reimbursement
requirements more effectively once federal guidance was published.
Some state budget office staff told us that their experience with COVID-
19 relief funds led them to develop centralized units or processes to
manage future federal relief funds more efficiently. For example,
California Department of Finance staff said they established a Federal
Fund Accountability and Cost Tracking unit in 2021 to oversee, track, and
report on spending by coordinating with state agencies on the
Coronavirus State and Local Fiscal Recovery Funds and other relief
funds. The state plans to use its Federal Funds Accountability and Cost
Tracking unit to manage other future federal funding packages, including
those received through the Infrastructure Investment and Jobs Act and
the Inflation Reduction Act of 2022. Similarly, Pennsylvania Office of the
Budget staff told us they plan to leverage systems and structures they
developed for using the COVID-19 relief funds to use funding they receive
from those acts. They said these systems include a shift toward a more
centralized grants management system to manage the flow of future
federal funds to the state, based on challenges they experienced using a
decentralized grants management system from their American Rescue
Plan Act funds.
Selected States
Established Centralized
Units and Processes to
Support the Use of
Federal Relief Funds

Page 35
GAO-24-106152  COVID-19 Relief Funds
We provided a draft of this report to the Departments of Education, Health
and Human Services, Homeland Security, Transportation, and the
Treasury for review and comment. We received technical comments from
the Departments of Education, Health and Human Services, and the
Treasury, which we incorporated as appropriate.
We also provided excerpts of the draft report to cognizant staff of state
budget offices in California, Florida, Illinois, Minnesota, New York,
Pennsylvania, Texas, and Washington. The selected states provided
technical comments, which we incorporated as appropriate.
We are sending copies of this report to the appropriate congressional
committees, the Secretaries of Education, Health and Human Services,
Homeland Security, Transportation, and the Treasury; representatives of
state budget offices in California, Illinois, Florida, Minnesota, New York,
Pennsylvania, Texas, and Washington; and other interested 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 I.

Jeff Arkin
Director, Strategic Issues

Agency Comments
and Third-Party Views

Page 36
GAO-24-106152  COVID-19 Relief Funds
List of Addressees
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
Chairwoman
The Honorable Rosa L. DeLauro
Ranking Member
Committee on Appropriations
House of Representatives
The Honorable Cathy McMorris Rodgers
Chair
The Honorable Frank Pallone, Jr.
Ranking Member
Committee on Energy and Commerce
House of Representatives

Page 37
GAO-24-106152  COVID-19 Relief Funds
The Honorable Mark E. Green, M.D.
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: GAO Contact and Staff
Acknowledgments

Page 38
GAO-24-106152  COVID-19 Relief Funds
Jeff Arkin, (202) 512-6806, arkinj@gao.gov
In addition to the contact named above, Alexandra Edwards (Assistant
Director), Jazzmin Cooper (Analyst in Charge), William Harrison, and
Edward Young made major contributions to this report. Also contributing
to this report were Michael Bechetti, Robert Gebhart, Samantha Lalisan,
Steven Putansu, and Rebecca Sero.

Appendix I: GAO Contact and Staff
Acknowledgments
GAO Contact
Staff
Acknowledgments

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