A Review of Pandemic Relief Funding and How It Was Used In Six U.S. Communities - Springfield, Massachuesetts

Document type: PDF source document
Date: 2024-05-02

Summary

A May 2024 report by the Pandemic Response Accountability Committee, the first in a series reviewing how six communities used pandemic funding, focusing on Springfield, Massachusetts. It states that Springfield recipients received almost $1.88 billion from 52 pandemic relief programs and subprograms during the first 18 months of the pandemic, and examines 9 of the 52 programs in detail. Program sections include the Coronavirus Relief Fund, the Elementary and Secondary School Emergency Relief Program, the Farmers to Families Food Box Program, pandemic unemployment insurance and Provider Relief Fund payments to nursing homes. The transit section reports that FTA obligated over $36.6 million to the Pioneer Valley Transit Authority and had disbursed about $10.6 million through September 30, 2021. Appendix B describes the scope and methodology for each program review.

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Full text

A Review of Pandemic Relief Funding
and How It Was Used In Six U.S.
Communities

Springfield, Massachusetts
May 2024

City of Springfield, Massachusetts
City of Coeur d’Alene, Idaho
Sheridan County, Nebraska
Marion County, Georgia
White Earth Nation Reservation in Minnesota
Jicarilla Apache Nation Reservation in New Mexico

PANDEMIC RESPONSE
ACCOUNTABILITY COMMITTEE

CONTENTS
Taking a Closer Look at a Community’s Experience: Springfield, MA .............................................. 1
Pandemic Impact on Community ................................................................................................... 2
Program Impact on the Community ............................................................................................... 3
Participant Experience.................................................................................................................... 3
CARES Act Urbanized Area Formula Grants ...................................................................................... 5
Community Development Block Grant – CARES Act......................................................................... 9
Coronavirus Relief Fund....................................................................................................................12
COVID-19 Public Assistance Emergency Protective Measures ...................................................... 17
Elementary and Secondary School Emergency Relief Program .................................................... 21
Farmers to Families Food Box Program ...........................................................................................26
Pandemic Unemployment Insurance Programs..............................................................................30
CARES Act Urbanized Area Formula Grants ....................................................................................38
Provider Relief Fund Payments to Nursing Homes ......................................................................... 41
Appendix A: Acronyms .......................................................................................................................49
Appendix B: Scope and Methodology .............................................................................................. 51
CARES Act Urbanized Area Formula Grants Program .................................................................52
Community Development Block Grant – CARES Act...................................................................54
Coronavirus Relief Fund................................................................................................................55
COVID-19 Public Assistance Emergency Protective Measures ..................................................56
Elementary and Secondary School Emergency Relief Program ................................................ 57
Farmers to Families Food Box Program .......................................................................................58
Pandemic Unemployment Insurance ...........................................................................................59
Project-Based Rental Assistance - CARES Act .............................................................................60
Provider Relief Fund Payments to Nursing Homes ..................................................................... 61

Pandemic Response Accountability Committee

Taking a Closer Look at a
Community’s Experience:
SPRINGFIELD, MA
This report is the first in a series of
reports taking an in-depth look at how six
communities used the pandemic funding
they received to address a wide range
of needs. We are focusing first on the
city of Springfield, Massachusetts, with
a detailed look at 9 of the 52 pandemic
programs that provided funding to the
community. For more information about
our review, see Appendix B.
Springfield is the third largest city in
Massachusetts and the fourth largest in
New England with 154,064 inhabitants.
From March 1, 2020, through March
2, 2023, the community experienced
171,829 recorded cases of COVID-19,
with 2,138 recorded deaths.
In the first part of our review, we found that
Springfield, MA, recipients, including the
city government, small businesses, and
individuals, received almost $1.88 billion
from 52 pandemic relief programs and
subprograms during the first 18 months
of the pandemic. This report will provide a
closer look at eight federal departments’
pandemic programs and subprograms—
nine in total—and the funding they provided
to Springfield. These programs aimed to
respond to and mitigate the effects of
the pandemic by addressing community

U.S. Census Bureau for counties, cities, Indian tribes.
Because individuals may be considered a member of more than one racial
demographic, the percentages may not equal 100 percent.
c
Centers for Disease Control and Prevention based on the rate of individuals who
received at least two doses of the vaccine. The vaccination rate represents the countywide rate and is not specific to the Springfield, MA, city borders. Data as of May 30,
2023.
d
Data obtained from the Massachusetts Office of Health and Human Services on March
23, 2023.
e
U.S. Census Bureau. The poverty line varies depending on factors, such as, the
year and household size. Please see Poverty Thresholds for more information.
a

development needs that posed a serious threat to
the health or welfare of the community, supporting
public transportation agencies, developing learning
loss programs for local schools, and other efforts.
The federal government’s pandemic response
was not the first widespread emergency response
the Springfield government implemented over the
past decade. From 2011 to 2013, the community
experienced several natural disasters (including
a snowstorm, a tornado, and a fire) that required
quick and coordinated responses between the
local government and the federal government.
During our site visit in May 2022, city officials said
this previous experience helped them establish a
coordinated response from the beginning of the
pandemic that was tailored to their community.
Officials also said this past experience helped
inform how they would spend federal pandemic
funding from multiple federal programs and
leverage non-pandemic funding.

Programs Selected for
Further Review
CARES Act Urbanized Area
Formula Grants Program
U.S. Department of Transportation

Community Development
Block Grant – CARES Act
U.S. Department of Housing and
Urban Development

Coronavirus Relief Fund
U.S. Department of the Treasury

COVID-19 Public Assistance
Emergency Protective Measures
U.S. Department of Homeland Security

Elementary and Secondary School
Emergency Relief Program
U.S. Department of Education

Pandemic Impact on Community
Many aspects of life in Springfield, MA, were
affected by the pandemic. For example, low-income
and minority populations were disproportionately
impacted due to the pandemic’s effects on small
businesses, housing, service industries, and
childcare. Springfield’s average unemployment rate
increased from 5.8 percent in 2019 to 14.5 percent
in 2020 with a peak of 21.6 percent in April 2020.
To help address this specific issue, individuals in
Springfield received over $444 million in federal
benefits from pandemic-related unemployment
insurance (UI) programs. At the time of our visit in
May 2022, underserved communities in Springfield
still struggled to secure essential services like
childcare due to increased costs and decreased
availability caused by the pandemic.

Pandemic Response Accountability Committee

Farmers to Families Food Box Program
U.S. Department of Agriculture

Pandemic Unemployment
Insurance Programs
U.S. Department of Labor

Project-Based Rental
Assistance - CARES Act
U.S. Department of Housing and
Urban Development

Provider Relief Fund Payments
to Nursing Homes
U.S. Department of Health and
Human Services

Program Impact on the Community
Officials that the Pandemic Response Accountability Committee (PRAC) and Offices of Inspector
General (OIG) teams interviewed offered a wide variety of responses when asked about the
community’s use of federal pandemic funds. The Springfield community shared several interesting
stories about how the federal assistance programs addressed the impacts of COVID-19.
Programming and repurposing existing federal assistance funding helped with immediate
responses to the pandemic, and recipients of funding appreciated the federal government’s
emergency assistance.
• Pioneer Valley Transit Authority (PVTA) experienced a 50 percent loss in revenue during the
pandemic. Through September 30, 2021, PVTA received $36.6 million through a Coronavirus
Aid, Relief, and Economic Security (CARES) Act funded Urbanized Area Formula Grant, of which
it used $10.6 million to maintain operations, provide essential services, and keep staff fully
employed so PVTA could return to full service.
• The city government worked with U.S. Department of Housing and Urban Development
(HUD) officials to reprogram Community Development Block Grant (CDBG) funding to make
small business assistance available before federal emergency funding was received. The
city subsequently provided an additional $684,927 to small businesses and non-profit
organizations in Community Development Block Grant – CARES Act (CDBG-CV) funds.
• Almost 87 percent of Springfield Public School principals, who responded to a survey we
conducted during our review, reported that they were ‘Very Satisfied’ or ‘Somewhat Satisfied’
with the flexibility of federal funding to meet each school’s needs.
• HUD’s automatic and immediate distribution of its initial allocation of the Project-Based Rental
Assistance-CARES Act funding helped pay for the increase in rental subsidies needed for
families that lost income due to the pandemic.

Participant Experience
During our visit, we received feedback from multiple officials in Springfield whose offices or
organizations received federal funding. They told us about their experiences with federal programs
as they responded to the pandemic within Springfield and highlighted the challenges and
successes.
• Springfield city health officials and staff said they appreciated the support and guidance from
the federal government. However, community officials noted that they needed to tailor their
response and education effort to resonate more with its residents by using trusted members
of society, such as prominent local officials, religious leaders, and community members, to
help provide targeted messaging and outreach.

Pandemic Response Accountability Committee

• Fiscal limitations affected smaller entities’ ability to participate in the Federal Emergency
Management Agency’s (FEMA) Public Assistance Emergency Protective Measures
reimbursement process. These entities did not have the option to cover the initial costs and
wait for FEMA reimbursements, so they did not seek assistance from FEMA.
• One organization that received food boxes through the Farmers to Families Food Box Program
(Food Box Program) stated it was a challenge to distribute the food boxes before the
perishable food rotted.
• Most surveyed claimants for the UI program expressed overall satisfaction with the application
process, promptness of receiving benefits, and the certification process to continue receiving
benefits.
• Corporate and facility leaders representing a Springfield nursing home stated that the Provider
Relief Fund (PRF) payments were integral to the nursing home’s pandemic response, including
for covering the costs of personal protective equipment (PPE) and staffing.

Pandemic Response Accountability Committee

PROGRAM SNAPSHOT

CARES Act Urbanized Area
Formula Grants
U.S. Department of Transportation
Millions of Americans use public transportation to access their jobs, education, essential services—
such as medical care and grocery shopping—and recreational activities. The COVID-19 pandemic
put provision of public transportation at risk from a variety of perspectives, including reductions in
ridership, revenue, and staff availability.
Since March 2020, Congress has provided $69.5 billion in supplemental funding to the Federal
Transit Administration (FTA) to help transit systems in the United States mitigate the impacts of
the COVID-19 pandemic.1 The majority of these funds were made available to recipients through
the Urbanized Area Formula Grants Program, which seeks to provide transit capital and operating
assistance in urbanized areas and for transportation-related planning.
FTA officials told us that the purpose, goals, and objectives of these funds were to support public
transportation agencies, as well as prevent, prepare for, and respond to COVID-19, which we
determined were consistent with the purposes outlined in the CARES Act. FTA also stated that
it considered all expenses incurred on or after January 20, 2020, and typically eligible under
Urbanized Area Formula Grants Program to be eligible for the CARES Act Urbanized Area Formula
Grants Program.
Through September 30, 2021, FTA made over $61.7 million in COVID-19 relief Urbanized Area
Formula Grants Program funds available to the Springfield urbanized area, which includes parts
of a neighboring state, Connecticut. Of these funds, FTA had obligated over $36.6 million through
a CARES Act-funded grant to the PVTA. At that time, FTA had disbursed about $10.6 million from
that grant to PVTA.
PVTA provides fixed-route bus and Americans with Disabilities Act demand-responsive van service in
24 Western Massachusetts communities. Funding for the PVTA comes from Federal, state, and
local governments as well as farebox and advertising revenues.

In March 2020, FTA received $25 billion through the Coronavirus Aid, Relief, and Economic Security (CARES) Act of 2020 to prevent, prepare
for, and respond to COVID-19 (Pub. L. No. 116-136). In December 2020, FTA received an additional $14 billion for these purposes through the
Coronavirus Response and Relief Supplemental Appropriations Act of 2021 (Pub. L. No. 116-260). In March 2021, FTA received another $30.5
billion for these purposes through the American Rescue Plan (ARP) Act of 2021 (Pub. L. No. 117-2).

Pandemic Response Accountability Committee

Program Impact
PVTA’s revenues dropped over 50 percent during the COVID-19 pandemic—from over $7.5 million
in fiscal year 2019 to under $3.3 million in fiscal year 2021. In April 2020, PVTA’s overall ridership
was 24 percent of what it had been in April 2019. With the Authority’s loss in ridership came a loss
in fare and advertising revenue. PVTA’s fare revenue was further impacted by a step it took in March
2020 to protect drivers and riders. Specifically, to limit contact between drivers and passengers, the
Authority implemented rear-boarding on buses and stopped collecting fares. PVTA did not resume
collecting fares until July 2020.
Given the revenue loss, PVTA officials believe that
the CARES Act Urbanized Area Formula Grants
Program funding was critical for it to maintain
operations, provide essential services, and keep
staff fully employed so the Authority could return
to full service in the future. One PVTA official called
the funds “a blessing” and stated that not receiving
them “would have been tragic” because PVTA
“could not stay in business without those funds.”

In interviews conducted by DOT OIG, PVTA officials
indicated the funds had a tremendous impact on
the Authority’s operations. However, DOT OIG notes
that recipients of CARES Act Urbanized Area Formula
Grants Program funding were not required to report
data that would allow FTA to measure the funding’s
overall effect, such as how many layoffs and service
cuts the funding helped prevent.

We determined PVTA’s CARES Act Urbanized Area
Formula grant expenditures through September 30, 2021, aligned with the purposes for which the
funding was given.2 Specifically, PVTA used the funds to:
• Cover its revenue shortfalls.
• Continue paying bus drivers for full work weeks—even early in the pandemic when, due to
decreases in ridership, the Authority did not need drivers to work their full schedules.
• Purchase personal protective equipment, cleaning services and supplies, driver barriers, and
laptops to allow non-customer facing employees to work from home.
• Obtain technology that shows customers approximately how many passengers are on a
bus before they board. One PVTA official noted that while they could not limit how many
passengers rode a particular bus, this technology helps riders feel comfortable by allowing
them to assess their COVID-19 risk.
• Make security improvements. Urbanized Area Formula Grants recipients, including CARES
Act funds, are required to expend at least 1 percent of their apportionment to fund security
projects.3 PVTA installed IT software and firewalls so teleworking employees could have remote
access to work from home. PVTA also hired additional security personnel to help enforce a
2

While PVTA spent pandemic relief funding in accordance with the stated purpose of the funds, it submitted the same expenditure for
reimbursement twice in at least 3 of the 147 invoices we reviewed—totaling at least $525. While we determined this amount to be immaterial,
we submitted the information to PVTA and FTA for corrective action. PVTA attributed the duplicate submissions to an error and committed to
remedying the charges.
Recipients can get an exception to this requirement if they certify that the funds are not needed. 49 U.S. Code (U.S.C.) 5307(c)(1)(J) (2015).

Pandemic Response Accountability Committee

requirement that passengers wear masks while on PVTA transportation vehicles. One PVTA
official said that mask enforcement was a “huge issue” and even led to fist fights. The driver
barriers—consistent with then-applicable public health guidance regarding COVID-19 safety in
the workplace—also helped keep drivers safe from unruly passengers.
Our interviews with PVTA officials indicated the funds had a tremendous impact on the Authority’s
operations. However, recipients of CARES Act Urbanized Area Formula Grants Program funding
were not required to report data that would allow FTA to measure the funding’s overall effect, such
as how many layoffs and service cuts the funding helped prevent. Unlike the American Recovery
and Reinvestment Act of 2009 (ARRA)—which required recipients to report funding impact through
estimates of the number of jobs created or retained by ARRA-funded projects—the CARES Act
only requires recipients to report the estimated number of jobs created or retained by the funded
project or activity “where applicable.” Under the CARES Act, agencies are responsible for creating
a user-friendly means for these recipients to comply with that requirement. However, the Office of
Management and Budget subsequently issued related guidance stating that it does not expect
agencies or recipients would need to report additional information to meet this requirement.4 FTA
relied on the Office of Management and Budget’s guidance and did not require additional reporting
from recipients of CARES Act Urbanized Area Formula Grants Program funding. According to FTA, it
has been tracking trends within the transit industry, such as ridership and service levels.

Participant Experience
PVTA officials believe that CARES Act funding was sufficient and well administered. They described
the funding as adequate to cover PVTA’s needs and said they did not need to choose between
priorities when allocating funds. While one PVTA official noted CARES funding created a little more
paperwork, another did not really notice a difference tracking funds for the CARES Act compared to
other programs. PVTA had received Urbanized Area Formula Grants funds before and already had
an approval process in place to prevent funds from being expended for unauthorized purposes.
One official stated that because they were familiar with FTA’s reimbursement system and knew
the backup documentation they were required to maintain, they found compliance with CARES Act
funding easy. The same PVTA official said the funds were “extremely easy” to use because the
funding was quickly and directly given to PVTA with no requirement to provide matching funds,
and FTA made the allowable uses clear.5 To help grant
recipients understand the allowable purposes for the funds,
USING FEDERAL FUNDS
FTA hosted webinars and updated its Frequently Asked
Questions (FAQ) webpage. Also, FTA’s Circular 9030.1E
Grant funding was “extremely easy to
provides detailed information on generally allowable
use” because PVTA received the funds
expenses covered by Urbanized Area Formula Grants.
quickly with clear allowable uses.

4
5

Office of Management and Budget, Memorandum for the Heads of Departments and Agencies: Implementation Guidance for Supplemental
Funding Provided in Response to the Coronavirus Disease 2019 (COVID-19) (M-20-21), April 10, 2020.
As the transit agency for an urbanized area with a population of 200,000 to 1 million people, PVTA received its allocation of Urbanized Area
Funding directly from FTA.

Pandemic Response Accountability Committee

The PVTA official described FTA’s guidance as “very clear and very timely” and said the
webinars were “really informative.” The official also cited FTA’s FAQ webpage as PVTA’s biggest
resource, saying it was regularly updated and easy to access.
On the other hand, multiple PVTA officials noted an issue related to paying bonuses with the CARES
funding. They said they wanted to give PVTA drivers bonuses—because they were “frontline
warriors” and worked despite the increased risk of getting COVID-19—but believed FTA’s guidance
prevented them from doing so unless bonuses were part of the drivers’ existing contracts. However,
according to an FTA official, since May 2020, the Agency’s FAQ webpage has noted that a recipient
that does not have an agreement in place may create one to allow them to pay a bonus or incentive
from that point forward. FTA guidance does not define the format that the agreement must take. An
FTA official clarified that the agreement should be documented but does not have to be formal,
such as a contract.

Pandemic Response Accountability Committee

PROGRAM SNAPSHOT

Community Development
Block Grant – CARES Act
U.S. Department of Housing and Urban
Development
At the beginning of the pandemic, many businesses and schools closed. Low-income and minority
populations in Springfield, MA, were disproportionately impacted because of the pandemic’s
negative effects on small businesses, service industries, and childcare. The city of Springfield’s
experience gained from previous disasters and
a good working relationship with HUD officials at
the Boston field office allowed the city to respond
QUICK RESPONSE THROUGH
quickly at the beginning of the pandemic. The city
REPROGRAMMING OF CDBG
reprogrammed some of its annual CDBG funding
FUNDS
from HUD to assist local businesses before it
received federal pandemic response funds. Doing
Springfield worked closely with HUD to quickly
so allowed Springfield to set up and fund the first of
reprogram some of its annual Community
four rounds of its “Prime the Pump” program, which
Development Block Grant funding to start the Prime
provided grants to local businesses and non-profit
the Pump program to assist local businesses before it
organizations to help them stay open, retain jobs,
received federal pandemic response funds.
and provide immediate support to the community.
The CARES Act (signed into law on March 27, 2020) made available $5 billion in supplemental
CDBG funding for grants to prevent, prepare for, and respond to coronavirus (CDBG-CV grants). Of
that amount, up to $2 billion was allocated to grantees based on the same formula in fiscal year
2020; $1 billion was allocated to states and insular areas based on factors related to public
health, economic, and housing impacts of the coronavirus; and the remaining amount was
allocated to the states or local governments at the Secretary’s discretion according to a formula
based on public health risk, economic, and housing impacts of the coronavirus. As of September
30, 2021, HUD awarded $4,051,632 in CDBG-CV funding to Springfield, MA, and of that amount
the city had expended $1,719,609 to prevent, prepare for, and respond to coronavirus. The city
has until September 1, 2027, to spend the remaining amount. The city planned to use the
remaining funds for mortgage and utility assistance, a business grant and loan program, public
infrastructure, a commercial driver’s license job training program, small business technical
assistance, and administrative costs.

Pandemic Response Accountability Committee

The CDBG Program provides annual grants on a formula basis to states, cities, and counties to
develop viable urban communities by providing decent housing and a suitable living environment,
and by expanding economic opportunities, principally for low- and moderate-income persons. The
program is authorized under Title 1 of the Housing and Community Development Act of 1974.
The goals and objectives for the CDBG-CV program were generally the same as the annual CDBG
program. Specifically, grantees must ensure that every program-funded activity meets one of the
three program national objectives: (1) benefit low- and moderate-income persons, (2) prevention or
elimination of slums or blight, or (3) address community development needs having a particular
urgency because existing conditions pose a serious and immediate threat to the health or welfare
of the community for which other funding is not available. HUD used the same performance
metrics as its annual CDBG program. These metrics measured jobs created, housing and services
provided, and access to infrastructure for low- and moderate-income persons.
Grantees received guidance for the CDBG-CV program in a variety of ways. HUD published
guidance and developed FAQs for the CDBG-CV program on the HUD Exchange website. In addition,
HUD hosted webinars and office hours for stakeholders. HUD field staff also responded to calls and
emails answering questions from grantees.

Program Impact
Using CDBG-CV program funds, the city of Springfield continued with the “Prime the Pump”
program which provided grants to businesses and non-profit organizations. The “Prime the Pump”
– Business Assistance program provided emergency financial relief to small, for-profit businesses
that were impacted by pandemic-related emergency shutdown orders and restrictions on inperson activities. These grants helped businesses pay for operating expenses to recover from the
pandemic. The “Prime the Pump” – Non-Profit Public Service program provided grants to assist nonprofits with unmet financial needs due to the pandemic, but that continued to provide direct public
services to Springfield’s low- and moderate-income population. In addition to the “Prime the Pump”
program, through a partnership with a non-profit, the city provided emergency short-term mortgage
and utility assistance to Springfield’s low- and moderate-income households who experienced a
loss of income due to the pandemic and needed assistance to remain current on mortgage and
utility payments. As of September 30, 2021, the city had disbursed $463,250 in grants to 69
local businesses that were impacted by pandemic-related6 emergency shutdown orders and
$221,677 in grants to 13 non-profit organizations for providing public services for low- and
moderate-income persons. The city also disbursed $658,537 to one non-profit organization for
mortgage and utility payments for low- and moderate-income households. The remaining amount
spent was for Section 108 loan payments to HUD, a business grant and loan program, a public
infrastructure program, and administrative costs.

The Section 108 Loan Guarantee program provides CDBG recipients with the ability to leverage their annual grant allocation to access low-cost,
flexible financing for economic development, housing, public facility, and infrastructure projects. Communities can use Section 108 guaranteed
loans to either finance specific projects or to launch loan funds to finance multiple projects over several years.

Pandemic Response Accountability Committee

Our review showed that the City of Springfield generally used its CDBG-CV funds in accordance
with the goals and objectives of the program. Like the annual CDBG program, one of the CDBG-CV
program goals is to develop viable urban communities by expanding economic opportunities,
principally for low- and moderate-income persons. The City of Springfield demonstrated that its
program expenditures met this goal by providing grants to eligible businesses and non-profit
organizations to pay for allowable expenses such as rent, utilities, and other operating expenses.
In addition, the City of Springfield had a process in place to ensure that the grants benefited lowand moderate-income persons through job retention and public services provided.

Participant Experience
City of Springfield officials believed that the CDBG-CV funding had a positive impact on its ability to
respond to the pandemic. The city attributed its swift and effective response to the pandemic to
key elements which included having received a direct allocation of program funds from HUD,
a good working relationship and direct communication
with HUD officials at the Boston field office, the city’s
FOR MORE INFORMATION
previous experience responding to disasters, partnerships
with nonprofits that had experience working with low- and
For more information about Community
moderate-income populations, and the weekly meetings
Development Block Grant – CARES Act
that facilitated communication and coordination across
program spending across the country,
city departments.
visit the PRAC’s website.

Pandemic Response Accountability Committee

PROGRAM SNAPSHOT

Coronavirus Relief Fund
U.S. Department of the Treasury

In March 2020, the city of Springfield, MA, experienced 54 positive cases of COVID-19 which surged
to 1,069 by April 2020. Through March 2, 2023, Springfield confirmed 171,829 cases. The city,
with a 2021 population of 154,064, was challenged with responding to COVID-19 effects including
overcoming economic impacts such as food insecurity of vulnerable demographic groups, staffing
shortages, increased prices, and shortages in PPE, and developing a permanent remote learning
environment for 25,000 students. In response,
the city leveraged its deficit spending account to
establish necessary food programs and procure
SPRINGFIELD DEMOGRAPHICS
items such as PPE to mitigate the spread and
Springfield is the third largest city in the
impacts of COVID-19 prior to receipt of federal
Commonwealth of Massachusetts and the fourth
funds. Springfield officials noted that upon
largest city in New England with a population of
receipt of federal funding, the city leveraged
154,064. The city is diverse with high levels of
its strong operational continuity from previous
poverty. More than 80 languages are spoken
experience with federal and state entities to
throughout the city.
efficiently obtain and distribute the funds to
needed communities.
The COVID-19 public health emergency significantly impacted the operations of Springfield’s
Department of Health and Human Services (Springfield’s HHS) and the Springfield Public
Schools (SPS) district. Springfield’s HHS began its response to the pandemic when the first
cases of COVID-19 were confirmed in March 2020. Springfield’s HHS focused initial operations
on community messaging providing reassurance during uncertain times as well as education
on protective measures. Early responses by Springfield’s HHS included conducting weekly press
conferences on infection rates, community impact, and mitigation strategies including contact
tracing to prevent the spread of COVID-19. Springfield’s Mayor regularly attended Springfield’s
HHS’ briefings to reinforce community messaging by providing residents health trends and
statistical updates on COVID-19 data. However, Springfield’s HHS initially experienced difficulties
in communicating health and safety information due to a lack of employees fluent in the many
languages spoken throughout the city. To assist with communication challenges, Springfield HHS
hired six contact tracers fluent in several languages spoken throughout its communities.
SPS was faced with adapting from in person to virtual learning and providing food to families

Pandemic Response Accountability Committee

who relied on the system for daily meals. SPS leveraged laptops previously purchased under a
legacy program to ensure students continued learning remotely. In March 2020, SPS pivoted from
providing in school meals to preparing boxed meals for families and senior citizens. Additionally,
drive up distribution centers were established throughout the city to issue meals and laptops.
Springfield leveraged transportation services and buses to distribute meals to families without
access to drive up distribution centers. SPS provided families internet access and established a
technical helpdesk capable of providing assistance in more than 80 different languages.

Program Information
The CARES Act7 established the Coronavirus Relief Fund (CRF) and appropriated $150 billion
for the U.S. Department of the Treasury (Treasury) to make payments to states, eligible units of
local governments,8 the District of Columbia, U.S. territories,9 and tribal governments (collectively
referred to as “prime recipients”). As of December 31, 2022, Treasury disbursed CRF payments to
964 prime recipients, which subsequently distributed the proceeds to 89,969 subrecipients and
beneficiaries through contracts, grants, loans, direct payments, or fund transfers. CRF payments
enabled prime recipients and subrecipients to provide fast and direct economic assistance
to impacted workers, families, small businesses, and industries in response to the COVID-19
pandemic. For example, CRF could be used to address medical or public health needs, acquire PPE,
provide small business assistance, facilitate distance learning, and provide economic support to
those suffering from employment or business interruptions and closures.
The CARES Act required CRF recipients to use the funds to cover expenses that (1) were necessary
expenditures incurred due to the public health emergency with respect to COVID-19; (2) were not
accounted for in the recipients’ budget most recently approved as of March 27, 2020; and (3) were
incurred during the covered period (March 1, 2020 through December 31, 2021).10 Prime recipients
are responsible for reporting CRF expenditures to Treasury on a quarterly basis during the covered
period in a grant reporting system.11
As a prime recipient, the Commonwealth of Massachusetts’ responsibilities included, but
were not limited to, providing guidance to subrecipients and beneficiaries, reiterating federal
requirements, and reviewing subrecipients’ expenditure reports to assess compliance with CRF
eligible use requirements. Springfield was not a prime recipient of CRF funding. Springfield received
funding through the Commonwealth of Massachusetts, as a subrecipient. The Commonwealth
of Massachusetts Department of Public Health conducted weekly meetings to collaborate and
7
8

P. L. 116-136 (March 27, 2020).
Title V of the CARES Act defines a unit of local government as a county, municipality, town, township, village, parish, borough, or other unit of
general government below the state level with a population that exceeds 500,000; an eligible unit of local government serves a population of
over 500,000 and certified its proposed uses of the funds received from the CRF.
9 The U.S. territories are as follows: United States Virgin Islands, Guam, American Samoa, Puerto Rico, and Commonwealth of the Northern
Mariana Islands.
10 The Consolidated Appropriation Act, 2021, P. L. 116-260 (December 27, 2020), amended the CARES Act by extending the covered period for
recipients of CRF payments to use proceeds through December 31, 2021. The period of performance end date for tribal entities was further
extended to December 31, 2022 by the State, Local, Tribal, and Territorial Fiscal Recovery, Infrastructure, and Disaster Relief Flexibility Act,
Division LL of the Consolidated Appropriations Act, 2023, P.L. 117-328, December 29, 2022, 136 Stat. 4459.
11 Treasury OIG uses a grant reporting system, to capture prime recipients’ CRF expenditures.

Pandemic Response Accountability Committee

disseminate consistent CRF guidance, updates, and news to local health departments. Additionally,
the Commonwealth’s Department of Housing and Community Development provided guidance
directly to subrecipients and beneficiaries through weekly meetings, e-mail distribution, and a
Frequently Asked Questions portal. Overall, the three selected subrecipients and beneficiaries in
Springfield indicated guidance was clear and the Commonwealth of Massachusetts was very
responsive to guidance clarification inquiries.12

Program Impact
As of March 31, 2022, Treasury disbursed more than $2.4 billion in CRF award funds to the
Commonwealth of Massachusetts, which awarded nearly $34.13 million to 23 subrecipients
and beneficiaries located within Springfield through transfers, direct payments, grants,
and contracts. As of March 31, 2022, the 23 subrecipients and beneficiaries had expended
approximately $31.48 million (92 percent) of CRF funding to assist with overcoming local
community pandemic impacts. For detailed review, we selected a sample of $20.46 million of the
$27.4 million (75 percent) in expenditures for three specific subrecipients of the Commonwealth of
Massachusetts geographically located in Springfield to determine whether they used the funds in
alignment with the program’s goals and objectives.
Selected CRF subrecipients and beneficiaries used the funds to assist vulnerable and economically
impacted community populations, disseminate pandemic related information, facilitate distance
learning, and promote a safe return to schools and municipal buildings. Additionally, based on
our analysis of the sampled expenditures, CRF funding was generally used in alignment with the
program’s goals and objectives of preventing and mitigating the impacts from the COVID-19 public
health emergency. Specifically, two of the three subrecipients and beneficiaries complied with the
CARES Act, Treasury Guidance, and Treasury OIG guidance; however, Springfield’s HHS did not
maintain adequate support documentation for the use of $300,000 in CRF award funds.13

Springfield
As of March 31, 2022, the Commonwealth of Massachusetts distributed $21.35 million in CRF
award funds directly to the city, which expended $18.92 million (89 percent). The city allocated
the funds to Springfield’s HHS, SPS, the Elections Commission, Community Development, Police
Department, Fire Department, and the Springfield City Library. Springfield’s HHS and SPS used CRF
award funds to aid vulnerable community populations, communicate pandemic related information,
ensure student success during remote learning, and facilitate a safe return to school. Springfield’s
HHS created a community member committee named Vax Force to serve as a liaison to assist with
identifying needs and providing vaccine information to vulnerable residents. SPS used CRF award
12 We selected three subrecipients for review in this report.
13 Department of the Treasury Office of Inspector General Coronavirus Relief Fund Frequently Asked Questions Related to Reporting and
Recordkeeping (OIG-CA-20-028R, March 2, 2021). The CARES Act provides Treasury OIG the responsibility for monitoring and oversight of
the receipt, disbursement, and use of CRF payments. Treasury OIG also has authority to recover funds if it is determined recipients failed to
comply with the requirements of subsection 601(d) of the Social Security Act, as amended, (42 U.S.C. 801(d)). Treasury OIG provided recipients
reporting and record retention requirements.

Pandemic Response Accountability Committee

funds to provide low-income families and students with in home reliable Wi-Fi access at little or no
cost. The SPS Culinary and Nutrition Center distributed more than 8.7 million meals to families
by establishing 23 grab and go meal locations and supported the delivery of more than 14,000
meals to senior centers. Additionally, SPS invested more than $1.5 million in preparation for a
safe return to 55 schools and municipal buildings by installing ventilation equipment including air
cleaners and filters.
Springfield’s HHS did not maintain adequate supporting documentation for the use of $300,000 in
CRF award funds. Treasury OIG guidance clarifies that recipients of a CRF award should maintain
and make available to the Treasury OIG upon request all documents and financial records sufficient
to establish compliance with eligible use requirements. The Commonwealth of Massachusetts
awarded $385,017 to Springfield, which was comprised of $300,000 in CRF award funds for the
Board of Health grants and $85,017 in state-funded Public Health Trust Funds.14 Springfield then
allocated $385,017 to Springfield’s HHS. Springfield’s HHS did not separately identify and account
for the CRF award funds and Public Health Trust Funds expenditures because the Commonwealth
of Massachusetts did not require Springfield or Springfield’s HHS to maintain separate accounting
records for each funding source, resulting in the Treasury OIG being unable to establish whether
eligible use requirements were met.15

Rental Assistance Management Company
As of March 31, 2022, the Commonwealth of Massachusetts distributed $2.93 million in CRF
award funds to a company managing rental assistance, which expended all the funding. Prior to the
pandemic, the company supported the Commonwealth of Massachusetts by managing the Rental
Assistance for Families in Transition program. The program provides emergency rental assistance to
low-income households struggling to pay rent. Due to the unprecedented amount of unemployment
as a result of COVID-19, the Commonwealth expanded the program, using CRF award funds, to
assist households struggling to pay rent by issuing stipends for overdue rent and future rent to
prevent homelessness and eviction. Also, the CRF award was used to increase the company’s
staffing for the program from approximately four staff to 70 staff. This expansion enabled
the program staff to respond to applicants within 48 hours and provide timely assistance to
struggling households.

Childcare Resource and Referral Non-Profit Organization
As of March 31, 2022, the Commonwealth of Massachusetts distributed $5.55 million in CRF
award funds to a childcare resource and referral organization, which expended all the funding.
The organization is a childcare resource and referral agency for Springfield’s Department of Early
Education. The organization provides educational, workforce development, housing and shelter, fuel
assistance, and childcare voucher services to qualifying individuals and families. For example, the
organization used the funding for childcare tuition payments on behalf of subsidized parents to
14 The Expanded Gaming Act of 2011 was signed into state law by the Commonwealth Governor. The Act established and also allocates resources
to the Public Health Trust Funds to mitigate the harms associated with gambling through research, prevention, intervention, treatment, and
recovery support services.
15 Treasury OIG will be issuing a separate memorandum to the U.S. Department of the Treasury regarding Springfield’s questioned costs.

Pandemic Response Accountability Committee

help prevent childcare facilities going out of business. Additionally, the organization established
a virtual learning environment to ensure children impacted by childcare facility closure
continued to receive education.

Participant Experience
Satisfaction
All three selected subrecipients and beneficiaries expressed overall satisfaction with the
CRF allocation process and amounts, and the ability to use the funds to address their needs/
challenges due to the pandemic. City officials noted they initially did not have a federal point of
contact for the CRF program. However, the Commonwealth of Massachusetts was able to coordinate
with Treasury and the city has been in communication with Treasury officials as to CRF eligible use
requirements. Springfield officials stated the city was grateful that it could use CRF award funds for
COVID-19 related purchases that other federal funds would not cover.

Challenges
City officials expressed that the main challenges were that the Commonwealth of Massachusetts
eligible use guidance interpretation periodically changed and was at times inconsistent. For
example, the Commonwealth of Massachusetts would initially approve and later deny expenditures.
The Commonwealth of Massachusetts also required the city to report all expenditures by May
2022, which is seven months prior to the submission deadline for the CRF award final reports on
December 31, 2022, for prime recipients. If the city did not complete its reports, it risked having any
unobligated or unapproved CRF award funds recovered by the Commonwealth of Massachusetts.
SPS officials believed that sufficient time was not provided for departments to make strategic
decisions on the use of CRF award funds.
Officials from the rental assistance management company and the childcare resource and referral
organization in our sample expressed that at the time of our interviews residents continued to
feel the impacts of COVID-19 as they still struggle to pay rent and childcare fees, many people
have not been able to return to work because of COVID-19, and many families have childcare
needs that have not yet been served.

FOR MORE INFORMATION
For more information about Coronavirus
Relief Fund program spending across
the country, visit the PRAC’s website,
including an interactive dashboard.

Pandemic Response Accountability Committee

PROGRAM SNAPSHOT

COVID-19 Public Assistance
Emergency Protective Measures
U.S. Department of Homeland Security
Congress provided the Federal Emergency Management Agency (FEMA) with pandemic funding for
its relief and response efforts through three laws: the CARES Act, the Consolidated Appropriations
Act of 2021, and the American Rescue Plan Act of 2021 (ARP Act). As the primary manager of
the COVID-19 pandemic-related funds appropriated to the U.S. Department of Homeland Security
(DHS), FEMA provides recovery assistance to affected individuals and communities, using contracts
and various grant programs, including Individual
Assistance, Public Assistance (PA), and Hazard
Mitigation Grants. From 2020 – 2022, FEMA
COVID-19 IMPACT ON
obligated approximately $56.5 billion to assist
the nation in addressing the challenges of the
SUBRECIPIENTS
pandemic with FEMA’s PA Emergency Protective
According to Subrecipient #4, a healthcare facility, it
Measures. Under the Robert T. Stafford Disaster
was particularly vulnerable to the impacts of COVID-19
Relief and Emergency Assistance Act, the president
due to the population they serve and the live-in
approved major disaster declarations for all fifty
group setting of the facility. They found it challenging
states, the District of Columbia, five territories, and
to isolate within the facility or quarantine those
three tribes. DHS OIG reviewed PA funds awarded to
exposed to COVID-19. Additionally, they eliminated
Springfield, MA.
visitations, daily activities, and programs to reduce
the potential virus spread but the lack of connectivity

The PA program seeks to provide federal
with the external community worsened their residents’
reimbursement of state, local, territorial, and
experience. Overall, they reported that COVID-19 was
Tribal government costs resulting from emergency
financially, physically, and emotionally draining.
protective measures, and the restoration of
disaster-damaged, publicly owned facilities as
a result of declared disasters. For the COVID-19
declarations, the President authorized reimbursements limited to PA Emergency Protective
Measures. These measures include, but are not limited to, medical care and transportation;
supplies and commodities (personal protection equipment); mass mortuary services; and
dissemination of public information that provides guidance about health and safety hazards.
To be eligible for PA Emergency Protective Measures funding, costs claimed must be necessary to
address immediate threats to public health and safety caused by the COVID-19 pandemic and be
reasonable pursuant to Federal regulations and Federal cost principles. Although some activities

Pandemic Response Accountability Committee

listed above may be eligible for funding through the U.S. Department of Health and Human Services
(HHS), Centers for Disease Control and Prevention, final reimbursement determinations will be
coordinated by HHS and FEMA. FEMA will not duplicate assistance provided by HHS or other
Federal agencies.

Public Assistance Impact
In Springfield, MA, six entities applied for PA Emergency Protective Measures funding by
submitting 15 projects16 for reimbursement. FEMA reviewed the projects, determined eligible
uses of PA funding that aligned with the goals and objectives of the PA program, and obligated
$16.8 million to these entities as of July 26, 2022. For costs FEMA determined as ineligible, it
denied funding. FEMA’s reasons for denying funding included increased operating costs not directly
resulting from the disaster and costs covered by other funding sources. Table 1 lists the status of
each subrecipient’s request as of July 26, 2022.
Table 1: FEMA Public Assistance to Springfield, MA, as of July 26, 2022
Sub-Recipient Sub-Recipient Sub-Recipient Sub-Recipient Sub-Recipient Sub-Recipient
1
2
3
4
5
6
SubRecipient
Type

Education

Local
Municipality

Healthcare
Facility

Education

Healthcare
Facility

Requested
Amount

$1,487,500

$164,194

$3,341,929

$109,903

$39,327

$15,333,567

Denied
Amount

$182,700

$1,569,371

$72,326

$32,225

$19,088

Obligated
Amount

$1,304,800

$164,194

$37,577

$0a

$15,314,479

Status

Obligated

Pending

Obligated

Withdrawn

Obligated

N/A

PPE, cleaning
supplies,
medical
supplies,
disinfection
services,
temperature
screening
services

Use

COVID-19
testing

PPE, cleaning
supplies,
barriers

N/A

PPE, cleaning
supplies,
shelter,
overtime

Source: DHS OIG compilation of FEMA Grants Manager data. Grants Manager is FEMA’s system of record.
a

Subrecipient #5 withdrew from the PA program and did not receive any obligations.
16 A project is a logical grouping of work required as a result of the declared major disaster or emergency. (44 CFR § 206.201)

Pandemic Response Accountability Committee

Three of six entities who applied for FEMA’s PA Emergency Protective Measures said the federal
funds received minimized the financial burden caused by COVID-19. The subrecipients reported
that they could immediately respond to the pandemic by using available funds from their
individual reserve accounts. However, FEMA’s reimbursement of COVID-19 costs was very helpful
in their financial recovery. For instance, subrecipient #1 said it did not take on loans to cover
initial expenses and instead used its own reserve funding, which PA funding helped replenish.
Subrecipient #4 said that PA funding was very helpful in reimbursing PPE and cleaning costs.
Overall, the subrecipients in Springfield used PA funding on items such as PPE, cleaning supplies,
COVID-19 testing, and vaccinations costs. In addition, they received funding for shelter, overtime,
medical supplies, computer equipment, plastic barriers, temperature screening services, and
laundry disinfection services.

Participant Experience
Although all subrecipients had prior experience with applying for or receiving federal funding, the
local municipality (subrecipient #3) and a healthcare facility (subrecipient #6) chose to hire a
consultant for technical assistance to help with the PA application process.

REIMBURSEMENT, A
BARRIER TO SMALLER
APPLICANTS
Local government officials indicated that
fiscal limitations affected some smaller
entities’ ability to participate in FEMA’s PA
reimbursement process. Those entities
said they did not have the option to wait
for FEMA reimbursements because they
did not have the funds available to cover
initial costs. As a result, they did not
seek assistance from FEMA and instead
pursued other funding sources outside of
FEMA that provided advance assistance.

However, local government officials said they completed
most of the application process without the consultant’s
assistance because they did not want to grant the
consultant access to their financial information. Additionally,
the uncertainty of the pandemic and the new PA rules
associated with the COVID-19 declaration further limited
the consultant’s assistance. Despite this, officials said
that hiring a consultant ultimately helped them navigate
FEMA’s guidance, eligibility requirements, and FEMA’s
Grants Portal.17

Local officials also shared some challenges associated with
the PA reimbursement process. For example, they said that
FEMA’s data requirements for reimbursement requests and
communicating with FEMA on cost eligibility issues was time
and resource consuming. Overall, subrecipient #3 officials
said less restrictive FEMA eligibility requirements, more like
CRF requirements, would be helpful. In their opinion, the
CRF was the most lenient Federal program for funding qualification and fastest to provide funds of
the available Federal pandemic funding sources.
Subrecipient #6 received funding for most of their reimbursement requests. Although their overall
17 FEMA uses Grants Portal as the applicant and sub-applicant facing information system. Grants Manager is the FEMA side of that same system.

Pandemic Response Accountability Committee

experience with FEMA was positive, they outlined several challenges. Subrecipient #6 hired a
consultant for technical assistance with FEMA’s PA application process. However, they quickly
learned that the consultant was not familiar with pandemic-related guidance, which ultimately
slowed down the subrecipient’s application process. As a result, subrecipient #6 ended the contract
with the consultant and relied on in-house resources to complete the application process.
In addition, they experienced challenges when attempting to simultaneously upload multiple
documents into FEMA’s Grants Portal and when completing FEMA forms, resulting in extensive
use of time and human resources. Subrecipient #6 also expressed concerns that FEMA’s
documentation requirements for reimbursement were too stringent.
Four subrecipients (#1, #2, #4, and #5) chose not to hire a consultant and worked directly with
their Massachusetts Emergency Management Agency (MEMA) representative. These subrecipients
stated that MEMA provided guidance on the process through email updates, webinars, and followup meetings. According to these subrecipients, MEMA’s guidance helped them understand which
costs were eligible for FEMA reimbursements. However, subrecipient #2 told us that they submitted
two projects for reimbursement at the same time, but only one was approved. The other project
remained in FEMA’s appeals process for months with no communication from FEMA for over 90
days. Although subrecipients #1, #2, and #6 did not work directly with FEMA, they said that their
overall experience navigating the FEMA grant process was better than their experiences with other
Federal grants.
Finally, subrecipient #5 told us it withdrew its request for PA reimbursement after FEMA denied
reimbursement. Specifically, subrecipient #5 told us they spent additional time and resources on
the PA application process to request reimbursement for portable hand-washing stations, touchless
hand-sanitizing stations, disinfectant spray, wipes,
gloves, safety gowns, laptop-cleaning materials,
and air purifiers. Ultimately, on December 15,
FOR MORE INFORMATION
2020, FEMA determined Subrecipient #5’s
For more information about the FEMA’s COVID-19
reimbursement requests were for increased
Public Assistance Emergency Protective Measures
operating costs, and, therefore, were ineligible for
spending across the country, visit the PRAC’s website.
PA reimbursement.18

18 The OIG has not verified this information as part of this study. The OIG has an ongoing audit being conducted in conformance with Generally
Accepted Government Audit Standards of FEMA’s Public Assistance Program in Response to the COVID-19 Pandemic (OIG-22-047-AUD-FEMA).

Pandemic Response Accountability Committee

PROGRAM SNAPSHOT

Elementary and Secondary School
Emergency Relief Program
U.S. Department of Education
The CARES Act created the Education Stabilization Fund which provided $30.75 billion to the U.S.
Department of Education “to prevent, prepare for, and respond to coronavirus, domestically or
internationally…”19 The CARES Act also created the Elementary and Secondary School Emergency
Relief (ESSER) program—a subprogram of the Education Stabilization Fund. The ESSER program
received funding through three pandemic related laws, and each law created different rounds in
the program’s implementation. Each round had slightly different funding totals, program expiration
dates, and planning or reporting requirements. To support local schools, the U.S. Department of
Education first provided ESSER funding to state education agencies, which then provided funds to
local education agencies (i.e., local school districts).20
• ESSER I: A first round of ESSER funding came from the CARES Act, and provided $13.23 billion
to prevent, prepare for, and respond to the coronavirus, domestically or internationally. ESSER I
funds could be used to address the impact that the COVID-19 pandemic had on elementary
and secondary schools across the country. ESSER I funds were intended to help schools safely
reopen, sustain safe operation, and address the pandemic’s impact on students.
• ESSER II: A second round of ESSER funding came from the Coronavirus Response and Relief
Supplemental Appropriations Act, 2021, and provided $54.31 billion. ESSER II funds were to
be used for the same purpose as ESSER I funds.
• ESSER III: A third round of ESSER funding came from the ARP Act and provided $121.97
billion. At least 20 percent of local education agencies ESSER III funds must be used to
address the academic impact of lost instructional time (i.e., learning loss). The remaining
funds may be used for the same purposes as ESSER I and ESSER II funds. For ESSER III, each
local education agency was also required to submit a plan to the state education agency
“within a reasonable timeline determined by the [state education agency]” on the use of the
funds, how it engages and consults with stakeholders when developing its plan, and how it
intends to make the plan publicly available and explain the safe return to in-person instruction
and continuity of services.21
19 See CARES Act, P.L. No. 116-136, Division B, Title VIII, (March 27, 2020).
20 SEAs also reserved funds in accordance with the guidance described in the U.S. Department of Education’s ESSER and GEER Use of Funds
FAQs; December 7, 2022. See questions A-8 through A-12.
21 See Department of Education’s Elementary and Secondary School Emergency Relief Programs and Governor’s Emergency Education Relief
Programs, Frequently Asked Questions, December 7, 2022 Update, question A-4.

Pandemic Response Accountability Committee

During phase one of this review, we found that school districts within the boundaries of Springfield,
MA, were awarded almost $272 million in ESSER funds. As of September 30, 2021, these school
districts had spent $12.8 million in funds from ESSER I and ESSER II but had not yet spent any
funding from ESSER III funds. See Table 2 for more information about the total ESSER funding for
Springfield, MA, schools.
Table 2: Springfield, MA,ESSER Funding Information, as of September 30, 2021

Total Obligated or Awarded

Total Expended

Expiration Date

ESSER I

$20,147,232

$12,002,248a

9/30/2022

ESSER II

$79,035,504

$775,220

9/30/2023

ESSER III

$172,779,167

9/30/2024

Total

$271,961,903

$12,777,468

This total includes expenditures by SPS and charter schools, as well as equitable services for non-public schools. See ED’s
Providing Equitable Services to Students and Teachers in Non-Public Schools Under the CARES Act Programs for further details
about equitable services for non-public schools.

Program Impact
For Springfield, MA, our work covered SPS—which is the largest school district within the city. Of
the $12 million in ESSER I funds that had been spent by all school districts within the city and
for equitable services for non-public schools
by September 30, 2021, SPS’ expenditures
represented approximately 80 percent of the
SPRINGFIELD PUBLIC
total—about $9.6 million. SPS has more than 60
SCHOOLS OPERATING STATUS
schools that employ about 4,500 teachers and
staff who support the learning and development
End of 2020 School Year
of approximately 26,000 students. The Springfield
Fully remote learning.
School Committee, chaired by the mayor of
2020 – 2021 School Year
Springfield, governs SPS, which is a department of
22
Springfield’s municipal government.
Fully remote learning through April 2021. Hybrid
ESSER I, II, and III funds awarded to SPS totaled
almost $244 million. No ESSER II or ESSER III
funds had been spent by SPS as of September 30,
2021. See Table 3 for a description and breakdown
of ESSER I spending by SPS.

learning (combination of in-person and remote
learning) began in April 2021.

2021 – 2022 School Year
Began in-person learning, with some students
doing remote learning. Hybrid learning was
allowed for some students.

22 Springfield Public Schools Operating Budget for Fiscal Year 2022.

Pandemic Response Accountability Committee

Table 3: ESSER I Spending by SPS, as of September 30, 2021
Description

ESSER I

Contracted Services

$846,862

Staff and Benefits

$2,698,402

Supplies and Technology

$5,858,306

Transportation

$183,465

Total SPS Expenditures

$9,587,035

(expenditures incurred by SPS and reimbursed by the state)

At the beginning of the pandemic, SPS officials stated that they generally focused on obtaining
laptops and tablets for students who did not already have one (mainly pre-kindergarten through
second grade), setting up an IT structure to support virtual programming, and setting up hotspots
around the city so students could attend virtual school and complete their homework. Due to virtual
and hybrid instruction during the pandemic, SPS officials stated that the district was tasked with
trying to address gaps in learning. To help, SPS had a larger than normal 2021 summer school,
and spent ESSER funding on stipends for staff who supported summer school (coded as "Staff and
Benefits" in Table 3). To further address gaps in learning, SPS used ESSER funds to make supplies
and technology purchases focused on comprehensive interactive literacy, foundational reading skills,
social studies, adaptive learning, and STEM (e.g., science, technology, engineering, and math).
While our review covered SPS' reported ESSER expenditures from the beginning of the pandemic
through September 30, 2021, we also spoke with officials about SPS’ future needs and overall
response throughout the pandemic. We also reviewed their ESSER III Implementation plan—
required by the U.S. Department of Education. Under ESSER III requirements, at least 20 percent
of a school district’s funds must be spent on mitigating the academic impacts of lost instructional
time. According to SPS' ESSER III plan, the district sought to do this with the following activities:
• Extending the school day/year.
• Tutoring programs and support, including
early literacy tutoring (including training
paraprofessionals) and peer tutoring
programs.
• Acceleration academy opportunities—
intensive, targeted, instructional programs
during vacation breaks—and summer learning
opportunities for individualized instruction and
enrichment.

SPS PRINCIPALS SURVEY
Almost 87 percent (33 of 38) of SPS principals who
responded to our survey answered, “Very Satisfied” or
“Somewhat Satisfied“ to the question “How satisfied
were you with the flexibility of federal funding to meet
your school's needs in order to support your school,
teachers, and children who attend your school?”
Only 5 percent responded, “Very Dissatisfied” or
“Somewhat Dissatisfied.”

• Expanding access to full-day, high-quality
pre-kindergarten.

Pandemic Response Accountability Committee

In addition to supporting learning loss-related activities, SPS planned to prioritize “prioritize[d]
social emotional, and counseling supports for families.”23 SPS plans to spend part of its ESSER III
funds on some of the following activities:
• Increasing personnel and services to support holistic student needs, including school
guidance and adjustment counselors, nurses, psychologists, or social workers.
• Arranging for wraparound services such as counseling to be provided at schools.

Participant Experience
SPS officials stated that city government officials had past experiences coordinating with
federal and state agencies, like FEMA, to respond to disasters in their community. One of the
largest lessons learned from previous disaster experience, officials said, was maintaining strong
relationships with state and federal agency contacts, as well as fostering strong relationships with
their elected representative.
SPS officials were informed by the Massachusetts Department of Elementary and Secondary
Education that ESSER III projects would have a more robust approval process. They stated that
SPS applied for ESSER III funds in September 2021 with the objective of completing maintenance
projects for school building renovations during summer 2022. These types of projects generally
need to be completed during the summer while schools are on break. According to SPS officials,
they did not receive approval from the state until a few weeks before our site visit in May 2022,
which officials anticipated could delay the projects by at least a year.24 SPS officials stated that they
would have preferred for the funding to come directly to the district instead of going through the
state education agency first.

SPOTLIGHT ON | FEEDING STUDENTS DURING THE PANDEMIC
Although schools across the nation closed, nutritional needs of school children continued. In
response to this, the Department of Agriculture granted schools more flexibility with feeding
children, including providing home delivery of meals, allowing parents or guardians to pick-up meals
for kids without their children being present, and providing multiple meals at once. While SPS did
not spend ESSER funds to provide meals to students during the period reviewed, supporting longterm closure activities, like providing meals to eligible students, would have been an allowable use
of ESSER funds.
Under these flexibilities and the need to ensure schoolchildren received food during the pandemic,
SPS set up 13 food distribution sites eventually increasing the number of sites to 18. Kids could
pick up breakfast, lunch, snack, and dinner. SPS served more than 8.7 million meals from the
23 Springfield Public Schools Operating Budget for Fiscal Year 2022.
24 Officials with the Massachusetts Department of Elementary and Secondary Education contracted with an architect to review constructionrelated projects and costs prior to approval by the state.

Pandemic Response Accountability Committee

beginning of the pandemic. They also used these sites to distribute the work packets for the
children to complete at home.
In addition to the 18 food distribution sites, the school district used their food distribution center
that had been opened five years prior to the start of the pandemic. This facility had been set up to
prepare food in-house for the entire district and to obtain cost savings by buying in bulk. Because
SPS was already using this facility to make and distribute food to the school kitchens, they already
had a base model in place to get food out quickly. Management explained that they used some
pandemic response funds to purchase a new piece of equipment for the center to prepare “TV
dinner” frozen food options that could be reheated in the oven or the microwave at home.

FOR MORE INFORMATION
For more information about the Education Stabilization
Fund, including Elementary and Secondary School
Emergency Relief program spending across the
country, visit the PRAC’s website.

Pandemic Response Accountability Committee

PROGRAM SNAPSHOT

Farmers to Families Food Box
Program
U.S. Department of Agriculture
At the onset of the COVID-19 pandemic, many restaurants, hotels, schools, and other food service
entities were forced to close or scale back operations. These closures had negative impacts on the
food supply chain from farmers and other producers, distributors, food services, and hospitality
entities. As a result of these supply and logistical issues, and reports of produce rotting in fields, the
U.S. Department of Agriculture (USDA) established the Farmers to Families Food Box Program (Food
Box Program) to mitigate the problems.
The purpose of the Food Box Program was to connect food—which would have otherwise been
sold to restaurants, hotels, schools, and other food service entities—to regional and local food
distributors. These distributors would purchase the food, packaged it in boxes, and delivered
fresh produce, dairy, and meat products to non-profit and governmental organizations, who in
turn would distribute these boxes to families and individuals in need.25 USDA contracted directly
with the distributors to administer five rounds of the Food Box Program. According to USDA,
this program delivered approximately 176 million food boxes worth $5.47 billion to nonprofit
and governmental organizations from May 2020 to May 2021. See Figure 1 below for more
information about the Food Box Program’s goals.
Figure 1: Three Primary Goals of the Food Box Program

Providing an alternative
outlet for domestic
Food Producers (e.g.,
farmers) faced with
declining demand
because of the closure
of food service entities.

Helping Food
Distributors retain jobs
that could have been
lost because of closures
of food service entities.

Delivering food boxes
to governmental
and nonprofit Food
Recipient Organizations
who gave the food to
families in need.

25 Food Distributors could only deliver boxes containing certain types of food or fluid milk (e.g., Dairy Box or Meat Box) or boxes that contained a
combination of food and fluid milk (e.g., Box containing both Dairy and Meat). Dairy boxes were standalone boxes in rounds 1 & 2 of the Food
Box Program, and combination boxes containing fresh produce, meat, and fluid meat were available in rounds 3, 4, & 5.

Pandemic Response Accountability Committee

Program Impact
For this review, we estimated that food distributors delivered 74,535 food boxes26 (valued at
$2,511,652) to nine food box organizations to feed families in Springfield, MA. However, since
USDA did not consistently obtain data to identify all organizations or food boxes received and had
inconsistencies within the data that it did receive, Springfield, MA, could have received a higher
or lower number of food boxes than our estimate. Based on the data obtained from USDA for nine
organizations, we noted that collectively these organizations participated in the first three rounds of
the Food Box Program. Table 4 below has more details about the boxes delivered to Springfield.
Table 4: Food Boxes Distributed to Springfield, MA

Food Recipient Organization

Round
Number

Number of
Food Boxes

Value

1,515

$60,600

2,364

$94,560

650

$26,000

24,192

$724,550

135

$4,428

138

$4,526

20,160

$793,498

1,848

$85,821

504

$19,837

16,296

$488,065

171

$9,285

138

$7,493

1,198

$32,316

2,034

$65,071

2,730

$81,764

462

$13,837

74,535

$2,511,652

Food Recipient Organization 1

Food Recipient Organization 2
Food Recipient Organization 3
Food Recipient Organization 4
Food Recipient Organization 5
Food Recipient Organization 6
Food Recipient Organization 7

Food Recipient Organization 8

Food Recipient Organization 9
Totals

Type of Food Boxes
Delivered
Fresh Fruit and
Vegetable Box
Combination Box
Combination Box
Combination Box
Combination Box
Combination Box
Precooked Meat Box

Fresh Fruit and
Vegetable Box
Combination Box

Source: USDA OIG Analysis of Food Box Program Data for Springfield, MA.

26 We found inconsistencies in the data because zip codes that are solely in Springfield, MA, are included in cities other than Springfield. Our
estimate includes all zip codes associated with Springfield, MA, even if the city name in the record was not Springfield, MA.

Pandemic Response Accountability Committee

While we were able to speak with one nonprofit
organization about its experience with the Food
Box Program, we faced challenges in getting
more community-specific information about the
total number of families served and whether
other organizations had received food boxes. We
also could not determine if any of the farmers or
ranchers providing food boxes to Springfield had
declining demand for the food they were producing
and benefited from the Food Box Program.
According to a GAO report,27 USDA did not collect
data to evaluate whether the Food Box Program
met some of its’ primary goals. The PRAC
observed this lack of this data, and it limited us
from determining if USDA had met the program’s
goals in Springfield. Under the program’s
structure, the food distributors provided USDA with
an invoice detailing the number, type, and cost
of the food boxes delivered, including high-level
information about the non-profit and governmental
organizations that received the boxes. However, this
structure did not provide information about which
farmers the program helped and how many boxes
were actually provided to families (and how many
families), or consistent information about which
organizations received food boxes for distribution.

LEARN MORE ABOUT THE FOOD
BOX PROGRAM
USDA OIG and the Governmental Accountability Office
(GAO) have released reports and data stories about
the Food Box program:
USDA OIG, COVID-19—Farmers to Families Food Box
Program Administration, Rpt. No. 01801-0001-22,
August 15, 2023
USDA OIG, COVID-19—Farmers to Families Food Box
Program Administration—Interim Report, Rpt. No.
01801-001-22(1), June 24, 2022
USDA OIG, USDA Farmers to Families Food Box
Program Data Story, June 22, 2022
GAO, USDA Food Box Program – Key Information
and Opportunities to Better Assess Performance,
GAO-21-353, September 8, 2021

Participant Experience
During our onsite work in Springfield, we met with one food box recipient organization that served
Springfield (and the surrounding area) during the pandemic. This organization is located in Hatfield,
MA, which is in the same county (Hampden County) as Springfield and runs food pantries in four
different counties in western Massachusetts.
The organization received boxes during the first, second, and third rounds of the Food Box Program.
They indicated that they had received an over-abundance of produce boxes and that it became
a challenge to distribute these boxes before the food rotted given the short shelf-life of some
produce items. The abundance of food boxes also resulted in one local farmer losing business.
The organization quit purchasing from the farmer due to having enough boxes and the difficulties
offloading or temporarily storing the boxes before the food rotted. For the first round of the program,
the organization noted challenges delivering food boxes from the delivery trucks to the trunks of
27 GAO, USDA Food Box Program: Key Information and Opportunities to Better Assess Performance, GAO-21-353; September 2021.

Pandemic Response Accountability Committee

families’ cars—the organization is set up more like a “grocery store” food pantry and does not have
a lot of storage space. Despite these inefficiencies with “truck to trunk”, USDA recommended food
box recipient organizations use this delivery method for rounds four and five of the program. The
organization ended up storing and distributing all the boxes themselves. The food box recipient
organization also shared their struggles to find volunteers to deliver the boxes before the food rotted
because regular volunteers primarily consisted of elderly individuals who stopped out of concerns
for their health due to COVID-19.
The organization began to receive combination food boxes in later rounds and although families
greatly appreciated the variety, the organization stated that some families wished they had
more variety to address their cultural beliefs. The organization also wished it had a contact at
USDA to ask questions about the program’s intent and to communicate their community’s needs.
Overall, while they provided suggestions to make the program easier, organization officials were
grateful for the boxes citing that it helped them address food insecurity in their community.

Pandemic Response Accountability Committee

PROGRAM SNAPSHOT

Pandemic Unemployment
Insurance Programs
U.S. Department of Labor
The federal-state UI program, created by the Social Security Act of 1935, offers an economic line of
defense against the ripple effects of unemployment. Specifically, UI benefits are intended to provide
temporary financial assistance to workers who are unemployed through no fault of their own.
On March 27, 2020, the CARES Act was signed into law with the intent to provide expanded UI
benefits to workers who were unable to work as a direct result of the COVID-19 pandemic. The
CARES Act was designed to mitigate the economic effects of the pandemic in a variety of ways,
including the establishment of three key CARES Act UI programs: Federal Pandemic Unemployment
Compensation (FPUC), Pandemic Unemployment Assistance (PUA), and Pandemic Emergency
Unemployment Compensation (PEUC). The three programs were later extended by the Continued
Assistance for Unemployed Workers Act of 2020 and ARP Act, ending on September 6, 2021.
The COVID-19 pandemic was historic in its impact on the UI system. From March 28, 2020, to
September 4, 2021, the U.S. Department of Labor (DOL) reported approximately 110 million initial
jobless claims were filed for state UI (regular UI) or PUA, and 1.5 billion continued claims28 were
submitted for regular UI, PUA, or PEUC.
The Springfield, MA, unemployment rate was significantly impacted by the COVID-19 pandemic.
Massachusetts estimated the unemployment rate in Springfield peaked in April 2020 at 21.6
percent—over 213 percent greater than the prior year’s highest monthly rate (see Table 5).

28 Continued claims are ongoing weekly unemployment benefit claims by workers who previously filed an initial claim.

Pandemic Response Accountability Committee

Table 5: Springfield, MA – Unemployment Estimates

Year

Springfield
Average
Unemployment Rate

Springfield
Highest Monthly
Unemployment Rate

Massachusetts
Average
Unemployment Rate

Massachusetts
Highest
Unemployment Rate

2018

6.4

7.5

3.5

3.7

2019

5.8

6.9

3.1

3.2

2020

14.5

21.6

9.5

17.1

2021

10.5

12.4

5.8

7.1

Source: DOL OIG analysis of Massachusetts Unemployment Data.

In addition to regular UI, Massachusetts reported 24,999 unemployed workers in Springfield
received more than $444 million in federal UI benefits from FPUC, PUA, and PEUC (see Table 6).29
Table 6: Springfield, MA – CARES Act UI Benefits
CARES Act UI Program

Total Benefits Paid

FPUC provided a $600 weekly supplement through July 31, 2020. FPUC
resumed in December 2020 with a $300 weekly supplement.

$270,071,668

PUA extended UI benefits to individuals not traditionally eligible for UI benefits,
such as self-employed workers.a

$108,664,387

PEUC provided additional weeks of UI benefits to individuals who had
exhausted their regular unemployment benefits.

$65,516,420

Total Benefits

$444,252,475

Source: DOL OIG data analysis of state workforce agency claims data for the period March 27, 2020, to September 6, 2021.
a

PUA also included independent contractors, those with limited work history, and those who otherwise did not qualify for regular UI or extended
benefits under state or federal law or under PEUC.

29 State workforce agencies provided DOL OIG data about pandemic unemployment insurance-related programs as part of a data disclosure
process. The Massachusetts State Workforce Agency provided this data as of December 1, 2021.

Pandemic Response Accountability Committee

Program Information
To participate in these three CARES Act UI programs, states signed an agreement with DOL. State
workforce agencies, which administer unemployment programs on behalf of the state, were then
allowed to provide benefits to eligible UI claimants. DOL made funding available to cover additional
benefits, ongoing administrative costs, and reasonable implementation costs.
DOL’s Employment and Training Administration provides leadership, direction, and assistance
to state workforce agencies in the implementation and administration of state UI programs and
federal unemployment compensation programs. The Employment and Training Administration
provided program guidance to state workforce agencies through Unemployment Insurance Program
Letters, Training and Employment Notices, and webinars available through the UI community of
practice page located on the WorkforceGPS website, which is sponsored by the Employment and
Training Administration. As the CARES Act UI programs were temporary, the Employment and
Training Administration did not establish performance metrics specific to these programs.
Under these three new UI programs, claimants were required to file a UI claim30 to receive benefits.
State workforce agencies would then assess eligibility and provide the claimant with the applicable
regular UI and/or CARES Act UI program payments for each week certified by the claimant.

Participant Experience
CARES Act UI Program Participant Assessment
To assess the new CARES Act UI programs (FPUC, PUA, and PEUC), we judgmentally31 selected
60 Springfield residents (claimants). DOL OIG’s investigators traveled to the area, confirmed the
individuals filed a UI claim, and performed in-person interviews with the claimants. Of the 60
claimants, 20 (33 percent) who received benefits from at least one of the three key pandemic UI
programs chose to respond. The surveys were conducted from May 2, 2022, to May 9, 2022.
DOL OIG’s deliberative process for this project’s sample selection included removing possible
fraudulent claims to ensure interviews of only eligible UI claimants. To do so, DOL OIG used
fraud indicators. This removal also ensured that DOL OIG investigators did not impact ongoing
investigations or interact with possible subjects or targets of future DOL OIG investigations.

30 FPUC is provided as a supplement (add-on) benefit to an underlying UI payment, such as regular UI, PEUC, or PUA. Claimants did not file a
separate claim for FPUC benefits. FPUC benefits were added if the individuals met the eligibility requirements for the underlying week claimed.
31 Judgmental sampling is a non-probability sampling technique in which the sample members are chosen on the basis of the auditor’s
knowledge and judgment.

Pandemic Response Accountability Committee

Satisfaction with Key CARES Act UI Programs Was High—Both Overall and
with Specific Components
Generally, the majority of surveyed claimants reported the ease of completing the application
process, overall experience filing a claim, promptness of UI benefit payments, and the certification
process to continue to receive benefits as satisfying.32 Overall, satisfaction with the UI system was
rated 4.2 on a 5 point scale, with 55 percent of surveyed claimants rating their experience as
extremely satisfying (see Figure 2).
The accessibility of the UI office to answer questions and offer assistance was rated the lowest of
all aspects—20 percent of surveyed claimants rated their experiences as extremely dissatisfying.
Further, surveyed claimants identified several difficulties, such as improper denials, overpayments,
and language barriers. In an interview, the regional state workforce agency33 officials noted
technical challenges associated with the required online application, such as accessibility, language
issues, and technical barriers.

32 Surveyors asked claimants a series of questions and claimants responded with a five-point scale where 1 was extremely dissatisfied and 5 was
extremely satisfied.
33 The DOL OIG and PRAC teams interviewed officials at the MassHire Springfield Career Center. MassHire Career Centers comprise the backbone
of the state’s delivery system for employment and training services for job seekers, businesses, and workers.

Pandemic Response Accountability Committee

Figure 2: Surveyed Claimants Assessment of Claims Process

Source: DOL OIG data analysis of claimant surveys conducted from May 2, 2022, to May 9, 2022.

Surveyed Claimants Generally Felt the CARES Act UI Programs Were
Impactful, Sufficient, and Fair
The majority of surveyed claimants reported either agreeing or strongly agreeing the benefits
provided by the CARES Act had a positive impact on their ability to meet their needs, were sufficient

Pandemic Response Accountability Committee

to pay for basic necessities, and were fair and reasonable (see Figure 3).34 The surveyed claimants
also agreed or strongly agreed that the number of weeks benefits were provided was sufficient.
On average, 0 to 15 percent of surveyed claimants felt the benefits did not have a positive impact,
were insufficient, or were not fair and reasonable.
An interview with the Springfield Chamber of Commerce disclosed that employers felt claimants
could earn more by collecting UI, and, therefore, would not return to work. However, the interview
with regional state workforce agency officials indicated that there were worker shortages prior to the
COVID-19 pandemic.
Figure 3: Surveyed Claimants Assessment of Benefits

34 Surveyors offered claimants a series of statements and, for each statement, asked claimants to tell them if they: (a) strongly agreed, (b)
somewhat agreed, (c) neither agreed nor disagreed, (d) somewhat disagreed, or (e) strongly disagreed.

Pandemic Response Accountability Committee

Claimants Generally Still Experienced Difficulty in the Labor Market
Of those who responded, 20 percent of surveyed claimants reported they were not currently working
for pay, and 35 percent reported they were unable to find employment before benefits ran out.
Additionally, 65 percent of surveyed claimants reported the state workforce agency did not assist
them with finding employment. The survey did not address whether the surveyed claimants were
aware of the state workforce agency’s job placement services. However, an interview with the
regional state workforce agency officials indicated that services were provided online, and many
customers had to overcome numerous technical barriers, such as access to online resources and
level of technical fluency. Further, the regional state workforce agency office had to develop and
provide virtual employment outreach, training and workshops, and UI assistance.
Figure 4: Surveyed Claimants Return to Work Assessment

Source: DOL OIG data analysis of claimant surveys conducted from May 2, 2022, to May 9, 2022.

Pandemic Response Accountability Committee

Program Integrity
With the passage of the CARES Act and subsequent pandemic legislation, pandemic related-UI
programs became a target for fraud. DOL OIG investigators, auditors, and data scientists have
created a series of fraud indicators35 to identify potentially fraudulent UI claims. DOL OIG identified
6.3 percent of the claims submitted from Springfield, MA, as potentially fraudulent (see Table 7).
Table 7: Springfield, MA – Fraud Indicatorsa
Category

Claimants

Percent of Total

Amount Paid

Total Claimants

24,999

$444,252,475

Multistate

1,055

4.2%

$24,740,353

Suspicious Email

592

2.4%

$17,664,792

State Flagged

<1%

$1,748,512

Deceased Person

<1%

$93,381

1,577

6.3%

$36,854,208

Claimants with Fraud Indicator:

All Preceding Fraud Indicators
(claimants with multiple indicators were
only included once to avoid duplication)

Source: DOL OIG data analysis of state workforce agency claims data for the period March 27, 2020, to September 6, 2021.
a

Fraud indicators were created by DOL OIG to flag potential incidents of fraud. Multistate claimants applied for benefits in multiple states. Claimants
with suspicious emails used the same email for multiple applications, used a temporary email address, or an email address with a common fraud
technique. Also flagged were claimants with social security numbers of a person that was deceased. Additionally, the state workforce agency flagged
certain claimants as potentially fraudulent.

Prior to the release of this report, the potentially
fraudulent claims were referred to the OIG’s Office
of Investigations to assess and determine if the
claims warrant investigation. If the claims did not
warrant investigation, we referred the claim to the
state workforce agency.

FOR MORE INFORMATION
For more information about unemployment
insurance programs during the pandemic, visit
the PRAC’s website.

35 Potentially fraudulent claims are based on data analytics and have not been investigated, adjudicated, or confirmed as fraud by a state
UI agency. Flagged transactions may not be fraudulent, and not all fraudulent transactions may be flagged. More generally, these types of
potential fraud measures can be used to identify transactions that may be indicative of potential fraud. They cannot, though, be interpreted
directly as measures of the extent of fraud in any specific geographic area.

Pandemic Response Accountability Committee

PROGRAM SNAPSHOT

CARES Act Urbanized Area
Formula Grants
CARES Act Urbanized Area
Formula Grants

U.S. Department of Transportation
At the beginning of the pandemic, many businesses and schools were shut down. Low-income
and minority populations in Springfield, MA, were disproportionately impacted because of
the pandemic’s negative effects on small businesses, the service industries, and childcare.
The pandemic affected multifamily rental properties differently depending on whether residents’
incomes were affected. While many people lost their jobs during the pandemic, some households’
incomes were not affected as much because they were retired, collected disability benefits, or were
employed as front-line workers.
The CARES Act (signed into law on March 27, 2020) made available $1 billion to owners of
properties that receive Section 8 Project-Based Rental Assistance (PBRA) to help prevent, prepare
for, and respond to coronavirus, including to provide additional funds to maintain normal operations
by compensating owners for decreased tenant rent payments from reduced tenant income. HUD
used $800 million of the CARES Act funding as additional housing assistance payments (HAP) for
approximately 16,500 properties with PBRA contracts to maintain normal operations and made
$190 million available as COVID-19 supplemental payments (CSP) for properties to prevent, prepare
for, and respond to coronavirus.36 As of September 30,
2021, HUD had provided $2,741,072 to 34 PBRA properties
As of September 30, 2021, HUD had
in Springfield, MA. Of this amount, $2,617,420 had been
provided $2,741,072 to 34 PBRA
provided to 34 properties to maintain normal operations,
properties in Springfield, MA.
and the remaining $123,652 was provided to five of these
properties in CSPs.
Under the PBRA program, HUD contracts with owners of multifamily rental housing to subsidize the
difference between the approved rent and what low-income tenants can afford. Eligible tenants
must pay the highest of 30 percent of adjusted income, 10 percent of gross income, or the portion
of welfare assistance designated for housing. The initial allocation of $800 million of the CARES
Act funding was distributed to the properties in June 2020 to ensure that sufficient funding was
available on the HAP contracts to cover the anticipated increase in subsidy amounts because of
a foreseeable reduction in tenant incomes due to the pandemic-related emergency shutdown of
businesses. In July 2020, HUD then allocated up to $190 million for CSP. CSP funds were available
36 The remaining $10 million was allocated for the Section 8 Moderate Rehabilitation Program, which was not included in this review.

Pandemic Response Accountability Committee

for operating cost increases that were related to a property’s efforts to prevent, prepare for, and
respond to the coronavirus. Some of the more common eligible expenditures included personal
protective equipment, increased cleaning and sanitization, and facility and equipment needed to
maintain adequate social distancing. HUD considered these payments to be one-time investments
to support property owners to continue providing housing in decent, safe, and sanitary conditions.
HUD distributed the initial $800 million to the properties automatically via the normal monthly
HAP vouchering process. Property owners did not need to take any special action to access these
CARES Act funds. For the $190 million allocated for CSP, HUD announced the availability of these
funds to property owners by issuing notices with instructions on how to apply for reimbursement for
eligible costs.

Program Impact
Our review showed that the properties in Springfield, MA, used PBRA CARES Act funds in
alignment with the goals and objectives of the program, which were to maintain normal
operations and to prevent, prepare for, and respond to coronavirus. PBRA CARES Act funding
that was automatically distributed to the properties ensured that sufficient funding was available to
pay the housing subsidies for eligible families. Expenditures that were reimbursed with CSP funds
helped pay for the increased frequency of cleaning and disinfecting, personal protective equipment,
and supplies to facilitate social distancing.
HUD distributed the initial allocation of the PBRA CARES
Act funding quickly through the normal vouchering process
to the properties in Springfield, and the funding was used
as intended. HUD indicated that the funds were added to
the current HAP contracts as a source of funds to pay the
monthly vouchers for housing assistance. The funds were
intentionally distributed through the normal vouchering
process because HUD did not want the properties to have
to do anything different to receive the funds and risk having
gaps in providing housing subsidies. HUD wanted to ensure
that the funds could be used quickly to assist families with
reduced incomes.

QUICK RESPONSE THROUGH
NORMAL VOUCHERING PROCESS
The funds were intentionally distributed
through the normal vouchering process
because HUD did not want the properties
to have to do anything different to receive
the funds and risk having gaps in providing
housing subsidies. HUD wanted to ensure
that the funds could be used quickly to
assist families with reduced incomes.

Of the five properties reviewed, three requested and
received CSP funding. The CSP funds reimbursed these properties for expenses related to their
efforts to prevent, prepare for, and respond to the coronavirus as intended. Property owners were
required to certify to their property’s financial need to receive CSP funds. The funds helped these
three properties pay for expenses that would have otherwise come from their operating funds.

Pandemic Response Accountability Committee

Participant Experience
HUD’s automatic and immediate distribution of the initial allocation of the CARES Act funding
helped pay for the increase in the amount of the rental subsidies needed for those families that
had a loss of income due to the pandemic. Owners of PBRA properties were not required to do
anything different than they normally would when an assisted family’s income changed. The PBRA
CARES Act funding helped ensure that the properties continued to have the rental revenue needed
to maintain normal operations.
The owners of properties that received CSP funding believed that it had a positive impact on
their ability to respond to the pandemic. Of the four property owners we spoke with, two properties
received CSP funds. They used CSP funds to cover operating cost increases that were directly
related to their efforts to prevent, prepare for, and respond to the coronavirus. Without the CSP
funds, the properties would have had to pay for the additional expenses with their operating
accounts. Doing so could have negatively affected other planned projects including repairs,
maintenance, and upgrades.

Pandemic Response Accountability Committee

PROGRAM SNAPSHOT

Provider Relief Fund
Payments to Nursing Homes
U.S. Department of Health and
Human Services

Nursing homes and their residents have been among those hardest hit by the COVID-19 pandemic
due in part to residents’ ages and underlying medical conditions, close living quarters, and nursing
homes’ longstanding challenges with staffing and infection control.37 38 39 40 41 As of August 7, 2022,
more than 1.1 million nursing home residents in the United States had already had a confirmed
case of COVID-19, with approximately 155,000 deaths.42
The Springfield, MA, nursing home in our sample has had substantial financial challenges in
responding to the pandemic.43 The nursing home’s corporate leaders reported that the facility
was profitable when they acquired it in late 2019, but it began losing revenue after March 2020,
as a result of the pandemic. Corporate and facility leaders attributed lost revenue to significant
drops in census. The nursing home reported that its number of residents dropped from 88 in the
first quarter of 2020 to 31 in the second quarter. The decrease was caused in part by resident
deaths and quarantine requirements for new admissions. Facility staff said the nursing home lost
revenue from short-term rehabilitation patients because it was closed to new admissions on several
occasions, most notably in March and April 2020 following its first COVID-19 case.
Corporate and facility leaders reported that, while revenue declined, expenses increased.
Corporate and facility leaders said that labor costs increased by 30 percent as a result of reliance
on third-party agency nurses, increasing hourly wages, and pay bonuses for staff working during
holidays and COVID-19 peaks. For example, the hourly wages of certified nursing aides at the facility
rose from $14 to $21 during the pandemic. In addition to labor costs, the limited supply of PPE
during the early weeks of the pandemic further increased expenses. For example, financial officers
37 HHS OIG, COVID-19 Had a Devastating Impact on Medicare Beneficiaries in Nursing Homes During 2020. OEI-02-20-00490, June 2021. 38
GAO, COVID-19 in Nursing Homes—Most Homes Had Multiple Outbreaks and Weeks of Sustained Transmission from May 2020 through
January 2021, GAO-21-367, May 2021, p. 1.
39 Centers for Disease Control and Prevention, People Who Live in a Nursing Home or Long-Term Care Facility. Accessed at public4.pagefreezer.
com/browse/CDC%20Covid%20Pages/11-05-2022T12:30/ www.cdc.gov/coronavirus/2019-ncov/need-extra-precautions/people-innursinghomes.html on September 15, 2021.
40 GAO, Infection Control Deficiencies Were Widespread and Persistent in Nursing Homes Prior to COVID-19 Pandemic, GAO-20-576R, May 20,
2020, p. 1.
41 Lauren Weber, “Nursing Homes Keep Losing Workers,” The Wall Street Journal, August 25, 2021. Accessed at www.wsj.com/articles/
nursinghomes-keep-losing-workers-11629898200 on November 2, 2021.
42 Centers for Medicare & Medicaid Services (CMS), COVID-19 Nursing Home Data. Accessed at data.cms.gov/covid-19/covid-19-nursing-homedata on August 19, 2022.
43 For the purposes of our review, we used the term “nursing homes” to refer to all facilities in our sample regardless of technical status (i.e.,
nursing facility and/or skilled nursing facility (SNF)) according to common use.

Pandemic Response Accountability Committee

INCREASED COSTS RELATED TO
COVID-19
The limited supply of personal protective
equipment early in the pandemic
increased facility expenses. A corporate
officer noted that the price of isolation
gowns increased from $0.99 to $12.50
early in the pandemic.

noted that the price of gloves had quadrupled. Along with
labor and PPE costs, the facility faced additional expenses,
including costs for third-party COVID-19 testing, high
efficiency particulate air filters and air purifiers, technology
for visitation and telemedicine, no-touch dispensers, and
disinfectants and supplies.

Nursing home leaders and staff reported both personal
and operational challenges to providing care during the
COVID-19 pandemic. Both facility leaders and staff reported
increased staff turnover, partially due to difficult experiences
throughout the pandemic. Between the first quarter of 2020
and the fourth quarter of 2021, 182 employees left the facility. The nursing home reported having
37 full-time employees during the fourth quarter of 2021, compared to 100 in the fourth quarter
of 2019. Staff said they worked in fear early in the pandemic and have continued to worry about
contracting COVID-19 and passing it to loved ones. Some staff had years-long relationships with
residents and experienced emotional distress from resident illness and deaths. To avoid shortages
during the pandemic, facility staff reported working overtime and covering for each other.
Nursing home staff and residents reported that residents experienced severe strain during the
COVID-19 pandemic. According to its Director of Infection Control, the facility lost 16 residents
to COVID-19 during a surge in April 2020, which contributed to the census decline from 88 to 31.
Residents said they experienced difficulties throughout the pandemic, such as being confined
to their rooms due to infection control procedures. Staff explained that residents were at risk for
depression and isolation due to shutdowns of visitation and activities. Nursing staff also noted that
delaying visitation was especially difficult for residents with dementia because their memory loss
advanced by the time families could visit.

Program Information
To reimburse health care providers for pandemic-related expenses and lost revenue, Congress
appropriated $178 billion to HHS during 2020 and 2021.44 To administer the funds, HHS
established the Provider Relief Fund (PRF)and related programs.45 46 The Health Resources
44 The CARES Act appropriated $100 billion; the Paycheck Protection Program and Health Care Enhancement (PPPHCE) Act appropriated $75
billion; and the Consolidated Appropriations Act, 2021, appropriated $3 billion. See CARES Act, P.L. No. 116-136, Division B, Title VIII, (March
27, 2020); PPPHCE Act, P.L. No. 116-139, Division B, Title I (April 24, 2020); Consolidated Appropriations Act, 2021, P.L. No. 116-260, Division
M, Title III (December 27, 2020).
45 HRSA administered funds for other programs, such as for the Rural Health Clinic COVID-19 Testing and Mitigation Program, alongside PRF.
HHS also used $8.5 billion that Congress appropriated through the American Rescue Plan (ARP) Act of 2021 to establish the ARP Rural
Distribution as a separate program to administer payments to providers and suppliers who serve rural enrollees in Medicaid, the Children’s
Health Insurance Program, and Medicare, including nursing homes and certified SNFs. See HHS, news release, “Biden-Harris Administration
Begins Distributing American Rescue Plan Rural Funding to Support Providers Impacted by Pandemic,” November 23, 2021. Accessed at www.
hhs.gov/about/news/2021/11/23/biden-admin-begins-distributing-arp-prf-support-to-providers-impacted-by-pandemic.html on September 13,
2022.
46 HHS, news release, “HHS to Begin Immediate Delivery of Initial $30 Billion of CARES Act Provider Relief Funding.” Accessed at public3.
pagefreezer.com/content/HHS.gov/31-12-2020T08:51/https:/www.hhs.gov/about/news/2020/04/10/hhs-to-begin-immediate-delivery-ofinitial-30-billion-of-cares-act-provider-relief-funding.html on August 23, 2022.

Pandemic Response Accountability Committee

and Services Administration (HRSA) is the HHS agency responsible for administering the PRF
program.47 PRF includes general and targeted distributions. General distributions are broadly
available to health care providers, while targeted distributions are for health care providers with
added COVID-19 challenges, such as those highly impacted by COVID-19 or serving high-need
and vulnerable populations (e.g., nursing homes).48 49 HHS began issuing PRF payments in April
2020, shortly after the CARES Act was enacted. HHS stopped making PRF payments in June
2023 following passage of the Fiscal Responsibility Act of 2023.50 For reporting purposes, HHS
established periods in which recipients of both types of PRF distributions have to use and report
on the funds (see Table 8).51 In general, recipients have to use the funds within one year after the
payment period ends and report on their use during a subsequent three-month period.52

47 86 Fed. Reg. 40064 (July 26, 2021).
48 HRSA, Past General Distributions, December 2021. Accessed at www.hrsa.gov/provider-relief/past-payments/general-distribution on August
23, 2022.
49 HRSA, Past Targeted Distributions, November 2022. Accessed at www.hrsa.gov/provider-relief/past-payments/targeted-distribution on
December 12, 2022.
50 HRSA, Provider Relief. Accessed at www.hrsa.gov/provider-relief on June 7, 2023.
51 For our analysis, we reviewed payments made during the first four periods and nursing home reports on PRF use made during the first two
periods.
52 HRSA, Important Dates for Reporting. May 2023. Accessed at www.hrsa.gov/provider-relief/reporting-auditing/important-dates on
May 11, 2023.

Pandemic Response Accountability Committee

Table 8: Timelines for Facility Receipt, Use, and Reports of PRF Payments
Reporting
Period

Payment Received Period

April 10, 2020, to
June 30, 2020

July 1, 2020, to
December 31, 2020

January 1, 2021, to
June 30, 2021

July 1, 2021, to
December 31, 2021

January 1, 2022, to
June 30, 2022

Deadline to Use Funds

Reporting Time Period

June 30, 2021

July 1, 2021, to
September 30, 2021a

December 31, 2021

January 1, 2022, to
March 31, 2022

June 30, 2022

July 1, 2022, to
September 30, 2022

December 31, 2022

January 1, 2023, to
March 31, 2023

June 30, 2023

July 1, 2023, to
September 30, 2023
January 1, 2024, to

July 1, 2022, to
December 31, 2022

December 31, 2023

January 1, 2023, to
June 30, 2023

June 30, 2024b

March 31, 2024
July 1, 2024, to
September 20, 2024

Source: HRSA, Important Dates for Reporting, December 2023. Accessed at www.hrsa.gov/provider-relief/reporting-auditing/
important-dates on January 9, 2024.
a

HRSA allowed a grace period for this reporting time period, which ended on November 30, 2021.

PRF payments not fully expended on expenses attributable to COVID-19 may only be applied to lost revenue up to the end of the
quarter in which the Public Health Emergency ended (i.e., June 30, 2023). See HRSA, How to Calculate Lost Revenues for PRF
and ARP Rural Reporting, February 2023. Accessed at www.hrsa.gov/provider-relief/reporting-auditing/lost-revenues on March
20, 2023.

HRSA distributed approximately $9.4 billion in targeted PRF payments directly to nursing
homes and certified skilled nursing facilities (SNFs).53 54 HHS distributed $4.8 billion of this
amount to 12,806 nursing homes and certified SNFs which provide complex care that can only
be safely and effectively performed by, or under the supervision of, skilled nursing and therapy
professionals.55 56 The terms and conditions associated with the SNF distribution required recipients
to use the payments for health care expenses and lost revenue attributable to preventing, preparing
53 In addition to these targeted distributions, some nursing homes may have also qualified for additional funding through general and other
distributions. In June 2023, HRSA reported to HHS OIG that HHS had obligated approximately $54.7 billion total to SNFs and nursing
homes across all PRF distributions.
54 HRSA, Past Targeted Distributions, November 2022
55 HRSA, Past Targeted Distributions, November 2022.
56 CMS, Medicare Coverage of Skilled Nursing Facility Care, July 2019.

Pandemic Response Accountability Committee

for, and responding to COVID-19.57 HHS distributed the other $4.6 billion to facilities through
the Nursing Home Infection Control (NHIC) distribution, which included two types of allocations:
infection control payments to 12,787 facilities and Quality Incentive Payment (QIP) program
payments to 11,819 facilities.58 The terms and conditions for the NHIC distribution, including QIP
payments, require the funds to be spent on infection control-related expenses, such as COVID-19
testing and reporting, and recruiting staff.59

Program Impact
The Springfield nursing home received both general and targeted PRF payments. As of December
2021, the nursing home had received a total of $919,454 from PRF distributions. Targeted
payments included $350,000 from the SNF distribution and $348,532 from NHIC distributions (see
Table 9).

57 HRSA, Acceptance of Terms and Conditions, Skilled Nursing Facility Relief Fund Payment Terms and Conditions.
58 HRSA, Past Targeted Distributions, November 2022.
59 HRSA, Acceptance of Terms and Conditions, Skilled Nursing Facility and Nursing Home Infection Control Relief Fund Payment Terms and
Conditions. Accessed at www.hrsa.gov/sites/default/files/hrsa/provider-relief/provider-relief-fund-nf-infection-control-payment-termsconditions.pdf on August 17, 2021.

Pandemic Response Accountability Committee

Table 9: PRF Payments to Nursing Homesa
Total Payments Distributed to
Nursing Homes Nationally

Total Payments to the
Sample Nursing Home

SNF

$4.8 billion

$350,000

NHIC

$4.6 billion

$348,532

OTHERb

$45.3 billionb

$220,922

TOTAL

$54.7 billionb

$919,454c

Distribution

Sources: HRSA, Past Targeted Distributions, November 2022. Accessed at www.hrsa.gov/provider-relief/past-payments/targeteddistribution on December 12, 2022; and HHS OIG analysis of PRF payment data.
a

HRSA last reviewed the web page that lists the targeted distribution totals in November 2022 and stated that the totals were
current through September 2022. PRF payment data for our sample nursing home are current through December 2021.
b
“Other” includes all other payments to nursing homes (i.e., PRF payments made through distributions that are not SNF and NHIC
distributions). HRSA reported to HHS OIG in June 2023 the total amount paid to nursing homes but does not publicly report total
amounts distributed to specific provider types for general distributions. HRSA also does not publicly report total amounts from other
PRF distributions—other than the SNF and NHIC distributions—that may have gone to those facilities.
c
The facility received an additional $4,314 from the ARP Rural Distribution. Although the ARP Rural Distribution is separate from PRF,
it was administered and included in HRSA’s data alongside PRF.

The nursing home reported that it spent all the PRF payments it received during the first two
periods and used the money for COVID-19-related expenses. Corporate leaders reported that the
nursing home incurred expenses in advance, then its corporate office allocated PRF for eligible
reimbursements. Corporate offices also reported use of the funds to HRSA.
At the time of our data collection, the facility was only required to have reported on the use of PRF
payments received during the first two periods (April 2020 through December 2020). Corporate
leaders reported that the nursing home used all the funds it received during the first two periods.
Specifically, the nursing home reported using $719,926 in total PRF payments, including $591,087
in payments targeted to nursing facilities ($350,000 in SNF payments and $241,087 in NHIC
payments).60
The nursing home reported using the payments to cover general and administrative and health care
related expenses. HRSA required nursing homes to report the use of NHIC payments and all other
payments (including SNF payments) separately:
• The nursing home reported using its NHIC payments ($241,087) to offset health care-related
expenses, such as medical supplies, third-party agency nursing staff, and laboratory fees.
60 These figures do not match the figures in Table 9 because the facility was not yet required to report its use of the remaining funds of
approximately $200,000 during the first two reporting periods.

Pandemic Response Accountability Committee

• The nursing home reported using all other payments it received ($128,839 in general funds
and $350,000 in SNF funds) for general and administrative expenses, such as rent, utilities,
and insurance.
Corporate leaders at the Springfield nursing home said HRSA’s guidance on allowable uses and
reporting requirements was sometimes unclear. They attributed their confusion to continuous
updates to the guidance that were difficult to monitor. However, the officers said they appreciated
that the guidance was broad enough to allow for discretion in using the funds to meet facility, staff,
and resident needs.
HHS OIG reviewed documentation that generally supported that the nursing home’s reported
use of the funds during the first two reporting periods aligned with PRF goals and objectives.
We reviewed the reports the nursing home made to HRSA during the first two reporting periods,
along with summary supporting documentation. We did not audit the facility’s financial reports
or supporting documents. We observed that the information the facility reported to HRSA was
generally supported by underlying facility data
and appeared to align with the allowable uses of
the general and targeted distributions. Facility
FOR MORE INFORMATION
documentation generally supported that the
For more information about Provider Relief Fund
nursing home used NHIC payments for infection
program spending across the country, visit the PRAC’s
control related expenses, as intended. Examples
website, including an interactive dashboard.
included facility expenses on PPE and other
infection control supplies.
HRSA plans to review nursing home reports to assess use of PRF payments. For each reporting
period, HRSA planned to select a sample of health care facilities, including nursing homes, to be
audited according to a risk-based strategy to verify compliance with the terms and conditions of
the program and recoup any inappropriately used funds. HRSA reported that it will also conduct an
ongoing analysis of providers’ reported spending, seeking to identify trends in how providers spent
PRF payments to provide services during the pandemic.

Participant Experience
PRF payments have been integral to the nursing home’s pandemic response, according to corporate
and facility leaders representing the Springfield nursing home. One corporate leader said the
PRF payments were “a godsend, without question.” They also emphasized that the automatic
distribution of the funds benefited the facility, because they did not have to apply or worry about
missing the financial assistance while they were focused on responding to the COVID-19 pandemic.
Corporate and facility leaders stated that the PRF payments were critical to “keeping the doors
open,” because the facility was making less revenue when it was closed for admissions. They also
reported that PRF payments were essential for covering the costs of PPE, as well as for retaining
and hiring additional staff. Nursing home staff agreed that the pay raises and bonuses helped
retain staff working under difficult conditions.

Pandemic Response Accountability Committee

“I think, you know, thank God. The first thing that I would say is that the initial payments we received
were pushed out to providers, which was so critical, because at that point we were fighting for our
lives just trying to understand what was happening on the ground.”
—Corporate leader

Corporate leaders reported that PRF payments were not sufficient to offset losses related to
COVID-19, and that the facility would benefit from additional relief funding. The nursing home
reported to HRSA that after the first two payment and use periods, it had hundreds of thousands
of dollars remaining in unreimbursed expenses, which HRSA defines as expenses that remain
unreimbursed after considering all assistance received by HRSA and all other sources.61 Corporate
leaders reported using lines of credit to cover some remaining costs.
Corporate leaders also perceived that HRSA’s methods for calculating some of the payment
amounts were not clear and described receiving less relief funding than expected. Specifically,
they expected a payment from the last general distribution to cover additional lost revenue and
increased costs HRSA required the facility to report earlier on, but said they received only about
5 cents on the dollar to the reported amounts. Still, corporate and facility leaders reported the
payments were valuable for supporting infection control and maintaining resident care during
the pandemic.

61 HRSA, User Guide: Provider Relief Fund (PRF) Reporting Portal—Reporting, p. 53. Accessed at hrsa.gov/sites/default/files/hrsa/provider-relief/
prf-reporting-portal-user-guide.pdf on August 15, 2022.

Pandemic Response Accountability Committee

Appendix A: Acronyms
ARP Act

American Rescue Plan Act of 2021

ARRA

American Recovery and Reinvestment Act of 2009

CARES Act

Coronavirus Aid, Relief, and Economic Security Act

CDBG

Community Development Block Grant

CDBG-CV

Community Development Block Grant – CARES Act

CIGIE

Council of the Inspectors General for Integrity and Efficiency

CMS

Centers for Medicare and Medicaid Services

COVID-19

coronavirus disease 2019

CRF

Coronavirus Relief Fund

CSP

COVID-19 Supplemental Payments

DHS

U.S. Department of Homeland Security

DOL

U.S. Department of Labor

DOT

U.S. Department of Transportation

ESSER

Elementary and Secondary School Emergency Relief

FAQ

Frequently Asked Question

FEMA

Federal Emergency Management Agency

Food Box Program

Farmers to Families Food Box Program

FPUC

Federal Pandemic Unemployment Compensation

FTA

Federal Transit Administration

GAO

U.S. Government Accountability Office

HAP

housing assistance payments

HHS

U.S. Department of Health and Human Services

HRSA

Health Resources and Services Administration

HUD

U.S. Department of Housing and Urban Development

Pandemic Response Accountability Committee

MEMA

Massachusetts Emergency Management Agency

NHIC

Nursing Home Infection Control

OIG

Office of Inspector General

FEMA’s Individual Public Assistance

PBRA

Section 8 Project-Based Rental Assistance

PEUC

Pandemic Emergency Unemployment Compensation

PPE

personal protective equipment

PRAC

Pandemic Response Accountability Committee

PRF

Provider Relief Fund

PUA

Pandemic Unemployment Assistance

PVTA or
the Authority

Pioneer Valley Transit Authority

QIP

Quality Incentive Payment

SNF

Skilled Nursing Facilities

Springfield’s HHS

city of Springfield, MA’s Department of Health and Human Services

SPS

Springfield Public Schools

Treasury

U.S. Department of the Treasury

unemployment insurance

USDA

U.S. Department of Agriculture

Pandemic Response Accountability Committee

Appendix B: Scope and Methodology
Scope
In October 2021, the PRAC along with 10 of our OIG members initiated a case-study-based review
that sought to identify the federal pandemic response funds provided to select geographic areas,
the purpose of those funds, and if the spending aligned with the intended goals and objectives. To
conduct our work, we divided the review into two phases. Phase one sought to determine how much
pandemic funding went to the six selected communities. The final report for phase one, Tracking
Pandemic Relief Funds that Went to Local Communities Reveals Persistent Data Gaps and Data
Reliability Issues, was issued on July 6, 2023. Phase two of the review sought to gain more insight
into how the six communities used their pandemic relief funding; if the spending generally aligned
with the goals and objectives of the programs and subprograms, and whether the funding helped
the six communities respond to the pandemic. The final insights report for phase two of this review,
Pandemic Relief Experiences: A Focus on Six Communities, was issued on March 28, 2024.
To conduct our work, we randomly selected six communities across the United States: Springfield,
Massachusetts; Coeur d’Alene, Idaho; Sheridan County, Nebraska; Marion County, Georgia;
White Earth Nation Reservation in Minnesota; and Jicarilla Apache Nation in New Mexico. More
information about the selection process can be found in Scope and Methodology section of our July
2023 report.
For phase two, we worked with the participating OIGs to select a total of 21 pandemic relief
programs and subprograms for review. Of those 21 programs, nine provided funding to recipients
in Springfield. In our review of the nine programs, we sought to identify how the recipients used the
funds and if the uses generally aligned with the program’s goals and objectives. The programs or
subprograms selected for Springfield were:
• CARES Act Urbanized Area Formula Grants Program | U.S. Department of Transportation
• Community Development Block Grant – CARES Act | U.S. Department of Housing and
Urban Development
• Coronavirus Relief Fund | U.S. Department of the Treasury
• COVID-19 Public Assistance Emergency Protective Measures | U.S. Department of Homeland
Security, Federal Emergency Management Agency
• Elementary and Secondary School Emergency Relief Program | U.S. Department of Education
• Farmers to Families Food Box Program | U.S. Department of Agriculture
• Pandemic Unemployment Insurance | U.S. Department of Labor

Pandemic Response Accountability Committee

• Project-Based Rental Assistance – CARES Act | U.S. Department of Housing and Urban
Development
• Provider Relief Fund Payments to Nursing Homes | U.S. Department of Health and Human
Services
More information about the scope and methodology for phase two of this review can be found in our
March 2024 report.

Methodology
We visited Springfield, MA, in May 2022 and conducted interviews with government, community,
and business leaders to discuss the community’s experiences with the pandemic, federal guidance,
best practices, lessons learned, and suggestions for improvement. The overall methods we used to
achieve the objectives included reviewing laws, program guidelines, and background information for
the programs as well as working with our OIG partners. The specific scope and methodology used to
review each of the selected programs and subprograms is provided in each of the program sections.

Standards
Each OIG and PRAC conducted this study in accordance with its own respective processes and
standards to ensure that all the contributions to this report met quality standards issued in
accordance with the generally accepted government auditing standards, CIGIE Quality Standards for
Inspection and Evaluation, and internal OIG guidance. All these standards require that we planned
and performed this study to obtain sufficient and appropriate evidence to provide a reasonable
basis for the insights and conclusions. This work was completed between October 2021 and
October 2022, and complies with the CIGIE’s Quality Standards for Inspection and Evaluation.

CARES Act Urbanized Area Formula Grants Program |
U.S. Department of Transportation, Office of Inspector General
Methodology
Scope | The Department of Transportation (DOT) OIG reviewed the Pioneer Valley Transit Authority’s
(PVTA) use of Federal Transit Administration (FTA) Coronavirus Aid, Relief, and Economic Security
(CARES) Act Urbanized Area Formula Grants Program funds from program inception through
September 30, 2021. In this audit, DOT OIG sought to determine, for the CARES Act Urbanized
Area Formula Grants Program, whether PVTA (1) spent pandemic funds in alignment with program
goals and objectives and (2) believes that Federal funding impacted its ability to respond to
the pandemic. Specifically, we examined CARES Act Urbanized Area Formula Grants Program

Pandemic Response Accountability Committee

expenditures from grant agreement MA-2020-023-00 through September 30, 2021.
Methodology | To determine whether PVTA spent pandemic funds in alignment with program
goals and objectives, we identified criteria in various sources, including the CARES Act, the statute
pertaining to the Urbanized Area Formula Grants Program,62 FTA’s Frequently Asked Questions
webpage, FTA Circular 9030.1E Urbanized Area Formula Program: Program Guidance and
Application Instructions, the Payment Integrity Information Act of 2019,63 and the applicable grant
agreement. We also obtained the Agency’s description of the purpose, goals, and objectives for the
CARES Act Urbanized Area Formula Grants Program. We conducted interviews with PVTA officials
to learn more about how the transit agency used the funds and obtained documentation for the
expenditures charged to its CARES Act grant through September 30, 2021. Two DOT OIG analysts
independently reviewed each expenditure and supporting documentation for all expenditures,
except those related to salaries and benefits. Each analyst separately determined whether the
expenditure was aligned with the purpose of the CARES Act funds. If the analysts disagreed as
to whether an expenditure matched the purpose of the funding, a third DOT OIG analyst made the
determination. We followed up with PVTA officials and collected additional documentation, as
needed, to resolve any questions we had about the expenditures.
To determine whether PVTA believed that federal funding impacted its ability to respond to the
pandemic, we drew from, and modified as appropriate, standard questions PRAC developed to
interview appropriate PVTA officials and staff. The audit team analyzed the testimonial evidence to
identify any themes.

Limitations
We did not have any significant limitations.
Data Quality | To check the completeness and integrity of the data PVTA officials provided, we
verified that the amounts they reported drawing down matched the amounts FTA reported outlaying
to the transit agency. For the purposes of our effort and in the absence of information that would
suggest otherwise, we judge the data to be reliable.

Standards
We conducted this audit 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.

62 49 U.S.C. 5307 (2015).
63 Pub. L. No. 116-117 (2020).

Pandemic Response Accountability Committee

Community Development Block Grant – CARES Act |
U.S. Department of Housing and Urban Development,
Office of Inspector General
Methodology
Scope | HUD OIG conducted the review remotely from May through September 2022. Our review
covered the city of Springfield’s use of Community Development Block Grant – CARES Act (CDBGCV) funds from program inception through September 30, 2021. Our review objectives were to
determine whether the city of Springfield spent CDBG-CV funds in alignment with program goals and
objectives and whether the CDBG-CV funds positively or negatively impacted Springfield’s ability to
respond to the pandemic.
Methodology | To accomplish our review objectives, we:
• Reviewed applicable HUD requirements (Federal Register and HUD memorandum).
• Interviewed HUD staff and city of Springfield staff to gain an understanding of the goals and
objectives of the CDBG-CV funds and to obtain feedback on the impact of CDBG-CV funds.
• Reviewed Springfield’s written policies and procedures for using the CDBG-CV funds.
• Reviewed a sample of program expenditures and the corresponding supporting documentation
provided by Springfield, including applications, contracts, invoices, and canceled checks.
The review universe consisted of 197 expenditure transactions totaling $1,651,818 between
August 3, 2020, and September 20, 2021. From this universe, we selected a statistical sample of
51 transactions totaling $285,257 for review to determine whether the city spent CDBG-CV funds in
alignment with the program goals and objectives.
To achieve our objective, we relied in part on the city’s computer-processed data. Although we
did not perform a detailed assessment of the reliability of the data, we determined that the data
were sufficiently reliable for the purposes of our review because we corroborated the data for the
sampled expenditures against supporting documentation provided by the city.
We determined that internal controls were not relevant to our objective. Our objective was not to
evaluate or provide assurance of the city of Springfield’s internal controls. Therefore, we did not
assess the city’s controls or express an opinion on them.

Standards
HUD OIG conducted this review in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the review to obtain sufficient,

Pandemic Response Accountability Committee

appropriate evidence to provide a reasonable basis for our findings and conclusions based on our
objective. We believe the evidence obtained provides a reasonable basis for our conclusions based
on our objective.

Coronavirus Relief Fund | U.S. Department of the Treasury,
Office of Inspector General
Objectives/Scope/Methodology
Our objectives were to determine whether subrecipients and beneficiaries located in Springfield,
MA, (1) used Coronavirus Relief Fund (CRF) proceeds in alignment with program goals and
objectives and (2) believe that CRF funding impacted (positively or negatively) their ability to
respond to the pandemic.
The scope of our engagement covered CRF expenditures reported in a grant reporting system from
March 1, 2020 (cycle 1) through March 31, 2022 (cycle 8). We selected three subrecipients of the
Commonwealth of Massachusetts geographically located in Springfield for the review. The three
subrecipients and beneficiaries selected are: (1) Springfield, (2) a rental assistance management
company, and (3) a childcare resource and referral organization. We sampled a total of $20.46
million of $27.4 million (17 transactions, or 75 percent) of CRF expenditures, representing all
payment types,64 for the three subrecipients and beneficiaries selected to determine whether they
used the CRF funds in alignment with the program’s goals and objectives.
To accomplish these objectives, we performed the following activities during engagement fieldwork
conducted from May 2022 through October 2022:
• Reviewed Title VI of the Social Security Act, as amended by Title V of Division A of the
CARES Act65
• Reviewed the Consolidated Appropriations Act, 202166
• Reviewed Treasury Guidance and Frequently Asked Questions published in the Federal
Register, Volume 86, No. 10 (January 15, 2021)
• Reviewed the Commonwealth of Massachusetts’ policies and procedures provided to
subrecipients and beneficiaries for CRF eligible use determination
• Interviewed subrecipient officials regarding CRF usage, experience, and impact
• Reviewed the Commonwealth of Massachusetts, city of Springfield, the rental assistance
management company, and the childcare resource and referral organization’s Single
64 Direct Payments, Contracts, Transfers, and Grants.
65 P. L. 116-136 (March 27, 2020).
66 P. L. 116-260 (December 27, 2020).

Pandemic Response Accountability Committee

Audit Reports for fiscal years 2020 and 2021 to assess findings that may pose risk to
the subrecipients and beneficiaries uses of CRF
• Reviewed media reports associated with the COVID-19 pandemic and CRF impacts within
Springfield
• Reviewed supporting documentation to determine if the 17 sample transactions (1) were
necessary expenditures incurred due to the public health emergency with respect to
COVID-19; (2) were not accounted for in the budget most recently approved as of March 27,
2020; and (3) were for costs incurred between March 1, 2020 and December 31, 2021.
Supporting documentation includes grant agreements, invoices, purchase orders, application
packages, and data extracts from the Commonwealth of Massachusetts, subrecipient, and
beneficiary accounting systems.

Standards
We conducted this engagement in accordance with the Quality Standards for Inspection and
Evaluation issued by CIGIE.

COVID-19 Public Assistance Emergency Protective
Measures | U.S. Department of Homeland Security,
Office of Inspector General
Methodology
Scope | We conducted this study to determine whether the pandemic funding provided through
the Federal Emergency Management Agency’s (FEMA) PA Emergency Protective Measures program
to subrecipients within Springfield, MA, between January 31, 2020, and February 10, 2023, was
used in a manner that aligned with the program goals and objectives. Additionally, we inquired to
what extent the subrecipients believed the Federal funds impacted their ability to respond to the
pandemic.
Methodology | We conducted a site visit to Springfield, MA, where we interviewed four
subrecipients, FEMA Region 1 officials, and Massachusetts Emergency Management Agency
(MEMA) officials. Subrecipient #5 responded to questions via email but declined to be interviewed,
and subrecipient #6 met with us telephonically. We also reviewed reimbursement data obtained
from FEMA’s Integrated Financial Management Information System and supporting documentation
in FEMA’s Grants Manager system to verify FEMA’s reimbursement approval and denial process.

Pandemic Response Accountability Committee

Limitations
FEMA’s PA records management system, Grants Manager, captures project-related data such as
the applicant type, amount requested, and the amount obligated. However, we were unable to
determine when FEMA-obligated funds were disbursed by MEMA to the subrecipients based on
our review of FEMA’s systems. FEMA does not maintain or have visibility of state disbursement
information by subrecipient.

Standards
The information obtained for the PRAC study is part of an ongoing audit being conducted in
conformance with Generally Accepted Government Auditing Standards of FEMA’s Public Assistance
Program in Response to the COVID-19 Pandemic (OIG-22-047-AUD-FEMA). The audit will determine
how well FEMA ensured Federal funds for COVID-19 PA Emergency Protective Measures reached
intended recipients and subrecipients and whether these funds were used as required. This report
is estimated to be completed in summer 2024.

Elementary and Secondary School Emergency Relief
Program | Pandemic Response Accountability Committee and
U.S. Department of Education, Office of Inspector General
Methodology
Scope | Our review covered Springfield Public Schools’ (SPS) use of ESSER funding from program
inception through September 30, 2021. Our objectives were to identify how SPS used the ESSER
funding it received and to determine whether SPS spent ESSER funds in alignment with program
goals and objectives. We coordinated this work with the U.S. Department of Education, Office of
Inspector General.
Methodology | To answer these objectives, we:
• reviewed applicable ESSER guidance including Frequently Asked Questions, Elementary and
Secondary School Emergency Relief Program and Governor’s Emergency Education Relief
Program issued in May 2021 and revised December 7, 2022.
• obtained summary descriptions of ESSER spending from SPS.
• determined if the descriptions of the funding uses aligned with ESSER’s objectives of helping
SPS prevent, prepare for, and respond to coronavirus, domestically or internationally.
• interviewed SPS officials, city of Springfield officials, and Massachusetts Department of
Elementary and Secondary Education officials about uses of funds as well as the effects the
ESSER funds had on Springfield’s ability to respond to the pandemic.

Pandemic Response Accountability Committee

Standards
We conducted this study in accordance with the Quality Standards for Inspection and Evaluation
issued by CIGIE.

Farmers to Families Food Box Program | Pandemic
Response Accountability Committee and U.S. Department of
Agriculture, Office of Inspector General
Methodology
Scope | Our review covered the use and impact of the U.S. Department of Agriculture's Farmers
to Families Food Box Program (Food Box Program). We included all five rounds of the program in
our review—to the extent that the data was available, and when boxes were provided to Springfield
May 15, 2020, through May 31, 2021. Our objectives were to identify how many food boxes went
to the Springfield, MA community and whether the program met its goals and objectives in serving
producers, distributors, and food recipient organizations and intended.
Methodology | To try to determine if the program served producers, distributors, and food recipient
organizations in accordance with program goals and objectives in Springfield, MA, community, we:
• reviewed multiple federal reports evaluating the Farmers to Families Food Box Program (Food
Box Program).
• obtained and reviewed data showing the number of food boxes sent to Food Recipient
organizations serving the Springfield, MA, community.
• interviewed a Food Box Recipient to determine how the Food Box Program helped Springfield,
MA, respond to the pandemic.
We also worked with USDA OIG to obtain data about the total number of food recipients and to
ensure that we fully understood the program objectives and structure.

Data Limitations
We used data collected and analyzed by USDA OIG during phase one of this case-study-based
review. Phase one introduced data limitations that prevented us from determining if the program
served producers, distributors, and food recipient organizations in accordance with program goals
and objectives.

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Standards
We conducted this study in accordance with the CIGIE’s Quality Standards for Inspection and
Evaluation.

Pandemic Unemployment Insurance | U.S. Department of
Labor, Office of Inspector General
Methodology
Scope | The evaluation covered the U.S. Department of Labor’s (DOL) unemployment insurance
(UI) response to the COVID-19 pandemic. Specifically, the federal UI benefits from the following
three key CARES Act UI programs were reviewed: Federal Pandemic Unemployment Compensation
(FPUC), Pandemic Unemployment Assistance (PUA), and Pandemic Emergency Unemployment
Compensation (PEUC). These three CARES Act UI programs were extended or resumed under the
Continued Assistance for Unemployed Workers Act of 2020 and extended by the American Rescue
Plan Act of 2021 (ARP Act) until September 6, 2021. Our evaluation included any benefits that
claimants received from these programs as reported by the states. These programs were selected
based on federal spending research and program funding amounts.
Data Sources | The DOL OIG team assessed UI payments to individuals in the designated
geographic areas based upon UI claims data transfers from state workforce agencies to DOL OIG.
Additionally, the DOL OIG team performed on-site surveys of claimants confirmed to have collected
benefits from FPUC, PUA, or PEUC.
Methodology | To answer the objective, the DOL OIG team reviewed the CARES Act, Continued
Assistance for Unemployed Workers Act of 2020, ARP Act, Employment and Training
Administration guidance, Federal Emergency Management Agency guidance, state agreements,
www. PandemicOversight.gov, and USASpending data. To determine the amount of fraud flags for
the three key CARES Act programs paid in the designated geographic areas, the review team worked
with OIG data scientists to assess claimants in the designated area for several key fraud indicators.
To assess the participants’ experiences with the three key CARES Act UI programs in the designated
geographic areas, we judgmentally67 selected 60 claimants with whom DOL OIG investigators
performed on-site interviews between May 2, 2022, and May 9, 2022, for Springfield. Prior to
selection, claimants with fraud indicators were removed to ensure interviews of only eligible UI
claimants and to not impact ongoing or future investigations. OIG investigators traveled to the area
and performed in-person interviews with the claimants. The survey results were then aggregated to
present an overall depiction of the participants’ experiences in the area.
67 Judgmental sampling is a non-probability sampling technique in which the sample members are chosen on the basis of the auditor’s
knowledge and judgment.

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Data Limitations
Since the claimants were judgmentally selected, we cannot project the results of our audit to larger
populations, such as statewide or nationally. This limitation is acceptable based on the objective of
this evaluation.

Standards
DOL OIG conducted this study in accordance with the Quality Standards for Inspection and
Evaluation issued by CIGIE.

Project-Based Rental Assistance - CARES Act | U.S.
Department of Housing and Urban Development, Office of
Inspector General
Methodology
Scope | We conducted the review remotely from May through August 2022. Our review covered the
use of Project-Based Rental Assistance (PBRA) CARES Act funds by a sample of multifamily rental
housing properties in Springfield, MA, from program inception through September 30, 2021. Our
review objectives were to determine whether the PBRA CARES Act funds were spent in alignment
with program goals and objectives and whether the funds positively or negatively impacted the
properties’ ability to respond to the pandemic.
Methodology | To accomplish our review objectives, we:
• Reviewed applicable HUD requirements (HUD memorandum and notices).
• Interviewed HUD staff to gain an understanding of the goals and objectives of the PBRA
CARES Act and CSP funds.
• Interviewed representatives of multifamily rental housing properties to obtain feedback on the
impact of the PBRA CARES Act and CSP funds.
• Reviewed a sample of properties that received an automatic allocation of PBRA CARES Act
funds.
• Reviewed a sample of properties that received CSP funds, and the corresponding supporting
documentation provided by HUD and the properties, including CSP requests, invoices, and
receipts.
The review universe consisted of 45 funding awards made to 34 properties in Springfield totaling
$2,741,072. From this universe, we selected a non-representative sample of two properties that

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received the highest automatic allocation of PBRA CARES Act funds totaling $538,350 for review.
We also selected from this universe a non-representative sample of three properties that received
both an automatic allocation of PBRA CARES Act and CSP funds totaling $272,567 for review to
determine whether the funds were spent in alignment with the program goals and objectives.
To achieve our objective, we relied in part on HUD’s computer-processed data. Although we did
not perform a detailed assessment of the reliability of the data, we determined that the data were
sufficiently reliable for the purposes of our review because we corroborated the funding award data
for the sampled properties with supporting documentation provided by HUD and the multifamily
properties.
We determined that internal controls were not relevant to our objectives. Our objectives were not to
evaluate or provide assurance of the multifamily properties’ internal controls. Therefore, we did not
assess the multifamily properties’ controls or express an opinion on them.

Standards
We conducted this review in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the review to obtain sufficient, appropriate
evidence to provide a reasonable basis for our findings and conclusions based on our objective(s).
We believe the evidence obtained provides a reasonable basis for our conclusions based on
our objective.

Provider Relief Fund Payments to Nursing Homes |
U.S. Department of Health and Human Services,
Office of Inspector General
Scope
The U.S. Department of Health and Human Services (HHS) OIG examined the use of targeted
Provider Relief Fund (PRF) payments to one nursing home in Springfield, MA, during calendar years
(CYs) 2020 and 2021. The selected facility was the only facility within Springfield, in our data,
that received direct PRF payments through distributions that HHS targeted for nursing homes and
certified skilled nursing facilities (SNFs).68 Because of data constraints, we excluded two nursing
homes that did not receive direct, targeted PRF payments, although they may have received PRF
funds distributed to their owners. We also excluded a third nursing home because, although its
Taxpayer Identification Number received PRF payments, those payments did not go to its location in
68 To determine the sample of nursing homes, we filtered data about PRF payments to nursing homes, which HHS OIG’s Division of Data Analytics
accessed directly through its data use agreement with HRSA, using ZIP Codes for Springfield provided by the PRAC. We also verified the sample
by using mapping tools to identify any additional nursing homes that were located within the ZIP Codes but included in the PRF data under
another location, such as the location of the facility’s owners.

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Springfield. We conducted our data collection concurrently with the PRAC’s site visit to Springfield
during May and June 2022 as part of our larger contributions to the PRAC study on the impact of
federal pandemic relief spending in six select locations. We used interviews, documentation, and
data analysis to identify how the nursing home used the PRF payments and whether it experienced
any challenges using these funds. Through our review, we also gathered the perspectives of
corporate and facility leaders, staff, and residents regarding whether the PRF payments helped
them prevent, prepare for, and respond to COVID-19, and whether the facility complied with terms
and conditions related to PRF use.

Methodology
Data Sources
Interviews
To evaluate the nursing home’s use of PRF payments, we interviewed leadership, staff, and a small
number of residents from the selected facility. We also conducted two group interviews with Health
Resources and Services Administration (HRSA) officials who were responsible for administering and
overseeing the payments. We employed adaptable interview protocols that allowed us to modify
questions, as needed, and follow up on additional issues as we learned new information and
identified key issues.
Nursing Home Interviews | We conducted group interviews with corporate and facility leaders and
staff in the selected nursing home. Participants included corporate and regional executives, facility
leadership, and a small number of clinical and nonclinical staff. We also conducted a small group
interview with residents as a way of gathering additional, supplementary insights and illustrations
about facility services and resident perceptions about the effects of the funding.
During these interviews, we discussed how the nursing home used the PRF payments and its
experiences in using the funds and reporting the information to HRSA. We discussed facility
leadership and staff perceptions of how the payments helped the facility prevent, prepare for,
and respond to COVID-19, and challenges that hindered their use of the funds. Additionally, we
discussed nursing home interactions with HRSA officials related to PRF use and oversight, and
any additional assistance from HRSA that the facility reported would have been useful. Although
our evaluation focused on targeted PRF distributions to nursing homes and certified SNFs, the
responses also included references to other general or targeted payments that the facility received.
HRSA Interviews | We conducted a few group interviews with PRF program administrators in
HRSA‘s Provider Relief Bureau. During the interviews, we gathered more detailed information about
PRF goals and performance metrics. We also discussed HRSA’s efforts to manage and oversee
the PRF, including the agency’s efforts related to PRF payment distribution, provider reporting
processes, audits, the recovery of improper or unintended payments, and other efforts.

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Document Review
We collected available funding receipt attestations and reports to HRSA about how the nursing
home used the PRF payments. The documents were extracted directly by HHS OIG’s Division of
Data Analytics, using a data use agreement it has with HRSA, during late April 2022 in preparation
for the PRAC’s series of location site visits, which began with this one in May 2022. At that
time, only two of four required reporting periods had passed, so the facility had not yet reported
on its use of all PRF payments. It had, however, reported on most of the payments it received
through the targeted distributions to nursing homes and certified SNFs. We also requested and
reviewed summary documentation from the facility supporting expenses outlined in those reports.
Additionally, we requested any correspondence between HRSA officials and the facility about the
PRF money and the reports, as well as any documentation of HRSA’s actions to assess and enforce
terms and conditions related to use of the funds, or to rescind funds not used according to those
requirements. As of June 8, 2022, HRSA had no documentation of oversight actions related to
the facility.
Data
To summarize the PRF payments the nursing home received and kept, we reviewed PRF payment
data from HRSA for the selected facility, which HHS OIG's Division of Data Analytics accessed
directly through its data use agreement with HRSA. We collected the PRF payment data in
preparation for the PRAC’s series of location site visits; the data were extracted on February 28,
2022, and, depending on whether the payments were made electronically or by check, were current
through the beginning of January or February 2022. The data, therefore, included all payments
made during our timeframe of CYs 2020 and 2021 (the first four distribution periods) and were
collected in time for us to conduct an initial analysis prior to the site visits.

Data Analysis
We conducted a qualitative analysis of interview data and documentation from the nursing home
and HRSA. We used our analysis to gain a deeper understanding of PRF program strengths and
weaknesses from the perspective of the nursing home. This analysis also helped us to determine
how the selected nursing home used targeted payments to improve infection control and address
health care expenses and lost revenue related to the pandemic.
We conducted a quantitative review of PRF payment data and of the nursing home’s financial
documentation. We used our analysis of the data to briefly summarize the types and amounts of
PRF payments the facility received and how the funds were used.

Limitations
HHS OIG focused only on the experiences of the selected nursing home. Our findings cannot be
extrapolated to all nursing homes that received PRF payments.
Although HHS OIG compared the nursing home’s reports to HRSA against supporting

Pandemic Response Accountability Committee

documentation and PRF terms and conditions to assess appropriateness, we did not conduct an
audit of the facility’s financial documentation to verify its reports and supporting material.

Standards
HHS OIG conducted this study in accordance with the Quality Standards for Inspection and
Evaluation issued by CIGIE.

Pandemic Response Accountability Committee

For more information:
Lisa Reijula
Associate Director of Outreach and Engagement, PRAC
Lisa.Reijula@cigie.gov

Visit us at:
PandemicOversight.gov

Report Fraud, Waste, Abuse, or Misconduct:
To report allegations of fraud, waste, abuse, or
misconduct regarding pandemic relief funds or programs
please go to the PRAC website at
PandemicOversight.gov.

A Committee of the
Council of the Inspectors General
on Integrity and Efficiency

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A Review of Pandemic Relief Funding and How It Was Used In Six U.S. Communities - Springfield, Massachuesetts

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