A Review of Pandemic Relief Funding and How It Was Used In Six U.S. Communities Coeur d’Alene, Idaho

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A Review of Pandemic Relief Funding
and How It Was Used in Six U.S.
Communities
Coeur d’Alene, Idaho
July 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

Pandemic Response Accountability Committee
ii
CONTENTS
Taking a Closer Look at a Community’s Experience: Coeur d’Alene, ID .......................................... 1
CARES Act Urbanized Area Formula Program ................................................................................... 5
Community Development Block Grant – CARES Act ......................................................................... 8
Coronavirus Relief Fund ....................................................................................................................11
Elementary and Secondary School Emergency Relief Program ....................................................16
Farmers to Families Food Box Program ...........................................................................................20
Pandemic Unemployment Insurance Programs ..............................................................................23
Project-Based Rental Assistance – CARES Act ...............................................................................31
Provider Relief Fund Payments to Nursing Homes .........................................................................34
Appendix A: Acronyms .......................................................................................................................42
Appendix B: Scope and Methodology ..............................................................................................44
CARES Act Urbanized Area Formula Grants Program .................................................................45
Community Development Block Grant – CARES Act ...................................................................47
Coronavirus Relief Fund ................................................................................................................48
Elementary and Secondary School Emergency Relief Program ................................................49
Farmers to Families Food Box Program .......................................................................................50
Pandemic Unemployment Insurance ...........................................................................................51
Project-Based Rental Assistance – CARES Act ............................................................................52
Provider Relief Fund Payments to Nursing Homes .....................................................................53

Taking a Closer Look at a
Community’s Experience:
COEUR D’ALENE, IDAHO
This report is the second in a series
taking an in-depth look at how six
communities used federal pandemic
funding to address a wide range of
community-based needs. In this report,
we focus on the city of Coeur d’Alene, ID,
with a detailed look at eight of the 45
pandemic programs that provided funding
to the community. For more information
about our review, see Appendix B.
Coeur d’Alene, ID, one of the top 10
largest cities in the state, has a total of
56,733 inhabitants. The city has a large
tourism industry and is a 40-minute drive
from Spokane, WA. Located on the edge of
Lake Coeur d’Alene, the city boasts several
attractions, including a world-famous
floating green on the 14th hole of the
Coeur d’Alene Resort Golf Course. As of
February 28, 2023, Kootenai County—
which includes Coeur d’Alene—had
experienced 47,273 recorded cases of
COVID-19, with 669 recorded deaths.
In the first part of our review, Tracking
Pandemic Relief Funds that Went to Local
Communities Reveals Persistent Data
Gaps and Data Reliability Issues, we found
that Coeur d’Alene recipients, including the
city government, small businesses, and
individuals, received more than $314.4
a U.S. Census Bureau for counties and cities.
b 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 county-
wide rate and is not specific to the Coeur d'Alene, ID, city borders. Data as of May 30,
2023.
d Data obtained from the Panhandle Health District in Coeur D’Alene, ID, and identifies
totals for Kootenai County as of February 28, 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.

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Pandemic Response Accountability Committee
million from 45 federal pandemic relief programs
and subprograms during the first 18 months of the
pandemic.
This report provides a closer look at eight federal
departments’ pandemic relief programs and
subprograms—a total of seven departments and
the funding they provided to Coeur d’Alene. These
programs aimed to mitigate the effects of the
pandemic by addressing community development
needs that posed a serious threat to the health
or welfare of the community, supporting public
transportation agencies, developing learning
loss remediation programs for local schools,
and other efforts.
We sought to gain more insight into how Coeur
d’Alene used its pandemic relief funding, how
the spending generally aligned with the goals
and objectives of the federal programs and
subprograms, and whether the funding helped
Coeur d’Alene residents respond to the pandemic.
Programs Selected for
Further Review
Coronavirus Aid, Relief, and Economic
Security (CARES) Act Urbanized Area
Formula Grants Program
U.S. Department of Transportation
Community Development Block
Grant – CARES Act (CDBG-CV)
U.S. Department of Housing and Urban
Development
Coronavirus Relief Fund (CRF)
U.S. Department of the Treasury
Elementary and Secondary School
Emergency Relief Program (ESSER)
U.S. Department of Education
Farmers to Families Food Box Program
U.S. Department of Agriculture
Pandemic Unemployment
Insurance Programs
U.S. Department of Labor
Project-Based Rental
Assistance (PBRA) – 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
Pandemic Impact on
the Community
The pandemic impacted many aspects of life in
Coeur d’Alene. For example, the public health
emergency had an impact on the operations of the
public school system through shutdowns and the
move to remote learning early in the pandemic.
Additionally, as the city began to reopen, the
community had a great need for more childcare
services so that parents could return to work.
The average unemployment rate in Coeur d’Alene
increased from 3.4 percent in 2019 to 7.4 percent
in 2020, peaking at 18.4 percent in April 2020. To
help address unemployment, Coeur d’Alene residents received more than $36.6 million in federal
benefits from pandemic-related unemployment insurance (UI) programs.
Local officials noted that the city shut down at the beginning of the pandemic. The Idaho governor’s
reopening plan, or Idaho Rebound stages, resulted in Coeur d’Alene gradually reopening in summer
2020 before many other communities in neighboring Washington state. This resulted in increased

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foot traffic during traditionally off-season times (i.e., winter 2020-2021) from areas like Spokane,
WA. The city also observed a significant in-migration of individuals moving from other states and
regions of the country into Coeur d’Alene during the pandemic. In addition, high demand as well
as inflation impacted the cost of housing and other necessities, which, according to some local
officials, deterred individuals from applying for work in the area. At the time of our visit in June
2022, Coeur d’Alene still struggled to address the increased housing demand caused by significant
in-migration.
Program Impact on the Community
Officials that the Pandemic Response Accountability Committee (PRAC) and Offices of Inspectors
General (OIG) teams interviewed offered a wide variety of responses when asked about the
community’s use of federal pandemic funds. Coeur d’Alene officials told us how the community
addressed the impacts of COVID-19. The community also told our teams that the federal
government’s emergency assistance helped with immediate responses to the pandemic.
• Kootenai County Transit System officials believe that it would have been extremely difficult for
them to respond to the pandemic without the Coronavirus Aid, Relief, and Economic Security
(CARES) Act Urbanized Area Formula Grants Program funding. Through September 30, 2021,
the Urbanized Area of Coeur d’Alene received about $4.9 million from the Federal Transit
Administration (FTA) Urbanized Area Formula Grants Program allowing Kootenai County Transit
System to continue to provide transportation services such as fare-free buses and demand-
response van services during the pandemic. FTA obligated about $4.5 million of these funds to
the Kootenai County, which operates Kootenai County Transit System.
• The city, working with existing nonprofit organizations, received $446,799 from the CARES Act
Community Development Block Grant program (CDBG-CV) to expand childcare access, provide
food for families and seniors, provide housing and utility access for workers, and provide rental
assistance.
• As of March 31, 2022, a total of 19 subrecipients—such as the city government, the public
school system, and the medical center—received $16.8 million from the U.S. Department of
the Treasury’s (Treasury) Coronavirus Relief Fund (CRF). The subrecipients used the funds
to pay salaries and wages for public health and safety employees substantially dedicated to
respond to COVID-19, facilitate distance learning at schools, increase the capacity of hospitals
to treat COVID-19 positive patients, and address the shortage of skilled workers in the
healthcare industry by providing training in fields such as medical coding.
• The city received $163,819 from the U.S. Department of Housing and Urban Development’s
(HUD) initial allocation of the Project-Based Rental Assistance-CARES Act funding. The funds
were used to help pay for the increase in rental subsidies needed for families that lost income
due to the pandemic.
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Participant Experience
During our visit in June 2022, we received feedback from multiple officials in Coeur d’Alene whose
offices or organizations received federal funding. These officials shared their experiences with
federal programs as they responded to the pandemic within Coeur d’Alene and highlighted the
challenges and successes. For example:
• A city official said the CDBG-CV funding helped the city’s ability to respond to the pandemic,
especially at the beginning when services and businesses shut down. Several nonprofit
organizations proactively contacted the city to help explain community needs. This
coordination helped facilitate the city’s efforts to address the community’s needs.
• The city’s use of CRF award funds was a collaborative process with the Idaho state
government, which established the Coronavirus Financial Advisory Committee to help
communities across the state work together to develop and implement best practices for using
the funds to meet communities’ needs.
• Coeur d’Alene Public School System officials noted that they struggled to find staff for their
programs. For example, the officials said the school system struggled with teacher burnout. To
address this concern, the school system used Elementary and Secondary School Emergency
Relief Program (ESSER) funding to increase teacher pay and retain staff during hybrid learning.
In addition, an official noted that public school applicants and new hires were at times unable
to find affordable living accommodations to live and work in the city.
• 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 from five nursing homes within the city limits reported that
Provider Relief Fund (PRF) payments to nursing homes were integral to the pandemic
response.
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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 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 the U.S. Department of Transportation (DOT) OIG 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 DOT OIG determined was 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 the Urbanized Area Formula Grants Program to be
eligible for the CARES Act Urbanized Area Formula Grants Program.
Through September 30, 2021, FTA made about $4.9 million in COVID-19 relief Urbanized Area
Formula Grants Program funds available to the Coeur d’Alene, ID, urbanized area. FTA obligated
about $4.5 million of the funds through a CARES Act-funded grant to Kootenai County. At that time,
FTA had disbursed $785,364 from the grant to Kootenai County. Kootenai County is responsible for
the oversight and management of the Kootenai County Transit System (also known as Citylink), a
small urban system serving several cities, including Coeur d'Alene.
The Kootenai County Transit System provides fare-free, fixed-route bus and Americans with
Disabilities Act demand-responsive van service. The system is partially funded by federal and state
funds awarded to Kootenai County. Grant matching funds are provided by participating cities, the
county, the Coeur d'Alene Tribe, Kootenai Health, and the Area Agency on Aging.
1 In March 2020, FTA received $25 billion through the CARES Act 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 Act of 2021 (Pub. L. No. 117-2).

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Program Impact on the Community
Kootenai County officials believe that it would have been extremely difficult for them to respond to
the pandemic without the CARES Act Urbanized Area Formula Grants Program funding. According
to officials, the county had to look to federal funding because the system had no additional funding
sources and the costs associated with the pandemic would have been detrimental to its operations.
DOT OIG determined the county’s expenditures from its CARES Act Urbanized Area Formula
Grant through September 30, 2021, aligned with the purposes for which the funding was given.
Specifically, the county used the funds to:
• Pay administrative leave for staff under
quarantine or concerned with COVID-19 risks,
which allowed the county to keep bus drivers
and mechanics employed. According to a county
official, this was important because drivers and
mechanics are hard positions to fill.
• Pay bonuses to drivers who continued working
during the pandemic.
• Pay for operational items such as fuel, preventative maintenance, paper and printing costs,
electricity, and sewer fees.
• Purchase personal protective equipment, cleaning services and supplies, driver barriers, and
equipment to allow non-customer facing employees to work from home.
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.
County officials explained that a county board reviews and approves grant expenditures, and
the CARES Act Urbanized Area Formula Grants Program expenditures were no exception. For the
CARES Act funding, county officials elaborated that they confirmed expenditures met the CARES
Act criteria, submitted them to the county board for approval, and then submitted them to FTA for
reimbursement.
The county officials DOT OIG interviewed indicated the funds had a tremendous impact and one
even called the 100-percent federal share “a real gift.” 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 (ARRA) of 2009—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
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meet this requirement.2 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 with Programs
County officials believe that CARES Act Urbanized Area Formula Grants Program funding was
sufficient and well administered. An official noted the funding came through pretty quickly and the
amount was “more than sufficient.” The official continued that the transit agency is currently using
its regular allocation of Urbanized Area Formula Grants
Program funding and keeping the remaining CARES Act
funding as a safety net. Another county official also indicated
satisfaction with the program’s administration, stating that
the funds were provided in a logical and reasonable way.
Two county officials noted FTA’s webinars and Frequently
Asked Questions on its website were particularly helpful
at providing guidance. While they indicated that FTA’s
information could have been clearer initially, they said that FTA clarified the guidance fairly quickly.
The third official said FTA drafted a lot of the material quickly and, when the county staff had
questions, it was easy for them to find the answers. Regarding the webinars, a county official was
impressed with the level of information FTA provided—including presentations by experts from the
Centers for Disease Control and Prevention—and said the Agency did a “fabulous” job.
2 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.
USING FEDERAL FUNDS
Officials noted FTA’s webinars and
Frequently Asked Questions on its
website were particularly helpful at
providing guidance.
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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 were shut down. While Spokane,
WA, remained shut down, businesses in the nearby city of Coeur d’Alene, ID, began to reopen,
following Idaho’s reopening plan, from around the middle of May through the end of June 2020. As
a result, demands for services and dining at restaurants increased significantly, as many residents
from the State of Washington traveled to the city. During the same time, the city observed a
significant increase in-migration of individuals. City leaders said that many of the new residents
were retirees. The pandemic and an increased in-migration brought higher demand for services
in the city and created more jobs than could be filled by its available workforce. While some
households’ incomes were not affected because the individuals were retired, collected disability
benefits, or remained employed, others might have lost their jobs during the pandemic. The
pandemic affected residents differently, depending on whether their household incomes were
affected or whether schools and daycare facilities remained open to allow parents to go to work.
The CARES Act (signed into law on March 27, 2020) made available to HUD $5 billion in
supplemental CDBG funding for grants to prevent, prepare for, and respond to CDBG coronavirus
(CDBG-CV) grants. Of that amount, $2 billion was allocated to grantees using HUD’s CDBG
allocation formula for 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 HUD Secretary’s
discretion according to a formula based on
public health, economic, and housing impacts of
coronavirus.
Existing connections with nonprofit organizations
helped the city use its CDBG-CV funding to address
the need for childcare across the community so that
parents could continue to work.
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 for the annual CDBG

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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) prevent or
eliminate 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
it used for 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 frequently asked questions 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. For example, the city reached out to its
local HUD office representative for guidance on allowable uses for the funds.
Program Impact on the Community
Using CDBG-CV program funds, the city awarded grants to nonprofit organizations under its
Community Opportunity Grant program. The Community Opportunity Grant program provided
funding for projects that would benefit low-to-moderate-income people or neighborhoods; promote
job creation and economic development; and prevent, prepare for, and respond to coronavirus. With
this funding, nonprofit organizations provided the following services and assistance to residents
impacted by the pandemic:
• Expanded childcare and academic support for working families.
• Provided food and meal assistance for families and seniors.
• Provided housing and utility assistance to workers.
• Provided shelter, food, and rental assistance for survivors of domestic violence.
• Provided emergency shelter and kitchen services for the homeless population.
As of September 30, 2021, HUD had awarded $446,799 in CDBG-CV funding to the city, of which
the city had spent $242,721. The city has until September 1, 2027, to spend the remaining
USING FEDERAL FUNDS
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 generally used its
CDBG-CV funds in accordance with the
goals and objectives of the program.
amount. The city planned to use the remaining funds
for Community Opportunity Grants to local nonprofits
and service providers for public service projects and
administrative costs.
HUD OIG's review showed that the city generally used its
CDBG-CV funds in accordance with the goals and objectives
of the program. One of the CDBG-CV program goals is to
develop viable urban communities by expanding economic
opportunities, principally for low- and moderate-income
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persons. The city demonstrated that its program expenditures met this goal by providing grants
to nonprofit organizations to pay for allowable expenses, such as rent, utilities, food, and other
operating expenses that benefited low- and moderate-income persons.
Participant Experience
A city official believed that the CDBG-CV funding helped significantly with the city’s ability to respond
to the pandemic, especially at the beginning of the pandemic when many things shut down. Some
nonprofit organizations proactively contacted the city regarding funding and community needs.
Coordination with these nonprofit organizations and existing infrastructure allowed the city to
address the needs of the community. For example, existing connections with nonprofit organizations
helped the city use its CDBG-CV funding to address the need for childcare across the community so
that parents could continue to work.
FOR MORE INFORMATION
For more information about Community
Development Block Grant – Coronavirus
program spending across the country,
visit the PRAC’s website.
Pandemic Response Accountability Committee

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PROGRAM SNAPSHOT
Coronavirus Relief Fund
U.S. Department of the Treasury
In March 2020, the city of Coeur d'Alene, ID, (Coeur d'Alene or the city) experienced its first case
of COVID-19 which surged to 1,538 cases by July 2020. Through December 2020, Coeur d’Alene
confirmed 12,665 cases and experienced challenges with responding to the effects of COVID-19.
As of February 28, 2023, Kootenai County—which includes Coeur d’Alene—experienced 47,273
recorded cases of COVID-19. Priorities included obtaining personal protective equipment (PPE)
and sanitization supplies. Upon receipt of federal funding, the city acquired and distributed PPE
and sanitization supplies, such as masks, respirators, gloves, and gowns to medical personnel as
efficiently as possible. The city also faced challenges with misinformation within the community
about the COVID-19 vaccine and mask mandates. In response, it leveraged existing infrastructure
by collaborating with nonprofit organizations to coordinate services to combat misinformation.
The COVID-19 public health emergency significantly impacted the operations of the city’s Fire
Department and Public School System. The Fire Department prioritized obtaining PPE and
additional equipment such as masks, respirators, laptops, and radios to prevent the spread of
COVID-19 and ensure that employees were not sharing equipment. Fire Department emergency
medical services personnel came in close contact with each other and sick individuals; therefore,
keeping workers socially distanced to the fullest extent possible was imperative. The Fire
Department collaborated with the Coeur d’Alene health district and hospital to proactively initiate
a countywide group for emergency medical services and deployed new COVID-19 prevention
guidelines. The new model required emergency medical services personnel to wear masks at all
times while in emergency facilities, including fire stations and vehicles. Additionally, personnel were
required to undergo daily screenings, temperature checks, and quarantine if they fell ill.
Public School System officials decided to close
schools on March 17, 2020, and prioritized
transitioning to a remote learning environment
and providing childcare with priority placement for
essential employees. The Public School System has
roughly 10,000 students spread across 18 schools:
one preschool, 11 elementary schools, three middle
schools, and three high schools. Public School System officials explained that they began
acquiring equipment and internet access immediately for students and staff and leveraged
school buses to deliver equipment to students.
The Public School System obtained technology
equipment and internet access to successfully
transition approximately 10,000 students spread
across 18 schools to a virtual learning environment.

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Program Information
The CARES Act established the CRF program and appropriated $150 billion for the U.S. Treasury
to make payments to states, eligible units of local government, the District of Columbia, U.S.
territories, and Tribal governments (collectively referred to as prime recipients).3 As of December
31, 2022, Treasury disbursed CRF awards to 964 prime recipients, which subsequently distributed
the award funds to 89,969 subrecipients through contracts, grants, loans, direct payments, or
fund transfers. CRF awards allowed 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, the CRF awards 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 were (1) necessary
expenditures incurred due to the public health emergency with respect to the COVID-19 pandemic;
(2) for costs not accounted for in the recipients’ budget most recently approved as of March 27,
2020; and (3) incurred during the covered period (March 1, 2020 through December 31, 2021).4
Prime recipients are responsible for reporting CRF award expenditures on a quarterly basis during
the covered period in GrantSolutions.5
Coeur d’Alene did not receive a CRF award directly from the Treasury. Subrecipients geographically
located in Coeur d'Alene received CRF award funds from the State of Idaho and the State of Indiana,
which received a CRF award directly from Treasury. As prime recipients, Idaho’s and Indiana’s
responsibilities included, but were not limited to, providing guidance to subrecipients, reiterating
federal requirements, and reviewing subrecipients’ expenditure reports to assess compliance
with the eligible use of funds requirements under the CRF award. Coeur d’Alene officials stated
they attended weekly meetings with the Idaho State Controller’s Office to discuss community
needs that required CRF assistance. The Coeur d’Alene Grant Oversight Committee addressed
ad-hoc COVID-19 related inquiries. A hospital nonprofit organization also provided eligible use
guidance and training to healthcare subrecipients. Additionally, city officials noted the Idaho State
Controller’s Office and a contracted certified public accounting firm performed CRF award post-
disbursement monitoring by reviewing general ledger transactions and other supporting
documents to ensure expenses were not reimbursed by more than one funding source. Overall,
the five selected subrecipients in Coeur d’Alene affirmed that Idaho, Indiana, and the city were
very responsive when providing COVID-19 related resources and guidance.6
3 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; and, The U.S. territories
are as follows: United States Virgin Islands, Guam, American Samoa, Puerto Rico, and the Commonwealth of the Northern Mariana Islands.
4 The Consolidated Appropriation Act, 2021, P. L. 116-260 (December 27, 2020), amended the CARES Act by extending the covered period for
CRF recipients awards to use the CFR award funds 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, included in Division LL Section 104 of the Consolidated Appropriations Act, 2023, P.L. 117-328, December 29, 2022, 136 Stat. 4459.
5 GrantSolutions, a grant and program management federal shared service provider under the U.S. Department of Health and Human Services,
developed a customized and user-friendly reporting solution to capture the use of CRF payments from recipients.
6 Treasury OIG selected five subrecipients out of 19 for the review—city of Coeur d’Alene, Coeur d’Alene Public School System, a medical center,
a short-term nursing and rehabilitation facility, and a medical coding company.
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Program Impact on the Community
Treasury disbursed $1.25 billion in CRF award funds to Idaho, which awarded approximately $16.64
million to 18 subrecipients, through direct payments and transfers, located in Coeur d’Alene.
Indiana awarded $170,625 in a CRF grant to one additional subrecipient located within Coeur
d’Alene. As of March 31, 2022, the 19 subrecipients expended all of the $16.81 million awarded
to assist with overcoming local community pandemic impacts. Treasury OIG sampled a total of
$14.72 million (88 percent) of CRF award funds for five subrecipients to determine whether
they used the CRF award funds in alignment with the program’s goals and objectives.
Subrecipients used the funds to pay salaries and wages for public health and safety employees
substantially dedicated to respond to COVID-19, facilitate distance learning, increase the capacity
of hospitals to treat COVID-19 positive patients, and address the shortage of skilled workers in the
healthcare industry by providing training in fields such as medical coding. Additionally, the sample
award funds tested were used in compliance with the CARES Act and Treasury guidance. As a
result, the overall assessment of risk for ineligible use of CRF award funds is low. As such, CRF
award funds were used in alignment with the program’s goals and objectives of preventing and
mitigating the impacts from the COVID-19 public health emergency.
City of Coeur d’Alene
Idaho distributed more than $8 million in CRF award funds to the city and it allocated the funds
to the Police Department and Fire Department. They used the funds to (1) pay wages and
benefits for police officers and firefighters whose duties were substantially dedicated to responding
to the COVID-19 public health emergency; (2) purchase a sanitization system to disinfect vehicles,
rooms, and equipment in schools and other facilities; and (3) purchase additional radios to
facilitate social distancing by preventing emergency medical services personnel from sharing
equipment.
Coeur d’Alene Public School System
Idaho distributed almost $3.3 million in CRF award funds to the Public School System. It used the
funds to (1) transition to a remote learning environment and (2) facilitate a safe return to school for
students and staff. Allocation of the funds to 18 schools within the city was based on student
enrollment. The schools received roughly $316 for each enrolled student to acquire necessary
items including PPE; Heating, Ventilation, and Air Conditioning (i.e., HVAC) filters; remote
learning instructional licenses; and technology devices.
Medical Center
Idaho distributed almost $2.1 million in CRF award funds to the center. It established a designated
COVID-19 unit at the beginning of the pandemic to care for COVID-19 positive patients and used
the funds to contract medical personnel for the newly established COVID-19 unit to alleviate the
load of their existing medical personnel.
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14
Short-term Nursing and Rehabilitation Facility
Idaho distributed $927,408 in CRF award funds to a short-term nursing and rehabilitation facility to
cover increased costs resulting from admitting and caring for COVID-19 patients. Idaho authorized
reimbursable payments to cover up to $30,000 per COVID-19 positive patient admitted to its facility
from Idaho hospitals, to enable the facility to admit patients who require skilled nursing care but no
longer require hospitalization, creating additional capacity for hospitals to care for COVID-19 positive
patients. Additionally, the facility used CRF award funds to purchase masks, hospital gowns, other
PPE supplies, and cover payroll expenses. Idaho required the nursing and rehabilitation facility to
submit applications for each patient to show proof of a positive COVID-19 test, hospital discharge,
and admission to the facility.
Medical Coding Company
The State of Indiana distributed $170,625 as a grant to a subrecipient located in Coeur d’Alene
to provide training to eligible recipients in Indiana. The company provides medical coding training
to individuals looking to enter the healthcare industry. The funds were used to pay for expenses
necessary to attend the training such as registration fees, textbooks, and testing fees.
Participant Experience
Satisfaction
A Coeur d’Alene’s city official stated that the city’s response to the pandemic was a collaborative
process with the Idaho governor. The official also told Treasury OIG that a Coronavirus Financial
Advisory Committee helped subrecipients educate one another, develop synergies, and
implement best practices for CRF eligible use of funds requirements. The subrecipients
interviewed expressed overall satisfaction with Treasury’s CRF program guidance, the federal
allocation process, eligible use determinations, their experience with federal funding,
communication amongst state and county agencies, prime recipients’ CRF guidance, and
their ability to use CRF award funds.
Coeur d’Alene officials explained that federal and state CRF guidance was sufficient to identify
eligible uses of CRF award funds. They also explained that the city, Idaho state government, and
local agencies participated in weekly meetings to obtain CRF guidance clarification and assess
COVID-19 impacts. A Coeur d’Alene official felt that the CRF allocations were more than they needed
because nonprofit organizations provided assistance prior to the federal government. The Public
School System officials told Treasury OIG that guidance changed a little over time, but it was clear
overall. The short-term nursing and rehabilitation facility officials stated that the Idaho Department of
Health was helpful when it needed guidance and clarification and mentioned there was continuous
communication with Idaho and health districts to discuss the CRF program. Additionally, the short-
term nursing and rehabilitation facility officials agreed CRF disbursements were sufficient and felt
there were no unrealistic restrictions to use the funds. Officials of the medical center in Treasury
OIG's sample shared that they collaborated with a nonprofit hospital association and the State of
Idaho to obtain CRF program assistance. Officials from the medical coding company in the sample
believe that the CRF award funds helped them in the ways the program intended.
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15
Challenges
Some subrecipients expressed it was difficult to obtain Idaho’s approval of purchases and meeting
Treasury’s December 31, 2021, deadline to obligate the funds was difficult to navigate. For
example, Coeur d’Alene officials felt it was difficult to get Idaho’s approval for certain information
technology purchase requests. A Coeur d’Alene official recalled submitting a funding request to
purchase computer monitors to enable alternating work shifts for sick employees. The monitors
would allow employees to telework, work onsite, and be on call to respond to beneficiaries and
emergencies. Although Idaho declined the monitor request, Coeur d’Alene did receive the necessary
CRF funding to establish telework capabilities for necessary employees. Additionally, an official
from the medical coding company in Treasury OIG's sample expressed that the December 31,
2021, deadline made it difficult for students to complete training programs because students
learn at different paces. The company overcame this challenge by leveraging other funding
sources. The medical center in Treasury OIG's sample identified an unmet need for additional
contract labor, which they overcame through cost saving options and alternate funding sources.
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

Pandemic Response Accountability Committee
16
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 (ED) “to prevent, prepare for, and respond to coronavirus, domestically or
internationally…”7 The CARES Act also created the 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, ED first provided ESSER funding to state educational agencies, which then
provided funds to the local educational agencies (i.e., local school districts).8
• 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 the 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 American Rescue Plan (ARP) Act and
provided $121.97 billion for ESSER. 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 agencies “within a reasonable timeline determined by the [state education
agency]” on the use of the funds, how it would engage and consult with stakeholders when
developing its plan, and how it intended to make the plan publicly available and explain the
safe return to in-person instruction and continuity of services.9
7 See CARES Act, P.L. No. 116-136, Division B, Title VIII, (March 27, 2020).
8 State education agencies 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.
9 See ED’s ESSER and GEER Use of Funds FAQs from December 7, 2022, question A-4.

17
During phase one of this review, we found that the school system within the boundaries of Coeur
d’Alene were awarded almost $22.5 million in ESSER funds, and those schools had spent around
$1.66 million in funds from ESSER I. As of September 30, 2021, these schools had not yet spent
any of their ESSER II or ESSER III funds. See Table 1 for more information about the total ESSER
funding for the school system in Coeur d’Alene.
Table 1: Coeur d’Alene, ID, ESSER Funding Information, as of September 30, 2021
Total Obligated or Awarded
Total Expendeda
Expiration Date
ESSER I
$1,849,445
$1,655,356
9/30/2022
ESSER II
$6,411,112
$0
9/30/2023
ESSER III
$14,203,715
$0
9/30/2024
Total
$22,464,272
$1,655,356
-
a Total Expended reflects the total amount of funding expended by the local education agencies for which the state education
agencies has issued a reimbursement.
Program Information
Our work covered the Coeur d’Alene Public School System— the largest school district within the
city. Coeur d’Alene Public Schools spent the $1.66 million noted in the above table. During our
work, Coeur d’Alene Public Schools had around 10,000 students across 18 schools including a
developmental preschool, 11 elementary schools,
three middle schools, two traditional high schools,
COEUR D’ALENE PUBLIC
SCHOOLS OPERATING STATUS
End of 2020 School Year
Fully remote learning.
2020–2021 School Year
Hybrid model to start year – half the students
were in school at a time and the other half
remote. In the second semester the school
system was fully open.
2021–2022 School Year
Fully open.
one alternative high school, and one credit
retrieval program.10 Members of the five-member
Board of Trustees are elected by the public and
govern the school system. ESSER I, II, and III funds
awarded to Coeur d’Alene Public Schools totaled
almost $22.4 million.
An official stated that the school system had spent
ESSER I funding on certificated teacher salaries
to cover budget shortfalls.11 Another school
system official also said that because of a drop in
enrollment from pre-pandemic levels, the system’s
annual state funding dropped by $1.3 million.
According to information from the state education
10 Obtained from Coeur d’Alene Public Schools website.
11 Certificated teachers are teachers holding a teaching certificate issued
by the Idaho Department of Education.
Pandemic Response Accountability Committee

18
agency, at the time of our review, the school system had spent $1.6 million of the $1.66 million it
received on salaries and benefits.
While our review covered the school system reported ESSER expenditures from the beginning of
the pandemic through September 30, 2021, we also spoke with school system officials about
the schools’ future needs and overall response throughout the pandemic. We also reviewed the
school systems ESSER III plan—required by the U.S. Department of Education. Under ESSER III
requirements, at least 20 percent of those funds must be spent on mitigating the effects of lost
instructional time (i.e., learning loss). According to the ESSER III plan, the school system sought to
address lost instructional time with the following activities:
• Expanding summer reading programs.
• Expanding summer school with interventions, Advanced Placement academics, and credit
recovery opportunities for secondary students.
• Partnering with community organizations like science, technology, engineering, and
mathematics activity groups.
• Expanding after school care to bring interventions to students with a demonstrated need.
• Educational camps.
• Tutoring.
• Apps and site licenses for students to access resources on devices provided by the school
system.
According to the school system’s June 30, 2021, financial report, the schools’ state-supported
revenue decreased by $4.83 million due to budget cuts and a drop in enrollment. The school
system’s ESSER III plan included $8.65 million in funding toward maintaining services despite state
budget cuts and enrollment dropping. The plan also included $5.85 million for staff retention pay.
The school system budgeted additional ESSER II and ESSER III funds for heating, ventilation, and
air conditioning system upgrades and repairs, and staff recruitment and retention. The plan stated
that $2.3 million was set aside to address COVID-19 mitigation efforts, which included upgrades for
heating, ventilation, and air conditioning.
Participant Experience
School system officials stated that ESSER funds helped as intended. One official also said that the
school system would not have been able to survive without the federal support. Officials noted that
the school system was able to retain employees and reassure staff because ESSER funds provided
additional budget flexibility during a time of uncertainty. Overall, they felt ESSER guidance was clear
on allowable expenditures and met the school system’s needs for its response. Staff felt that the
state education agency was very responsive to questions about the guidance.
Officials expressed that the school system faced a significant challenge assessing how much PPE
in total to purchase because they did not know how long the COVID-19 pandemic would last. The
uncertain needs for inventory, quantity, storage, and distribution contributed to the challenges.
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School system officials also said that they struggled to find staff for some of their expanded
programs. They struggled a lot with teacher burnout and chose to use ESSER funds to increase
teacher pay, and thus increase retention during hybrid learning. The school system had difficulty
with staffing. One school system official noted that in one instance applicants or new hires were
unable to find affordable living accommodations, and other officials said there were cases in which
people accepted positions but then could not find an affordable place to live, and later had to
withdraw from the positions.
SPOTLIGHT ON | FEEDING STUDENTS DURING THE PANDEMIC
While schools across the nation closed, students continued to have nutritional needs during the
day. In response, unrelated to ESSER program, the U.S. Department of Agriculture granted schools
more flexibility to feed their students. State education agencies were given the authority to approve
the delivery of meals to students’ homes, allow parents or guardians to pick-up meals without their
students being present, or approve students receiving multiple meals at a time. To help support
these efforts, ESSER funds could be used for “planning for, coordinating, and implementing
activities during long-term closures, including providing meals to eligible students…”a
Coeur d’Alene Public Schools staff said that 44 percent of the student body in 2019-2020 was
on free or reduced lunches. Officials stated they set up a food distribution within two weeks of
the school closing due to the pandemic. They used two existing facilities, one in the north and
one southern site, for food preparation. In summer 2020, school system officials said that they
expanded to two additional sites. Buses were also used to send out food to students. Eventually
there were 12 distribution sites which provided bagged meals. Initially they only provided lunch, but
eventually they also provided breakfast for students.
a U.S. Department of Education, Elementary and Secondary School Emergency Relief Programs and Governor’s Emergency Education Relief
   Programs, Frequently Asked Questions, May 2021.
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

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PROGRAM SNAPSHOT
Farmers to Families 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.
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 to ensure public safety. 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, package it in boxes, and deliver fresh
produce, dairy, and meat products to nonprofit and governmental organizations, who in turn
would distribute these boxes to families and individuals in need.12 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.
Figure 1: Three Primary Goals of the Food Box Program
12 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.

21
Program Impact on the Community
To perform our work, the PRAC team used data previously collected and analyzed by USDA OIG
in PRAC’s July 2023 report, Tracking Pandemic Relief Funds that Went to Local Communities
Reveals Persistent Data Gaps and Data Reliability Issues. Our first review highlighted data
limitations which prevented us from determining whether the program served producers,
distributors, and food recipient organizations in accordance with program goals and objectives.
During phase one USDA OIG estimated that food distributors delivered 27,602 food boxes (valued
at $1,204,086) to seven food box organizations to feed families in Coeur d’Alene.13 However, since
USDA did not consistently obtain reliable data to identify all organizations or food boxes received
and had inconsistencies within the data that it did receive, the total number of food boxes
distributed to Coeur d’Alene could have been more or less. Based on the data obtained from USDA
for these seven organizations, we noted that all together these organizations participated in
rounds two, three, and five of the food box programs.
Table 2: Food Boxes Distributed to Coeur d’Alene, ID
Food Recipient Organization
Round
Number
Number of
Food Boxes
Value
Type of Food Boxes
Delivered
Food Recipient Organization 1
2
2,121
$112,837
Precooked Meat Box
3
1,659
$170,183
3
2,121
$112,837
Combination Box
Food Recipient Organization 2
3
2,584
$122,046
Combination Box
Food Recipient Organization 3
3
262
$12,370
Combination Box
Food Recipient Organization 4
5
17,264
$569,727
Combination Box
Food Recipient Organization 5
3
480
$22,677
Combination Box
Food Recipient Organization 6
2
587
$55,280
Combination Box
2
236
$12,537
Precooked Meat Box
Food Recipient Organization 7
3
288
$13,593
Combination Box
Totals
27,602
$1,204,086
Source: USDA OIG Analysis of Food Box Program Data for Coeur d'Alene, ID.
We faced challenges obtaining more community-specific information about the total number of
families served and confirming whether other organizations received food boxes. We also could not
determine if any of the farmers or ranchers providing food boxes to Coeur d’Alene had declining
demand for food and benefited from the Food Box Program.
13 In our phase 1 report, USDA OIG estimated a total of 27,603 food boxes, and this report shows 27,602. This is an immaterial difference
attributed to how the two numbers were rounded.
Pandemic Response Accountability Committee

22
According to a Government Accountability
Office (GAO) report, USDA did not collect data
to evaluate whether the Food Box Program met
some of its primary goals—including assisting
food producers with declining demand.14
Similarly, the PRAC observed this issue of a lack
of data in our work which limited our ability to
determine the extent to which USDA met the Food
Box Program goals in Coeur d’Alene, ID. Under
the program structure set up by USDA, 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 nonprofit and governmental organizations that
received the boxes. This structure did not provide
USDA with information about which food producers
(i.e., farmers) the program helped and how many
of those 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
Because USDA did not collect contact information for the food box recipients, we could not meet
with these recipients. As a result, we could not determine how the Food Box Program impacted
families and individuals in the Coeur d’Alene, ID, community.
14 GAO, USDA Food Box Program: Key Information and Opportunities to Better Assess Performance, GAO-21-353; September 2021.
Pandemic Response Accountability Committee

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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.
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: Pandemic Unemployment Assistance (PUA), Pandemic Emergency
Unemployment Compensation (PEUC), and Federal Pandemic Unemployment Compensation (FPUC).
The three programs were later extended by the Continued Assistance for Unemployed Workers Act
of 2020 (CAA) and ARP Act, ending on September 6, 2021.15
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 claims were
submitted for regular UI, PUA, or PEUC.16
The Coeur d’Alene, ID, unemployment rate was drastically impacted by the COVID-19 pandemic.
Idaho estimated the unemployment rate in Coeur d’Alene peaked in April 2020 at 18.4
percent—over 372 percent greater than the prior year’s highest monthly rate (see Table 3).
15 Idaho ended its participation in the pandemic-related UI programs on June 19, 2021, prior to the programs’ statutory expiration of September
6, 2021.
16 Continued claims are ongoing weekly unemployment benefit claims by workers who previously filed an initial claim.

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Table 3: Coeur d’Alene, ID – Unemployment Estimates
Year
Coeur d’Alene
Average
Unemployment Rate
(%)
Coeur d’Alene
Highest Monthly
Unemployment Rate
(%)
Idaho Average
Unemployment Rate
(%)
Idaho Highest
Unemployment Rate
(%)
2018
3.4
3.6
2.8
3.0
2019
3.4
3.9
2.9
2.9
2020
7.4
18.4
5.4
11.6
2021
4.4
5.0
3.6
4.0
Source: DOL OIG analysis of Idaho Unemployment Data.
In addition to regular UI, Idaho reported 5,120 unemployed workers in Coeur d’Alene received about
$36.6 million in federal UI benefits from FPUC, PUA, and PEUC (see Table 4).17
Table 4: Coeur d’Alene, ID – 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.
$27,900,000
PUA extended UI benefits to individuals not traditionally eligible for UI benefits,
such as self-employed workers.a
$5,500,303
PEUC provided additional weeks of UI benefits to individuals who had
exhausted their regular unemployment benefits.
$3,181,457
Total Benefits
$36,581,760
Source: DOL OIG data analysis of state workforce agency claims data for the period March 27, 2020, to June 19, 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.
17 State workforce agencies provided DOL OIG data about pandemic unemployment insurance-related programs as part of a data disclosure
process. The Idaho state workforce agency provided this data as of February 24, 2022.
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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 claim to receive benefits.18
State workforce agencies would then assess eligibility and provide the claimant with the applicable
regular UI or CARES Act UI program payments, or both, 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), DOL OIG judgmentally selected
60 Coeur d’Alene residents (claimants). DOL OIG investigators traveled to the area, confirmed
the individuals filed a UI claim, and performed in-person interviews with the claimants. Of the 60
claimants, 23 (38 percent) who received benefits from at least one of the three key pandemic UI
programs chose to respond. The surveys were conducted from June 13, 2022, to June 17, 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.
18 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.
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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.19 Overall, satisfaction with the UI system was
rated 4.3 on a 5-point scale, with 48 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—17 percent of surveyed claimants rated their experiences as extremely dissatisfying.
Further, surveyed claimants identified several difficulties including confusion with program eligibility
and weekly certifications, contacting the state workforce agency, and technical difficulties, such
as identity proofing. An interview with regional state workforce agency officials identified technical
obstacles, like high traffic on websites, but also noted that the UI program allowed individuals
impacted by the pandemic to continue to support their families.20
19 Surveyors asked claimants a series of questions and claimants responded with a five-point scale on which one was extremely dissatisfied and
five was extremely satisfied.
20 The DOL OIG and PRAC audit teams interviewed officials at the Idaho Department of Labor, Post Falls Office. Idahoans out of work through no
fault of their own can get help filing for unemployment insurance from Idaho Department of Labor staff in local office locations throughout the
state.
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Figure 2: Surveyed Claimants Assessment of Claims Process
Source: DOL OIG data analysis of claimant surveys conducted from June 13, 2022, to June 17, 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
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to pay for basic necessities, and were fair and reasonable (see Figure 3).21 The surveyed claimants
also agreed or strongly agreed that the number of weeks benefits were provided was sufficient. On
average, 4 to 9 percent of surveyed claimants felt the benefits did not have a positive impact, were
insufficient, or were not fair and reasonable.
The interview with the regional state workforce agency officials noted that some employers felt
surveyed claimants could earn more by collecting UI, and, therefore, would not return to work.
However, state workforce agency officials stated there were other factors that affected individuals’
choices to return to work, such as health concerns and virtual school requiring adults to stay home.
Further, inflation had impacted the cost of resources, like housing, which deterred certain workers
from applying for work in the area.
Figure 3: Surveyed Claimants Assessment of Benefits
Source: DOL OIG data analysis of claimant surveys conducted from June 13, 2022 to June 17, 2022.
21 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.
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Claimants Generally Still Experienced Difficulty in the Labor Market
Of those who responded, 13 percent of surveyed claimants reported they were not currently working
for pay, and 22 percent reported they were unable to find employment before benefits ran out
(see Figure 4).
Additionally, 83 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, Employment and Training
Administration officials reported that, during the pandemic, initial claims for federal and state
programs rose to 10 times pre-pandemic levels, far higher than state systems were designed to
handle. Further, the interview with the regional state workforce agency indicated that the employees
in employment services switched to processing UI claims to support the increased demand.
Figure 4: Surveyed Claimants Return to Work Assessment
Source: DOL OIG data analysis of claimant surveys conducted from June 13, 2022 to June 17, 2022.
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 indicators to identify potentially fraudulent UI claims.
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30
DOL OIG identified 13 percent of the claims submitted from Coeur d’Alene, ID, as potentially
fraudulent22 (see Table 5).
Table 5: Coeur d’Alene, Idaho – Fraud Indicatorsa
Category
Claimants
Percent of Total
Amount Paid
Total Claimants
5,120
-
$36,581,760
Claimants with Fraud Indicator:
Multistate
627
12.2%
$5,596,219
Suspicious Email
10
<1%
$3,126,913
State Flagged
6
<1%
$55,139
Deceased Person
- b
- b
- b
All Preceding Fraud Indicators
(claimants with multiple indicators were
only included once to avoid duplication)
665
13%
$5,845,662
Source: DOL OIG data analysis of state workforce agency claims data for the period March 27, 2020, to June 19, 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.
b No fraud indicator identified.
Prior to the release of this report, the potentially
fraudulent claims were referred to DOL OIG’s Office
of Investigations to assess and determine if the
claims warrant investigation. If the claims did not
warrant investigation, DOL OIG 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.
22 Please note that 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.
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PROGRAM SNAPSHOT
Project-Based Rental
Assistance – CARES Act
U.S. Department of Housing and Urban
Development
As of September 30, 2021, HUD had
provided $163,819 to five PBRA
properties in Coeur d’Alene
At the beginning of the pandemic, many businesses and schools were shut down. While Spokane,
WA, remained shut down, businesses in the nearby city of Coeur d’Alene, ID, began to reopen,
following Idaho’s reopening plan, from around the middle of May through the end of June 2020. As
a result, demands for services and dining at restaurants increased significantly, as many residents
from Washington State travelled to Coeur d’Alene. During the same time, the city observed a
significant in-migration of individuals. City leaders believed that many of the new residents were
retirees. The pandemic and increased in-migration brought higher demand for services in
Coeur d’Alene and created more jobs than could be filled by its available workforce. However,
the pandemic affected multifamily rental properties differently, depending on whether residents’
incomes were affected. While some people might have lost their jobs during the pandemic, many
households’ incomes were not affected as much because they were retired, collected disability
benefits, or remained employed. The CARES Act 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.23 As of September
30, 2021, HUD had provided $163,819 to five PBRA
properties in Coeur d’Alene. Of this amount, $145,540 had been provided to five properties to
maintain normal operations, and the remaining $18,279 was provided to three 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
23 The remaining $10 million was allocated for the Section 8 Moderate Rehabilitation Program, which was not included in this review.
31

32
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
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 needs
related to maintaining 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
condition.
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 on the Community
HUD OIG’s review showed that the properties in Coeur d’Alene 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 Coeur d’Alene, 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
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33
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.
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 five property owners HUD OIG spoke with, three
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.
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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.24 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.25
The five Coeur d’Alene, ID, nursing homes in the U.S. Department of Health and Human Services
(HHS) OIG sample have had substantial financial challenges in responding to the pandemic.26
The nursing homes’ corporate and facility leaders reported lost revenue as a result of significant
drops in census during the pandemic.27 According to one facility finance officer, the total number
of days that residents occupied beds dropped by more than half compared to pre-pandemic levels,
from 2,897 days in January 2020 to 1,346 days in June 2021. Several factors contributed to the
census decline. Nursing home leaders and staff said that family members were reluctant to admit
loved ones because they were worried that the resident would contract COVID-19 or that the family
would be unable to visit due to COVID-19 precautions. Nursing home leaders and staff also reported
that medical providers in Coeur d’Alene postponed elective surgeries during the pandemic, which
resulted in fewer admissions to nursing facilities for post-acute care, and that staffing shortages
further restricted facilities’ ability to admit new residents.
24 HHS OIG, COVID-19 Had a Devastating Impact on Medicare Beneficiaries in Nursing Homes During 2020, OEI-02-20-00490, June 2021;
Government Accountability Office (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;  Centers for Disease Control and Prevention, People Who
Live in a Nursing Home or Long-Term Care Facility; GAO, Infection Control Deficiencies Were Widespread and Persistent in Nursing Homes
Prior to COVID-19 Pandemic, GAO-20-576R, May 20, 2020, p. 1; and, Lauren Weber, “Nursing Homes Keep Losing Workers,” The Wall Street
Journal, August 25, 2021.
25 Centers for Medicare & Medicaid Services (CMS), COVID-19 Nursing Home Data, August 19, 2022.
26 For the purposes of HHS OIG's review, the term "nursing homes" refers to all facilities in its sample regardless of technical status (i.e., nursing
facility and/or sskill nursing facility (SNF) according to common use.)
27 All five nursing homes were part of larger nursing home chains. Two nursing homes were part of the same chain.
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35
INCREASED COSTS RELATED TO
COVID-19
The nursing homes reported significant
increases in labor costs as a result of the
pandemic. One facility reported providing
pay bonuses of $100 to $500 per shift to
incentivize staff to work additional shifts
on an as-needed basis.
Corporate and facility leaders from all five nursing
homes reported that, while revenue declined, expenses
increased. Leaders described increased costs for PPE, with
staff using high amounts of PPE to provide resident care
under COVID-19 protocols. One facility reported sometimes
using more than 1,000 disposable isolation gowns per day
to protect residents and staff. Nursing homes also incurred
expenses in setting up dedicated isolation units to care for
COVID-19-positive residents. Setup included constructing
barriers, purchasing additional equipment, and providing
frequent COVID-19 tests to residents and staff. Other related
expenses included additional infection control supplies,
supply storage units, and technology for telehealth and virtual visits. All five nursing homes also
reported incurring significant labor costs. Nursing homes often paid staff to work extra hours to
cover the COVID-19 isolation units and the shifts of other staff who were out sick with COVID-19 or
in quarantine due to exposure. They also used pay bonuses, increased hourly rates, and hazard pay
to incentivize and retain staff. For example, two facilities reported providing hazard pay of $5 per
hour for staff working in the COVID-19 units. Other labor-related expenses included sick pay and
hotel expenses for employees who had COVID-19 or were quarantining, and meals for employees. In
addition to efforts to support existing staff, the nursing homes hired contracted staff from staffing
agencies, which further increased labor costs. Leaders at one nursing home reported that agency
nurses cost $70 per hour, twice as much as in house staff.
Nursing home staff reported both personal and operational challenges to providing care during
the COVID-19 pandemic. Staff said that early in the pandemic they were afraid of contracting
COVID 19 and exposing loved ones. Nurses in one facility described staying at a hotel for a month
to avoid the risk of bringing the virus home. Staff also said that resident illness and deaths took
an emotional toll on them, with one saying, “Everything was moving so fast, so you couldn’t even
take the time to grieve the people you’ve been with for years.” Across the facilities, staff reported
that the challenge of providing care during the COVID-19 pandemic was compounded by difficulties
surrounding COVID-19 protocols. Some staff said that implementation of the protocols sometimes
caused conflict with residents and visitors who disagreed with the COVID-19 guidance and visitation
restrictions. Frequent changes in public health guidance also made staff confused and skeptical
of the protocols. Staff also said that as the pandemic continued, some staff experienced burnout,
panic attacks, or post-traumatic stress disorder and some staff left their jobs.
Nursing home leaders, staff, and residents reported that residents experienced severe strain
during the COVID-19 pandemic. One nursing home administrator said that their facility’s first
outbreak was “very traumatic [and] extremely deadly,” with 14 resident deaths in a two-week
period. Facility leaders and staff reported that—in addition to the fear of contracting COVID-19—
residents lost human connections and a sense of community because of limited visitation and
group activities, as well as reduced interactions with staff and caregivers. One resident said, “Not
being able to hug my granddaughter or my great-granddaughter is very distressing… It breaks your
heart.” Staff also said that residents were sometimes frustrated with mask requirements, and that
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PPE often made it difficult for them to communicate with caregivers. Staff in one facility explained
that some residents refused to leave their room because they did not want to wear a mask, or that
some residents claimed they would rather die than wear PPE or not see their family. One medical
director reported an increase in cognitive issues and psychiatric illnesses (e.g., anxiety, depression,
post-traumatic stress disorder, and dementia) among residents because of emotional complications
from the pandemic.
Program Information
To reimburse health care providers for pandemic-related expenses and lost revenue, Congress
appropriated $178 billion to HHS during 2020 and 2021.28 To administer the funds, HHS
established the PRF and related programs.29 The Health Resources and Services Administration
(HRSA) is the HHS agency responsible for administering the PRF program.30 PRF includes general
and targeted distributions. General distributions were broadly available to health care providers,
while targeted distributions were 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).31
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
2023.32 For reporting purposes, HHS established periods during which recipients of both types of
PRF distributions have to use and report on the funds (see Table 6).33 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.34
28 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); and Consolidated Appropriations Act, 2021, P.L. No. 116-260,
Division M, Title III (December 27, 2020).
29 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 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; and, HHS, news release, “HHS to
Begin Immediate Delivery of Initial $30 Billion of CARES Act Provider Relief Funding.”
30 86 Fed. Reg. 40064 (July 26, 2021).
31 HRSA, Past General Distributions, December 2021; and, HRSA, Past Targeted Distributions, November 2022.
32 HRSA, Provider Relief, June 2023.
33 For its analysis, HHS OIG reviewed payments made during the first four periods and nursing home reports on PRF use made during the
first two periods.
34 HRSA, Important Dates for Reporting. May 2023.
36
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Table 6: Timelines for Facility Receipt, Use, and Reports of PRF Payments
Reporting
Period
Payment Received Period
Deadline to Use Funds
Reporting Time Period
1
April 10, 2020, to
June 30, 2020
June 30, 2021
July 1, 2021, to
September 30, 2021a
2
July 1, 2020, to
December 31, 2020
December 31, 2021
January 1, 2022, to
March 31, 2022
3
January 1, 2021, to
June 30, 2021
June 30, 2022
July 1, 2022, to
September 30, 2022
4
July 1, 2021, to
December 31, 2021
December 31, 2022
January 1, 2023, to
March 31, 2023
5
January 1, 2022, to
June 30, 2022
June 30, 2023
July 1, 2023, to
September 30, 2023
6
July 1, 2022, to
December 31, 2022
December 31, 2023b
January 1, 2024, to
March 31, 2024
7
January 1, 2023, to
June 30, 2023
June 30, 2024b
July 1, 2024, to
September 30, 2024
Source: HRSA, Important Dates for Reporting, December 2023.
a HRSA allowed a grace period for this reporting time period, which ended on November 30, 2021.
b 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.
HRSA distributed approximately $9.4 billion in targeted PRF payments directly to nursing
homes and certified skilled nursing facilities (SNFs).35 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.36  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
for, and responding to COVID-19.37 HHS distributed the other $4.6 billion to facilities through
the Nursing Home Infection Control (NHIC) distribution, which included two types of allocations:
35 In addition to these targeted distributions, some nursing homes may have also qualified for additional funding through general and other PRF
distributions. In June 2023, HRSA reported to OIG that HHS had obligated approximately $54.7 billion total to SNFs and nursing homes across
all PRF distributions; and, HRSA, Past Targeted Distributions, November 2022.
36 HRSA, Past Targeted Distributions, November 2022; and, CMS, Medicare Coverage of Skilled Nursing Facility Care, July 2019.
37 HRSA, Acceptance of Terms and Conditions, Skilled Nursing Facility Relief Fund Payment Terms and Conditions.
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38
infection control payments to 12,787 facilities and Quality Incentive Payment (QIP) program
payments to 11,819 facilities.38 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.39
Program Impact
The five Coeur d’Alene nursing homes received both general and targeted PRF payments.
As of December 2021, the sample nursing homes had received a total of $4,572,004 from PRF
distributions. Targeted payments included $1,377,500 from the SNF distribution and $1,237,591
from NHIC distributions.
Table 7: PRF Payments to Nursing Homesa
Distribution
Total Payments Distributed to Nursing
Homes Nationally
Total Payments Distributed to the
Sample Nursing Homes
SNF
$4.8 billion
$1,377,500
NHIC
$4.6 billion
$1,237,591
OTHERb
$45.3 billionb
$1,956,913
TOTAL
$54.7 billion
$4,572,004c
Source: HRSA, Past Targeted Distributions, November 2022; HHS OIG analysis of PRF payment data.
a The total amounts distributed to nursing homes nationally through the SNF and NHIC distributions are current through September
2022. PRF payment data for HHS OIG's sample nursing homes 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's 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 facilities received an additional $98,926 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.
38 HRSA, Past Targeted Distributions, November 2022.
39 HRSA, Acceptance of Terms and Conditions, Skilled Nursing Facility and Nursing Home Infection Control Relief Fund Payment Terms and
Conditions.
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The nursing homes reported that they spent all the PRF payments they received during the first
two periods and varied in how they used the money. Corporate and facility leaders reported that
the nursing homes incurred expenses in advance, then their corporate offices allocated PRF for
eligible reimbursements. Corporate offices also reported use of the funds to HRSA.
At the time of HHS OIG’s data collection, the facilities were required only 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 homes used all the funds they received during the first
two periods. Specifically, the five nursing homes reported using $2,417,459 in total PRF payments,
including $2,066,909 in payments targeted to nursing facilities ($1,377,500 in SNF payments and
$689,409 in NHIC payments).40
Of the five nursing homes, two facilities reported using the payments for both lost revenue and
expenses, two facilities used the payments only for lost revenue, and one facility used the payments
only for expenses. HRSA required nursing homes to report the use of NHIC payments and all other
payments (including SNF payments) separately:
• Collectively, the nursing homes reported using most of their NHIC payments ($495,529) to
offset health care-related expenses, such as medical equipment and supplies. They used the
remainder of the NHIC payments ($193,881) for general and administrative expenses, such
as payroll.
• Collectively, the nursing homes reported using most of the other payments they received
($1,122,044) to cover pandemic-related lost revenue. They also used $459,052 for general
and administrative expenses and $146,953 for health care-related expenses.
Corporate leaders at the Coeur d’Alene nursing homes said HRSA’s guidance on allowable uses
and reporting requirements was sometimes unclear. One chief financial officer said: “Even when
there was clear guidance, from HRSA’s perspective, understanding what was needed was definitely
unclear. It was a struggle to figure out what we need to do, how we need to spend it, and how we
need to report.” HRSA created frequently asked questions resources to provide further guidance,
which corporate leaders said were helpful but sometimes released late or difficult to find. Despite
the challenges, corporate leaders said that the guidance was broad enough to allow flexibility to
address COVID-19-related costs and lost revenue.
Two of the five nursing homes in HHS OIG’s sample initially submitted reports incorrectly during
the first reporting period, and they did not receive payments during the second distribution
period. During the first reporting period, the corporate office for the two nursing homes incorrectly
reported that the facilities’ targeted PRF payments at the corporate level, rather than the facility
level. HRSA allowed them to resubmit the reports after the deadline passed. During the second
distribution period, the same two facilities did not receive NHIC payments like other nursing homes.
The chief financial officer stated that HRSA deemed them ineligible for such payments because the
40 These figures do not match the figures in Table 2 because the facilities were not yet required to report their use of the remaining funds of
approximately $2.15 million during the first two reporting periods.
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40
corporation was in the middle of bankruptcy proceedings. HRSA reported that it later changed its
policy so that bankruptcy was no longer a consideration when determining eligibility and paid these
facilities during subsequent payment waves.
HHS OIG reviewed documentation that generally supported that the nursing homes’ reported
use of the funds during the first two reporting periods aligned with PRF goals and objectives.
HHS OIG reviewed the reports the nursing homes made to HRSA during the first two reporting
periods, along with summary supporting documentation. HHS OIG did not audit the facilities’
financial reports or supporting documents. They observed that the information the facilities
reported to HRSA was generally supported by underlying facility data and appeared to align with
the allowable uses of the general and targeted distributions. (Documentation from one facility did
not appear to support its use of $717.50 during the first period.) Facility documentation generally
supported that the nursing homes used NHIC payments for infection control-related expenses, as
intended. Examples included facility expenses on medical equipment and 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 five nursing homes’ pandemic response, according
to corporate leaders and facility staff representing the Coeur d’Alene nursing homes. One
corporate leader noted that the payments provided “huge financial relief.” Corporate leaders for
another nursing home stated that the PRF payments helped mitigate negative effects that the
pandemic had on quality of care and described using the payments to purchase equipment such as
communication devices for residents to attend telemedicine visits and to speak with their families.
Staff in that nursing home agreed, explaining that the facility was one of the last in the area to
experience a COVID-19 case, and that the PRF payments played a “big part [in] keeping [COVID-19]
out.”
Corporate and facility leaders from all five nursing homes reported that PRF payments were
not sufficient to offset losses related to COVID-19, and that the facilities would benefit from
additional relief funding. During the first two reporting periods, these facilities reported lost
revenue and expenses related to COVID-19 that exceeded the PRF funds they received. One
corporate leader said that while they appreciated the funds, the PRF payments were significantly
less than the facility’s expenses. The facility 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
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41
HRSA and all other sources.41 The facility’s corporate leaders further stated that the nursing home
was “continuing to incur significant expenses” from its COVID-19 response that were not being
reimbursed. Despite the losses, corporate leaders from the five facilities appreciated the payments
and that the funds were distributed quickly. One nursing home administrator stated that they were
unsure how the facility would have responded to the pandemic if it had not received the funds.
FOR MORE INFORMATION
For more information about Provider Relief Fund
program spending across the country, visit the PRAC’s
website, including an interactive dashboard.
41 HRSA, User Guide: Provider Relief Fund (PRF) Reporting Portal—Reporting, p. 53.
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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
DOL
U.S. Department of Labor
DOT
U.S. Department of Transportation
ED
U.S. Department of Education
ESSER
Elementary and Secondary School Emergency Relief
FAQ
Frequently Asked Question
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
NHIC
Nursing Home Infection Control
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OIG
Office of Inspector General
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
QIP
Quality Incentive Payment
SNF
Skilled Nursing Facilities
Treasury
U.S. Department of the Treasury
UI
unemployment insurance
USDA
U.S. Department of Agriculture
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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 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 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 selected six communities across the United States: Springfield, MA; Coeur
d’Alene, ID; Sheridan County, NE; Marion County, GA; 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, eight provided funding to recipients
in Coeur d’Alene. In our review of the eight programs, we sought to identify how the recipients used
the funds and if the uses generally aligned with respective program goals and objectives. The
programs or subprograms selected for Coeur d’Alene 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
• 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
• 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
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More information about the scope and methodology for phase two of this review can be found in
our March 2024 report.
Methodology
We visited Coeur d’Alene, ID, in June 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 the program sections
below.
Standards
Each OIG and the 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, the Council of the
Inspectors General on Integrity and Efficiency’s (CIGIE) Quality Standards for Inspection and
Evaluation, and internal OIG guidance. All these standards required 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 November 2023,
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 | DOT OIG reviewed Kootenai County’s use of FTA 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 Kootenai County
—which is responsible for oversight and management of the Kootenai County Transit System based
in Coeur d’Alene, ID—spent pandemic funds in alignment with program goals and objectives and
believed that federal funding impacted its ability to respond to the pandemic. Specifically, it
examined CARES Act Urbanized Area Formula Grants Program expenditures from grant agreement
ID-2020-008-00 through September 30, 2021.
Methodology | To determine whether Kootenai County spent pandemic funds in alignment with
program goals and objectives, DOT OIG identified criteria in various sources, including the CARES
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Act, the statute pertaining to the Urbanized Area Formula Grants Program, 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, and the applicable
grant agreement.  DOT OIG also obtained the agency’s description of the purpose, goals, and
objectives for the CARES Act Urbanized Area Formula Grants Program. It conducted interviews with
Kootenai County 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. They followed up with Kootenai County officials and
collected additional documentation, as needed, to resolve any questions DOT OIG had about the
expenditures.
To determine whether Kootenai County believed that federal funding impacted its ability to respond
to the pandemic, DOT OIG drew from, and modified as appropriate, standard questions the PRAC
developed to interview appropriate Kootenai County officials and staff. The audit team analyzed the
testimonial evidence to identify any themes.
Limitations
DOT OIG did not have any significant limitations.
Data Quality | To check the completeness and integrity of the data Kootenai County officials
provided, DOT OIG verified that the amounts they reported drawing down matched the amounts
FTA reported outlaying to the transit agency. For the purposes of its effort and in the absence of
information that would suggest otherwise, DOT OIG judges the data to be reliable.
Standards
DOT OIG conducted this audit in accordance with generally accepted government auditing
standards. Those standards require that it plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for DOT OIG's findings and conclusions based
on its audit objectives. DOT OIG believes that the evidence obtained provides a reasonable basis
for its findings and conclusions based on DOT OIG’s audit objectives.
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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 2022 through April 2023. Its review
covered the city’s use of CDBG-CV funds from program inception through September 30, 2021.
Its review objectives were to determine whether the city spent CDBG-CV funds in alignment with
program goals and objectives and whether the CDBG-CV funds positively or negatively impacted the
city’s ability to respond to the pandemic.
Methodology | To accomplish HUD OIG’s review objectives, it:
• Reviewed applicable HUD requirements (Federal Register and HUD memorandum).
• Interviewed HUD and city staff to gain an understanding of the goals and objectives of the
CDBG-CV funds and to obtain feedback on the impact of the funds.
• Reviewed a sample of program expenditures and the corresponding supporting documentation
provided by the city, including applications, contracts, invoices, and canceled checks.
The review universe consisted of 31 expenditure transactions totaling $242,721 between January
21, 2021, and September 28, 2021. From this universe, HUD OIG selected a statistical sample of
22 transactions totaling $170,666 for review to determine whether the city spent CDBG-CV funds in
alignment with the program goals and objectives.
To achieve its objectives, HUD OIG relied in part on the city’s computer-processed data. Although it
did not perform a detailed assessment of the reliability of the data, HUD OIG determined that the
data were sufficiently reliable for the purposes of its review because it corroborated the data for
the sampled expenditures against supporting documentation provided by the city.
HUD OIG determined that internal controls were not relevant to its objectives. HUD OIG’s objectives
were not to evaluate or provide assurance of the city’s internal controls. Therefore, it 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 it plan and perform the review to obtain sufficient,
appropriate evidence to provide a reasonable basis for HUD OIG's findings and conclusions based
on its objective(s). HUD OIG believes the evidence obtained provides a reasonable basis for its
conclusions based on HUD OIG's objectives.
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Coronavirus Relief Fund | U.S. Department of the Treasury,
Office of Inspector General
Objectives/Scope/Methodology
Treasury OIG’s objectives were to determine whether subrecipients located in Coeur d’Alene, ID, (1)
used CRF proceeds in alignment with program goals and objectives, and (2) believed that CRF
funding impacted (positively or negatively) their ability to respond to the pandemic.
The scope of Treasury OIG's engagement covered CRF expenditures reported in GrantSolutions from
March 1, 2020 (cycle 1) through March 31, 2022 (cycle 8). Treasury OIG selected five subrecipients
out of 19 for the review: (1) city of Coeur d’Alene, (2) Coeur d’Alene Public School System, (3) a
medical center, (4) a short-term nursing and rehabilitation facility, and (5) a medical coding
company. Its sample included testing of a total of $14.72 million out of $16.81 million (10
transactions, or approximately 88 percent) in CRF award funds, representing all payment types,42 to
determine whether they used the CRF funds in alignment with the program’s goals and objectives.
To accomplish these objectives, Treasury OIG performed the following activities during engagement
fieldwork conducted from June through November 2022:
• Reviewed Title VI of the Social Security Act, as amended by Title V of Division A of the
Coronavirus Aid, Relief, and Economic Security Act (CARES) Act.43
• Reviewed the Consolidated Appropriations Act, 2021.44
• Reviewed the state and subrecipient policies and procedures for determining CRF eligible use.
• Interviewed subrecipient officials regarding CRF usage, experience, and impact.
• Reviewed the state and subrecipients’ Single Audit Reports for fiscal years 2020 and 2021 to
assess findings that may pose risk to the subrecipients’ uses of CRF.
• Reviewed media reports associated with the COVID-19 pandemic and CRF impacts within
Coeur d’Alene.
• Reviewed supporting documentation to determine if the 10 sample transactions were
(1) necessary expenditures incurred due to the public health emergency with respect to
COVID-19; (2) not accounted for in the budget most recently approved as of March 27, 2020;
and (3) 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 state and subrecipient accounting systems.
42 Direct Payments, Transfers, and Grants.
43 P. L. 116-136 (March 27, 2020).
44 P. L. 116-260 (December 27, 2020).
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49
Standards
Treasury OIG conducted this engagement in accordance with the Quality Standards for Inspection
and Evaluation issued by CIGIE.
Elementary and Secondary School Emergency Relief
Program | Pandemic Response Accountability Committee
and U.S. Department of Education, Office of Inspector General
Methodology
Scope | The PRAC and ED OIG’s review covered Coeur d’Alene Public School’s use of Elementary
and Secondary School Emergency Relief (ESSER) funds (three rounds of funding) from program
inception through September 30, 2021. Our review 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. The PRAC coordinated this work with the ED OIG.
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 Coeur d’Alene Public Schools.
• Determined if the descriptions of the funding uses aligned with ESSER’s objectives of helping
Coeur d’Alene Public Schools prevent, prepare for, and respond to coronavirus, domestically or
internationally.
• Interviewed Coeur d’Alene Public Schools officials, City of Coeur d’Alene officials, and Idaho
Department of Elementary and Secondary Education officials about uses of funds as well as
the effects the ESSER funds had on Coeur d’Alene’s ability to respond to the pandemic.
Standards
We conducted this study in accordance with the Quality Standards for Inspection and Evaluation
issued by CIGIE.
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50
Farmers to Families Food Box Program | Pandemic
Response Accountability Committee and U.S. Department
of Agriculture, Office of Inspector General
Methodology
Scope | The PRAC and USDA OIG’s review covered the use and impact of the Farmers to Families
Food Boxes implemented by USDA. 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 Coeur d’Alene. Our review
objective was to determine whether the program served producers, distributors, and food recipient
organizations in accordance with program goals and objectives.
Methodology | To try to determine if the program served producers, distributors, and food recipient
organizations in accordance with program goals and objectives in the Coeur d'Alene community, we:
• Reviewed multiple federal reports evaluating the Food Box program.
• Obtained and reviewed data showing the number of food boxes sent to Food Recipient
organizations serving the Coeur d’Alene, ID, community.
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 part one of this case-study-based review.
Part 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.
Standards
We conducted this study in accordance with CIGIE’s Quality Standards for Inspection and
Evaluation.
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51
Pandemic Unemployment Insurance | U.S. Department of
Labor, Office of Inspector General
Methodology
Scope | The evaluation covered the DOL’s UI response to the COVID-19 pandemic. Specifically, the
federal UI benefits from the following three key CARES Act UI programs were reviewed: FPUC, PUA,
and 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 ARP Act until September
6, 2021. Three states ended the expanded UI programs early. Specifically, Nebraska and Idaho
ended their programs on June 19, 2021, and Georgia on June 26, 2021. DOL OIG’s 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, American Rescue Plan Act of 2021, ETA guidance,
Federal Emergency Management Agency guidance, state agreements, 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, DOL OIG judgmentally selected 60 claimants with whom DOL OIG investigators
performed on-site interviews (see Table 1).45 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.
Data Limitations
Since the claimants were judgmentally selected, DOL OIG cannot project the results of its audit
to larger populations, such as statewide or nationally. This limitation is acceptable based on the
objective of this evaluation.
45 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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52
Standards
DOL OIG conducted this study in accordance with CIGIE’s Quality Standards for Inspection and
Evaluation.
Project-Based Rental Assistance - 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. Its review
covered the use of PBRA CARES Act funds by a sample of multifamily rental housing properties in
Coeur d’Alene, ID, from program inception through September 30, 2021. Its 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 HUD OIG’s review objectives, it:
• Reviewed applicable HUD requirements (HUD memorandums 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 12 funding awards made to five properties in Coeur d’Alene
totaling $163,819. From this universe, HUD OIG selected for review the two properties that received
only an automatic allocation of PBRA CARES Act funds totaling $77,750. HUD OIG also selected for
review the remaining three properties, which received both an automatic allocation of PBRA CARES
Act and CSP funds totaling $86,069, to determine whether the funds were spent in alignment with
the program goals and objectives.
To achieve its objectives, HUD OIG relied in part on HUD’s computer-processed data. Although HUD
OIG did not perform a detailed assessment of the reliability of the data, it determined that the
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53
data were sufficiently reliable for the purposes of HUD OIG's review because it corroborated the
funding award data for the sampled properties with supporting documentation provided by HUD
and the multifamily properties.
HUD OIG determined that internal controls were not relevant to their objectives. Its objectives were
not to evaluate or provide assurance of the multifamily properties’ internal controls. Therefore, HUD
OIG did not assess the multifamily properties’ 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 it plan and perform the review to obtain sufficient,
appropriate evidence to provide a reasonable basis for its findings and conclusions based on
its objective(s). HUD OIG believes the evidence obtained provides a reasonable basis for its
conclusions based on HUD OIG's objectives.
Provider Relief Fund Payments to Nursing Homes |
U.S. Department of Health and Human Services,
Office of Inspector General
Scope
HHS OIG examined the use of targeted PRF payments to five nursing homes in Coeur d’Alene, ID,
during calendar years 2020 and 2021. The selected facilities received direct PRF payments through
distributions that HHS targeted for nursing homes and certified SNFs.46 HHS OIG conducted its data
collection concurrently with the PRAC’s site visit to Coeur d’Alene during June and July 2022 as part
of its larger contributions to the PRAC study on the impact of federal pandemic relief spending in six
select locations. HHS OIG used interviews, documentation, and data analysis to identify how the
nursing homes used the PRF payments and whether they experienced any challenges using these
funds. Through its review, HHS OIG 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 facilities complied with terms and conditions related to PRF
use.
46 To determine the sample of nursing homes, HHS OIG 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 Coeur d’Alene provided by the PRAC. HHS OIG
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.
Pandemic Response Accountability Committee

Methodology
Data Sources
Interviews
To evaluate the nursing homes’ use of PRF payments, HHS OIG interviewed leadership, staff,
and a small number of residents from the selected facilities. HHS OIG also conducted two group
interviews with HRSA officials who were responsible for administering and overseeing the payments.
HHS OIG employed adaptable interview protocols that allowed it to modify questions, as needed,
and follow up on additional issues as it learned new information and identified key issues.
Nursing Home Interviews | HHS OIG conducted group interviews with corporate and facility
leaders and staff in each selected nursing home. Participants included corporate executives,
facility leadership, and a small number of clinical and nonclinical staff. HHS OIG also conducted
small group interviews with residents at four of the five facilities as a way of gathering additional
insights and illustrations about facility services and resident perceptions about the effects of the
funding. The remaining facility accepts residents only for short stays and therefore had no residents
available who would have been at the facility at the time it received PRF payments.
During these interviews, HHS OIG discussed how the nursing homes used the PRF payments and
their experiences in using the funds and reporting the information to HRSA. HHS OIG discussed
facility leadership and staff perceptions of how the payments helped the facilities prevent, prepare
for, and respond to COVID-19, and challenges that hindered their use of the funds. Additionally,
HHS OIG discussed nursing home interactions with HRSA officials related to PRF use and oversight,
and any additional assistance from HRSA that the facilities reported would have been useful.
Although its 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 facilities
received.
HRSA Interviews | HHS OIG conducted a few group interviews with PRF program administrators in
HRSA‘s Provider Relief Bureau. The interviews gathered more detailed information about PRF goals
and performance metrics. HHS OIG 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.
Document Review
HHS OIG collected available funding receipt attestations and reports to HRSA about how the nursing
homes 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 in May 2022. The Division of Data Analytics
also provided updated documents for two facilities on June 16, 2022. At that time, only two of four
required reporting periods had passed, so the facilities had not yet reported on their use of all PRF
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Pandemic Response Accountability Committee

payments. They had, however, reported on most of the payments they received through the targeted
distributions to nursing homes and certified SNFs. HHS OIG also requested and reviewed summary
documentation from the facilities supporting expenses and lost revenue outlined in those reports.
Additionally, HHS OIG requested any correspondence between HRSA officials and the facilities 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 facilities.
Data
To summarize the PRF payments the nursing homes received and kept, HHS OIG reviewed PRF
payment data from HRSA for the selected facilities, which its Division of Data Analytics accessed
directly through its data use agreement with HRSA. HHS OIG 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 HHS OIG's timeframe of calendar years 2020 and 2021 (the first four distribution periods)
and were collected in time for it to conduct an initial analysis prior to the site visits.
Data Analysis
HHS OIG conducted a qualitative analysis of interview data and documentation from the nursing
homes and HRSA. HHS OIG used its analysis to gain a deeper understanding of PRF program
strengths and weaknesses from the perspective of the nursing homes. This analysis also helped
HHS OIG to determine how the selected nursing homes used targeted payments to improve
infection control and address health care expenses and lost revenue related to the pandemic.
HHS OIG conducted a quantitative review of PRF payment data and the nursing homes’ financial
documentation. HHS OIG used its analysis of the data to briefly summarize the types and amounts
of PRF payments each facility received and how the funds were used.
Limitations
HHS OIG focused only on the experiences of the selected nursing homes. Its findings cannot be
extrapolated to all nursing homes that received PRF payments.
Although HHS OIG compared the nursing homes’ reports to HRSA against supporting
documentation and PRF terms and conditions to assess appropriateness, it did not conduct an
audit of the facilities’ financial documentation to verify their reports and supporting material.
Standards
HHS OIG conducted this study in accordance with CIGIE’s Quality Standards for Inspection and
Evaluation.
55
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
Follow us at:
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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