A Review of Pandemic Relief Funding and How It Was Used in Six U.S. Communities Sheridan County, Nebraska
- Document type
- Report
- Date
- 2024-09-26
Summary
A September 2024 report by the Pandemic Response Accountability Committee, the third in a series on how six communities used federal pandemic funding, focusing on Sheridan County, Nebraska. The report states that Sheridan County recipients received more than $61 million from 31 federal pandemic relief programs and subprograms, and it examines six: the Coronavirus Relief Fund, the Elementary and Secondary School Emergency Relief Program, the Farmers to Families Food Box Program, pandemic unemployment insurance programs, the Public Housing Operating Fund and Provider Relief Fund payments to nursing homes. It reports, for example, that a minority resource center received $147,732 in CRF funds and that three nursing homes received $4,961,682 from the Provider Relief Fund. Appendices set out acronyms and the scope and methodology.
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Full text
A Review of Pandemic Relief Funding
and How It Was Used in Six U.S.
Communities
Sheridan County, Nebraska
September 2024
City of Springfield, Massachusetts
City of Coeur d’Alene, Idaho
Sheridan County, Nebraska
Marion County, Georgia
White Earth Nation Reservation in Minnesota
Jicarilla Apache Nation Reservation in New Mexico
PANDEMIC RESPONSE
ACCOUNTABILITY COMMITTEE
CONTENTS
Taking a Closer Look at a Community’s Experience: Sheridan County, NE..................................... 1
Coronavirus Relief Fund...................................................................................................................... 4
Elementary and Secondary School Emergency Relief Program....................................................... 7
Farmers to Families Food Box Program ...........................................................................................13
Pandemic Unemployment Insurance Programs.............................................................................. 16
Public Housing Operating Fund – CARES Act .................................................................................. 24
Provider Relief Fund Payments to Nursing Homes ......................................................................... 27
Appendix A: Acronyms .......................................................................................................................35
Appendix B: Scope and Methodology .............................................................................................. 37
Scope ............................................................................................................................................. 37
Methodology ..................................................................................................................................38
Standards ......................................................................................................................................38
Coronavirus Relief Fund................................................................................................................38
Elementary and Secondary School Emergency Relief Program ................................................40
Farmers to Families Food Box Program ....................................................................................... 41
Pandemic Unemployment Insurance ...........................................................................................42
Public Housing Operating Fund – CARES Act ..............................................................................43
Provider Relief Fund Payments to Nursing Homes .....................................................................44
Pandemic Response Accountability Committee ii
Taking a Closer Look at a
Community’s Experience:
SHERIDAN COUNTY, NEBRASKA
This report is the third 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
Sheridan County, NE, with a detailed look
at six of the 31 pandemic programs that
provided funding to the community. For
more information about our review, see
Appendix B.
Sheridan County is the fourth largest
county in Nebraska by landmass covering
2,441 square miles; however, it ranks
55 in terms of population with only
4,996 inhabitants. From March 1, 2020,
through February 28, 2023, the county
experienced 1,189 recorded cases of
COVID-19 and 41 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 Sheridan County, NE, recipients,
including local governments, small
businesses, and individuals, received more
than $61 million from 31 federal pandemic
relief programs and subprograms during
the first 18 months of the pandemic. This
report provides a closer look at six of a
U.S. Census Bureau data for counties and cities.
these federal pandemic programs from six 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 data based on the rate of individuals
who received at least two doses of the vaccine. The vaccination rate represents the
countywide rate. Data as of May 30, 2023.
d
Data was obtained from the Panhandle Public Health District and represents cases 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.
federal agencies and the funding they provided to
Sheridan County. These programs aimed to respond
to and mitigate the effects of the pandemic by
Programs Selected for
addressing community development needs that Further Review
posed a serious threat to the health or welfare of Coronavirus Relief Fund
the community, supporting public transportation
U.S. Department of the Treasury
agencies, developing learning loss remediation
programs for local schools, and other efforts. We Elementary and Secondary School
sought to gain deeper insights into how Sheridan Emergency Relief Program
County used its pandemic relief funding, how the U.S. Department of Education
spending aligned with the goals and objectives
of the federal relief programs, and whether the Farmers to Families Food Box Program
funding assisted Sheridan County residents in U.S. Department of Agriculture
responding to the pandemic.
Pandemic Unemployment
Insurance Programs
Pandemic Impact on U.S. Department of Labor
the Community Public Housing Operating Fund
– CARES Act
According to residents and local officials, the U.S. Department of Housing and Urban
pandemic impacted multiple aspects of life in Development
Sheridan County. For example, though the average
unemployment rate in Sheridan County stood at 2.3 Provider Relief Fund Payments
percent in 2020, the county experienced a peak to Nursing Homes
unemployment rate of 4.2 percent in March 2020. U.S. Department of Health and Human Services
To help address unemployment, Sheridan County
residents received more than $285,000 in federal
benefits from pandemic-related unemployment
insurance (UI) programs.
Local officials also highlighted an unusual element of Sheridan County’s experience in that the
community did not truly feel the effects of the pandemic until months after the nationwide public
health emergency was declared. Specifically, Sheridan County experienced its first confirmed case
of COVID-19 on June 27, 2020, almost three months into the pandemic. During our site visit in
August 2022, officials and individuals we spoke to explained that although they felt the effects
of the pandemic starting in 2020, they felt them more in 2022. Consequently, their challenges
centered on supply chain issues, inflation, and a housing shortage. For example, one official told
us the local volunteer fire department had been waiting eight months for a shipment of boots they
had ordered. Farmers and ranchers in the county also experienced similar supply chain issues with
specialized equipment. Other officials at a local nonprofit organization shared that they encountered
a shortage of diapers in their community, which impacted their ability to supply such critical
childcare supplies to families in need.
Pandemic Response Accountability Committee 2
Program Impact on the Community
Officials whom 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. The Sheridan County community told our teams they
appreciated the federal government’s emergency assistance and that it helped with immediate
responses to the pandemic. A sample of the responses:
• A minority resource center in Sheridan County received $147,732 from the U.S. Department
of the Treasury’s (Treasury) Coronavirus Relief Fund (CRF) and primarily used the funds to
provide economic support programs for food, utility, and rental assistance to Native American
populations located within and around the county.
• Public Housing Agencies received $13,972 from the U.S. Department of Housing and Urban
Development’s (HUD) Public Housing Operating Fund to purchase personal protective
equipment (PPE) supplies such as masks, thermometers, and shields for their offices. They
also used the funds to pay salaries for their maintenance staff and to pay for accounting
services.
• Three nursing homes within Sheridan County received $4,961,682 from the Provider Relief
Fund (PRF) and reported using the funds to cover administrative and health care-related
expenses as well as lost revenue.
Participant Experience
During our visit in August 2022, we received feedback from multiple officials whose offices or
organizations received federal funding. They shared their experiences with federal programs as they
responded to the pandemic within Sheridan County and highlighted the challenges and successes.
For example:
• Gordon-Rushville Public School District officials said that teacher loss would have been much
greater without Elementary and Secondary School Emergency Relief (ESSER) funding. The
officials also said the funding allowed them to make upgrades such as new technology for
remote work and facility improvements, which made the teachers feel more valued.
• Staff at a local nonprofit organization stated they had a positive experience with the Farmers
to Families Food Box Program (Food Box Program). They also said they used the food deliveries
to distribute PPE and public health information to recipients.
• Most surveyed claimants for the UI programs expressed either satisfaction or extreme
satisfaction with the application process, the overall process of filing a claim, and the
promptness of receiving benefits..
Pandemic Response Accountability Committee 3
PROGRAM SNAPSHOT
Coronavirus Relief Fund
U.S. Department of the Treasury
The Panhandle Public Health District (PPHD) is a health department in Nebraska servicing 12
counties, including Sheridan County. From March 2 to April 16, 2020, PPHD reported 33 positive
COVID-19 cases, which increased to 4,644 cases by November 16, 2020. Through January 4, 2021,
PPHD confirmed 7,740 cases.1 The City of Gordon, located in Sheridan County, was forced to close
its office to the public. However, staff continued
working at the office, and conducted business
through phone calls, a payment drop box, and
online platforms. City staff adapted safety protocols
PANHANDLE PUBLIC HEALTH
to prevent the spread of COVID-19 by adjusting DISTRICT
work schedules to maintain social distancing, From March 2 to April 16, 2020, the health
limiting work vehicle occupancy to one person, and department reported 33 positive COVID 19 cases,
wearing masks. The city initially faced challenges in which increased to 7,740 cases by January 4, 2021.
getting masks and other PPE. For example, it took
PPHD two to three months into the pandemic to
provide PPE, such as gloves and masks, to the city.
In the fall of 2020, the Nebraska Department of Labor conducted studies to measure impacts of
the COVID-19 pandemic on businesses and the labor force statewide.2 Results were collected from
1,263 business establishments and 1,488 households across the state. According to the studies,
more than 85 percent of businesses reported being significantly impacted by the pandemic. More
than one in six business establishments reported temporary layoffs, and more than a quarter
of businesses reported making changes to the services or products they offered in response to
pandemic-related disruptions. More than 70 percent of employers reported a job that was difficult
to fill, and more than half reported a job that had historically been difficult to hire had become more
so since the onset of the pandemic.
1 PPHD Press Releases on April 16, 2020, November 16, 2020, and January 4, 2021, http://www.pphd.ne.gov/Pages/newsroom.htm.
2 Statewide COVID Impacts and Teleworking Report, September 2021
Pandemic Response Accountability Committee 4
Program Information
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) established the CRF and
appropriated $150 billion for 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 payments to 964 prime
recipients, which subsequently issued CRF payments to 89,969 subrecipients and beneficiaries
through contracts, grants, loans, direct payments, or fund transfers.4 CRF payments 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,
CRF could be used to address medical or public health needs, acquire PPE, provide small business
assistance, facilitate distance learning, and provide economic support to those suffering from
employment or business interruptions and closures.
The CARES Act required CRF recipients to use the funds to cover expenses that were (1) necessary
expenditures incurred due to the public health emergency with respect to the COVID-19 pandemic;
(2) 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).5 Prime
recipients are responsible for reporting CRF expenditures on a quarterly basis during the covered
period in GrantSolutions.6
As a prime recipient, the state of Nebraska’s responsibilities included, but were not limited
to, providing guidance to subrecipients, reiterating federal requirements, and reviewing
subrecipients’ expenditure reports to assess compliance with CRF eligible use requirements.
Nebraska’s Department of Health and Human Services (Nebraska HHS) also provided reminders
to subrecipients regarding records retention during technical assistance calls and meetings.
Nebraska’s HHS relied on subrecipient applications to determine whether proposed expenditures
were necessary due to COVID-19. Additionally, PPHD provided information on its website including
a COVID-19 risk level, and information on patient hospitalizations, hospital bed availability, and
vaccine availability.
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. The U.S. territories are as
follows: United States Virgin Islands, Guam, American Samoa, Puerto Rico, and Commonwealth of the Northern Mariana Islands.
4 A subrecipient is an entity that received CRF payments from a prime recipient that received a CRF award directly from Treasury. Subrecipients
assist with carrying out the CRF program. Subrecipients can also include recipients of transfers from a prime recipient that is a state, territory,
local government, or Tribal government. Individuals and organizations (e.g., businesses, nonprofits, or educational institutions) that directly
benefit from an assistance program established using payments from CRF are not considered subrecipients but are considered beneficiaries.
Treasury OIG requires that the prime recipient report on expenditures made by subrecipients, as well as payments made to beneficiaries in the
GrantSolutions reporting system (see footnote 7 for definition of the grant reporting system).
5 The Consolidated Appropriation Act, 2021, P.L. 116-260 (December 27, 2020), amended the CARES Act by extending the covered period for
recipients of CRF payments to use proceeds through December 31, 2021. The period of performance end date for Tribal entities was further
extended to December 31, 2022, by the State, Local, Tribal, and Territorial Fiscal Recovery, Infrastructure, and Disaster Relief Flexibility Act,
Division LL of the Consolidated Appropriations Act, 2023, P.L. 117-328, (December 29, 2022), 136 Stat. 4459.
6 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.
Pandemic Response Accountability Committee 5
Program Impact on the Community
As of June 30, 2022, Treasury disbursed $1.08 billion in CRF to the State of Nebraska, which
awarded $147,732 to one subrecipient located within Sheridan County, a minority resource
center (the Center), via a grant. Sheridan County did not receive CRF award funds directly from
Treasury or from Nebraska. As such, Sheridan County is not a prime recipient or subrecipient
of CRF. As of June 30, 2022, the Center spent all the CRF award funds it received to continue
operations and provide economic support for local communities impacted by the pandemic.
Treasury OIG tested $76,424 (52 percent) of CRF expenditures to determine whether the Center
used the funds in alignment with the program’s goals and objectives.
The minority resource center primarily provided economic support programs to Native American
populations located within and around the county. For example, the Center distributed financial
relief payments to eligible members to assist with food, utilities, and rental payments. Additionally,
the grant provided resources to charitable organizations and licensed childcare providers to assist
impacted families with children. The Center expanded its community health and educational
outreach programs to areas not within its traditional service area based on an assessment of
community needs. The selected CRF expenditures tested complied with the CARES Act and Treasury
guidance and were used in alignment with the program’s goals and objectives of preventing
and mitigating the impacts from the COVID-19 public health emergency. As a result, the overall
assessment of risk for ineligible use of CRF is low.
Participant Experience
Satisfaction
The minority resource center officials expressed overall satisfaction with Treasury’s CRF
allocation amounts, federal and state guidance, and the ability to use CRF award funds. They
emphasized that the amount received was generous, timely, and beneficial to responding to the
impacts of COVID-19 throughout the county and surrounding areas. The officials also explained
that Nebraska HHS held meetings and webinars to disseminate CRF guidance to state and
county agencies.
Challenges
The minority resource center officials experienced delays and uncertainty regarding the
disbursement of CRF award funds. The Center received three CRF disbursements; however, officials
explained there was no distribution timeline on when the funding would be disbursed. Additionally,
the Center officials explained there were unmet needs,
such as rental assistance, when funding ran out; having
FOR MORE INFORMATION additional funding would have enabled them to provide
For more information about Coronavirus further support to vulnerable citizens.
Relief Fund program spending across
the country, visit the PRAC’s website,
including an interactive dashboard.
Pandemic Response Accountability Committee 6
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 a different round 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 education agencies, which then
provided funds to local education agencies (i.e., local school districts).8
• ESSER I: The first round of ESSER funding came from the CARES Act, and provided $13.23
billion to prevent, prepare for, and respond to the coronavirus, domestically or internationally.
ESSER I funds could be used to address the impact that the COVID-19 pandemic had on
elementary and secondary schools across the country. ESSER I funds were intended to
help schools safely reopen, sustain safe operation, and address the pandemic’s impact on
students.
• ESSER II: A second round of ESSER funding came from the Coronavirus Response and Relief
Supplemental Appropriations Act of 2021 and provided $54.31 billion. ESSER II funds were to
be used for the same purposes as ESSER I funds.
• ESSER III: A third round of ESSER funding came from the American Rescue Plan Act of 2021
(ARP Act) and provided $121.97 billion. At least 20 percent of local education agencies’
ESSER III funds must be used to address the academic impact of lost instructional time (i.e.,
learning loss). The remaining funds may be used for the same purposes as ESSER I and
ESSER II funds. For ESSER III, each local education agency was also required to submit a plan
to the state education agency “within a reasonable timeline determined by the state education
agency” on the use of the funds, how it would engage and consult with stakeholders when
developing its plan, and how it intended to make the plan publicly available. Each local
education agency was also required to develop a plan for the safe return to in-person
instruction and continuity of services.
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 Department of Education’s Elementary and
Secondary School Emergency Relief Programs and Governor’s Emergency Education Relief Programs, Frequently Asked Questions, December
7, 2022, Update. See questions A-8 through A-12.
Pandemic Response Accountability Committee 7
During phase one of this review, we found that the two school districts within the boundaries of
Sheridan County (Gordon-Rushville Public Schools and Hay Springs Public Schools) were awarded
about $2.4 million in ESSER funds. As of September 30, 2021, these school districts had spent
$180,649 in ESSER I funds, and they 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 Sheridan County, NE, schools.
Table 1: Sheridan County, NE, Schools ESSER Funding Information, as of September 30, 2021
Total Awarded Total Spenta Expiration Date
ESSER I $180,649 $180,649 9/30/2022
Gordon-Rushville Public
$158,261 $158,261
Schools
Hay Springs Public
$22,388 $22,388
Schools
ESSER II $688,336 $0 9/30/2023
Gordon-Rushville Public
$603,029 $0
Schools
Hay Springs Public
$85,307 $0
Schools
ESSER III $1,546,040 $0 9/30/2024
Gordon-Rushville Public
$191,722 $0
Schools
Hay Springs Public
$1,354,318 $0
Schools
Total ESSER $2,415,025 $180,649 -
a Total Spent reflects the total amount of funding expended by the local education agencies for which the state education agency
has issued a reimbursement.
Program Information
Gordon-Rushville Public School District GORDON-RUSHVILLE PUBLIC
SCHOOLS OPERATING STATUS
Gordon-Rushville Public School District had
an enrollment of almost 600 students and End of 2020 School Year
consisted of four schools: two elementary schools Fully remote learning.
(kindergarten to grade 5), a middle school (grades
2020–2021 School Year
6 to 8), and a high school (grades 9 to 12). The
district had approximately 60 teachers. The elected Fully open.
school board selects the district’s superintendent.
Pandemic Response Accountability Committee 8
Staff from the Gordon-Rushville Public School District stated that the district spent ESSER I funds
to purchase technology to assist with remote work, to support cleaning and disinfection, and to pay
paraprofessional staff. Staff added that the district spent most of these funds on the information
technology (IT) supplies and other IT components that enabled remote work. See Table 2 for more
information about the ESSER I funding categories for Gordon-Rushville Public School District.
Table 2: Spending Categories for Gordon-Rushville Public School District for ESSER I,
as of September 30, 2021
Description ESSER I Total Spent
Information Technology Supplies and other IT components $140,964
Cleaning Supplies $7,280
PPE and Schools Modifications for Social Distancing and Safety $10,017
Total $158,261
Source: PRAC Analysis of Nebraska ED Data.
During our site visit in August 2022, district officials stated that they had spent all their ESSER I
funds and received reimbursement for 75 percent of their ESSER II expenditures. They reported
that they used ESSER II funds to further improve the district’s technology infrastructure, purchase a
new bus, and conduct facility upgrades.
We also reviewed Gordon-Rushville’s ESSER III plan—required by ED. Under ESSER III requirements,
at least 20 percent of the funds must be spent on mitigating the academic impacts of learning loss.
The Gordon-Rushville ESSER III plan stated that learning loss would be addressed through:
• Purchasing a new reading series for kindergarten through 8th grade.
• Increasing summer school and after school offerings.
• Contracting with more mental health providers.
Other uses listed in Gordon-Rushville’s plan included:
• Updating student and staff devices (i.e., computers) and continuing to implement ways to
improve remote learning and student access to information.
• Improving the high school cafeteria’s air quality to allow for student social distancing, reducing
the virus transmission risk, and other environmental health hazards.
• Upgrading the elementary school’s fire suppression system, including asbestos removal.
Pandemic Response Accountability Committee 9
Hay Springs Public School District
Hay Springs Public School District had an HAY SPRINGS PUBLIC
enrollment of approximately 200 students and SCHOOLS OPERATING STATUS
consisted of four schools: a pre-kindergarten
school, an elementary school (kindergarten to End of 2020 School Year
grade 5), a middle school (grades 6 to 8), and Fully remote learning.
a high school (grades 9 to 12). The district had
about 30 staff, including approximately 20 2020–2021 School Year
teachers. The elected school board selects the Fully open.
district’s superintendent.
A Hay Springs Public School District official told us that the district used ESSER I funds to support
and pay custodial staff. According to data from the State of Nebraska Department of Education
(Nebraska ED), as of September 30, 2021, the district had spent all its $22,388 in ESSER I funds
on custodial salaries and benefits. District officials explained that they used their ESSER II funds to
improve information technology infrastructure, perform facility upgrades, and improve the schools’
kitchens and food safety.
We also spoke to district officials about their overall response to the pandemic and their future
needs and reviewed their required ESSER III plan. As noted above, under ESSER III requirements,
at least 20 percent of those funds must be spent on learning loss. According to the Hay Springs
ESSER III plan, the district intended to conduct a data evaluation and needs assessment to help
identify the most effective, high-quality instructional materials to purchase for the schools’ needs.
The district also planned to address learning loss through curriculum revision, interventions, and
the use of related technology to implement the programs. Furthermore, the district planned to use
teacher observation, test scores, and its performance metrics to help decide how to respond to
learning loss created by the pandemic.
As part of its response efforts, the district also hired additional staff to increase the amount of
personalized instruction provided to students during the 2020–2021 school year. As a result,
according to district officials, they were able to mitigate learning loss and meet a performance
milestone of 85 percent of students scoring proficient on standardized tests within the same
school year.
Participant Experience
Officials from both the Gordon-Rushville and Hay Springs school districts told us that ESSER funds
were sufficient to meet the districts’ needs in relation to the ESSER program’s stated purposes.
Both school districts’ officials provided positive feedback on ESSER III guidance, noting that the
guidance could be understood more easily and that it made the process of spending the funds
simpler than the earlier rounds of ESSER.
Pandemic Response Accountability Committee 10
Gordon-Rushville Public School District
Gordon-Rushville Public School District officials said that the district would have survived without
the ESSER funding, but the funding did greatly improve their situation. They also explained the
changing nature of the pandemic made it more difficult to determine how to spend their ESSER
funding. Officials further expressed that if the districts had known in advance how much funding
they would receive—rather than getting additional funding in rounds—then they could have better
planned how to use their ESSER funding. In addition, district officials believed that the loss of
teachers would have been much greater without the ESSER funding and that teachers would have
faced more difficult circumstances. They also said that upgrades they implemented with funding
made teachers feel more valued.
Hay Springs Public School District
Hay Springs Public School District officials provided positive feedback on Nebraska ED efforts
to ensure schools spent ESSER funds appropriately and effectively. The officials explained that
the CDC guidelines for schools and childcare programs created more challenges because the
guidelines were not specifically developed for rural schools. One official highlighted the need for
CDC guidelines more applicable to their rural context. He added that the changing CDC guidelines
over the course of the pandemic made it extremely difficult for the district to make and enforce
school policies. The official also said he believed the impact of school closures on children
was not fully considered. Moreover, he believed that Sheridan County school closures caused
students trauma.
Nebraska Department of Education
As part of our review, we spoke with Nebraska ED officials who were responsible for administering
the state’s ESSER funds. The officials said the Commissioner of Nebraska ED held weekly meetings
with local school districts to share ESSER information. State officials commented that information
provided by the federal government about program funding availability, guidelines, and permissible
uses could sometimes be unclear, though they added that they did not fault the federal government
for this given the need to quickly administer information in a rapidly changing environment due
to the nature of the pandemic. They added the federal government sometimes issued further
guidance “after-the-fact” that changed what the state had previously told school districts. One
state official noted these changes created frustration within the local schools. The state official
also explained there was little the state education agency could do because it was responsible for
following the federal guidance issued.
When we asked officials about the adequacy of the ESSER funds in helping the school districts,
one state official said some districts did not know how to spend all their respective funds, while
other districts requested more money. This state official further explained that based upon their
experience during the pandemic, the federal government’s process used to distribute ESSER
funding could have been better in providing each school district what it needed.
Pandemic Response Accountability Committee 11
Nebraska ED officials told us that although they received a lot of federal guidance about allowable
costs under ESSER funding, they never had a clear understanding of what costs tied to COVID-19
means.9 Absent this explanation, officials said the department advised districts to use common
sense in determining whether an incurred cost responded to COVID-19 and therefore could be
reimbursed through ESSER funding. Using this test, Nebraska ED did not approve all proposed
expenditures due to disagreements among county officials about whether they were tied to
COVID-19.
SPOTLIGHT ON | FEEDING STUDENTS DURING THE PANDEMIC
While schools across the nation closed, students continued to have nutritional needs during the
day. In response, 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
Officials from both school districts said student meal programs continued during the pandemic. A
Hay Springs district official stated that grab-and-go meals were provided at the school for pick-up.
Gordon-Rushville district officials stated that they provided students takeout meals and expanded
the program into the summer, weekends, and for people 21 and under.
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.
9 A U.S. Department of Education official told us they provided guidance in December 2021 on what costs tied to COVID-19 meant.
Pandemic Response Accountability Committee 12
PROGRAM SNAPSHOT
Farmers to Families Food
Box Program
U.S. Department of Agriculture
At the onset of the COVID-19 pandemic, many restaurants, hotels, schools, and other food service
entities were forced to close or scale back operations 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, as well as reports
of produce rotting in fields, the U.S. Department of Agriculture (USDA) established the 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, which in turn
would distribute the boxes to families and individuals in need.10 USDA contracted directly with
the distributors to administer five rounds of the Food Box Program. According to USDA, this
program delivered approximately 176 million food boxes worth $5.47 billion to nonprofit
and governmental organizations from May 2020 to May 2021. See Figure 1 below for more
information about the Food Box Program’s goals.
Figure 1: Three Primary Goals of the Food Box Program
Providing an alternative outlet Helping Food Distributors Providing food to families in
for domestic Food Producers that supply and distribute need by delivering food boxes to
(e.g., farmers) faced with food to retain jobs that could governmental and nonprofit Food
declining demand because of be lost because of food Recipient Organizations which
food service entities closures. service entities closures. gave the food to families.
Source: GAO, USDA Food Box Program: Key Information and Opportunities to Better Assess Performance, GAO-21-353, September 2021
10 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 milk were available in rounds 3, 4, & 5.
Pandemic Response Accountability Committee 13
Program Impact on the Community
To perform our work, the PRAC team used data previously collected and analyzed by USDA OIG in
in the PRAC’s July 2023, 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. However, USDA OIG
estimated that food distributors delivered 2,464 boxes food boxes (valued at $69,633) to one
recipient organization to feed families in the Sheridan County community.11 During our site visit in
August 2022, we spoke to this organization, which stated it distributed all the food boxes within a
few hours through a “pick-up event.”
Under the program structure USDA established, the distributors were required to provide USDA
with an invoice detailing the number, type, and cost of food boxes delivered, including high-level
information about the nonprofit and governmental organizations that received the boxes. However,
these program reporting requirements did not provide USDA with information about which food
producers (i.e., farmers) the program helped, how many food boxes went to how many families, or
consistent information about which organizations received food boxes for distribution. Given this
reporting structure, it is possible that Sheridan County residents could have received a higher or
lower number of boxes than USDA OIG’s estimate—for example, another organization not identified
in the data could have received and distributed boxes to Sheridan County residents, or a lesser
percentage of residents than projected could have picked up boxes. In addition, these data
limitations prevented us from obtaining community-specific information on the total number of
families served or confirm that only one organization received food boxes to provide to individuals
and families in need in Sheridan County.
According to a Government Accountability LEARN MORE ABOUT THE FOOD
Office (GAO) report, USDA did not collect data BOX PROGRAM
to evaluate whether the Food Box Program met
some of its primary goals—including assisting USDA OIG and the Governmental Accountability Office
food producers with declining demand.12 Similarly, (GAO) have released reports and data stories about
the PRAC observed a lack of data in our work, the Food Box program:
which limited our ability to determine the extent
to which USDA met the Food Box Program goals USDA OIG, COVID-19—Farmers to Families Food Box
in Sheridan County. For example, USDA did not Program Administration, Rpt. No. 01801-0001-22,
August 15, 2023
require food distributors to collect and submit data
showing what food they purchased from producers USDA OIG, COVID-19—Farmers to Families Food Box
facing declining demand. Although Sheridan Program Administration—Interim Report, Rpt. No.
County’s predominant industry is agriculture, we 01801-001-22(1), June 24, 2022
could not identify any farmers or ranchers in the
county who benefited from the Food Box Program. USDA OIG, USDA Farmers to Families Food Box
Program Data Story, June 22, 2022
11 This estimate identified by USDA OIG for Sheridan County is less
than the total boxes identified by USDA data (2,619 boxes valued at
$74,023). This difference accounts for potential recipients of food
GAO, USDA Food Box Program: Key Information
boxes from surrounding counties. and Opportunities to Better Assess Performance,
12 GAO, USDA Food Box Program: Key Information and Opportunities to GAO-21-353, September 8, 2021
Better Assess Performance, GAO-21-353, September 2021.
Pandemic Response Accountability Committee 14
Participant Experience
During our field work in Sheridan County, PRAC officials met with the nonprofit organization that
received food boxes for delivery to the community. This organization is located near the border
of Sheridan County and supports the broader region with several community-centered service
programs including a childhood development program, a food pantry, a diaper program, and
assistance for homeless individuals and families. The organization’s staff told us they received the
food boxes during the second round of the program. They also provided positive feedback about
the program. Staff told us that once their organization learned it would be receiving the boxes, they
publicized a food pick-up event using local media, flyers, and their website. They attributed the
media outreach to the success of the event. The nonprofit organization also used this pick-up event
to pass out face masks and public health information related to COVID-19.
Pandemic Response Accountability Committee 15
PROGRAM SNAPSHOT
Pandemic Unemployment
Insurance Programs
U.S. Department of Labor
The federal-state unemployment insurance (UI) program, created by the Social Security Act of
1935, offers an economic line of defense against the ripple effects of unemployment. Specifically,
UI benefits are intended to provide temporary financial assistance to workers who are unemployed
through no fault of their own.
On March 27, 2020, the CARES Act was signed into law with the intent to provide expanded UI
benefits to workers who were unable to work as a direct result of the COVID-19 pandemic. The
CARES Act was designed to mitigate the economic effects of the pandemic in a variety of ways,
including the establishment of three key CARES Act UI programs: Federal Pandemic Unemployment
Compensation (FPUC), Pandemic Unemployment Assistance (PUA), and Pandemic Emergency
Unemployment Compensation (PEUC). The three programs were later extended by the Continued
Assistance for Unemployed Workers Act of 2020 and the ARP Act of 2021, ending on September 6,
2021.13
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.14
The Sheridan County unemployment rate was marginally impacted by the COVID-19 pandemic.
Nebraska estimated the unemployment rate in Sheridan County peaked in March 2020 at 4.2
percent—20 percent greater than the prior year’s highest monthly rate (see Table 3).
13 Nebraska ended its participation in the pandemic-related UI programs on June 19, 2021, prior to the programs’ statutory expiration of
September 6, 2021.
14 Regular UI, also known as state UI, is a program administered by state workforce agencies in the United States to provide temporary financial
assistance to eligible workers who have lost their jobs through no fault of their own; continued claims are ongoing weekly unemployment
benefit claims by workers who previously filed an initial claim.
Pandemic Response Accountability Committee 16
Table 3: Sheridan County, NE – Unemployment Estimates
Sheridan Sheridan County
County Average Highest Monthly Nebraska Average Nebraska Highest
Unemployment Rate Unemployment Rate Unemployment Rate Unemployment Rate
Year (%) (%) (%) (%)
2018 2.6 3.2 2.9 3.3
2019 2.7 3.5 3.0 3.6
2020 2.3 4.2 4.1 8.1
2021 1.8 2.2 2.5 3.3
Source: DOL OIG analysis of Nebraska unemployment data.
In addition to regular UI, Nebraska reported 45 unemployed workers in Sheridan County received
about $285,800 in federal UI benefits from FPUC, PUA, and PEUC (see Table 4).15
Table 4: Sheridan County, NE – CARES Act UI Benefits
CARES Act UI Program Total Benefits Paid
FPUC provided a $600 weekly supplement through July 31, 2020. FPUC
$231,300
resumed in December 2020 with a $300 weekly supplement.
PUA extended UI benefits to individuals not traditionally eligible for UI benefits,
$42,296
such as self-employed workers.a
PEUC provided additional weeks of UI benefits to individuals who had
$12,204
exhausted their regular unemployment benefits.
Total Benefits $285,800
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.
15 State workforce agencies provided DOL OIG data about pandemic UI-related programs as part of a data disclosure process. The Nebraska state
workforce agency provided this data as of January 25, 2022.
Pandemic Response Accountability Committee 17
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.
State workforce agencies would then assess eligibility and provide the claimant with the applicable
regular UI and/or CARES Act UI program payments for each week certified by the claimant.16
Participant Experience
CARES Act UI Program Participant Assessment
To assess the new CARES Act UI programs (FPUC, PUA, and PEUC), DOL OIG judgmentally sampled
39 Sheridan County residents (claimants).17 DOL OIG’s investigators traveled to the area, confirmed
the individuals filed a UI claim, and performed in-person interviews with the claimants. Of the 39
claimants, 12 (31 percent) who received benefits from at least one of the three key pandemic UI
programs chose to respond. The surveys were conducted November 1–3, 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, the 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 OIG investigations.
16 FPUC was 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.
17 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; six claimants with fraud indicators were removed from DOL OIG’s sample.
Pandemic Response Accountability Committee 18
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.18 Overall, satisfaction with the UI system was
rated 4.0 on a 5-point scale, with 38 percent of surveyed claimants rating their experience as
extremely satisfying (see Figure 2).
Figure 2: Surveyed Claimants Assessment of Claims Process
Source: DOL OIG data analysis of claimant surveys conducted November 1–3, 2022.
18 Surveyors asked claimants a series of questions and claimants responded with a 5-point scale where 1 was extremely dissatisfied and 5 was
extremely satisfied.
Pandemic Response Accountability Committee 19
Surveyed claimants identified difficulties, including the time it took to file a claim and an inability
to access the UI system. The regional state workforce agency reported in an interview that it was
swamped with customers, and customers were forced to wait in the halls to receive services.
Normally the agency served no more than 25 customers a week.19 However, during the pandemic,
this became the minimum number of customers each day of the week. Despite the increase
in customers, only one surveyed claimant (8 percent) reported that UI office accessibility was
extremely dissatisfying.
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
to pay for basic necessities, and were fair and reasonable (see Figure 3).20 The surveyed claimants
also agreed or strongly agreed that the number of weeks benefits were provided was sufficient. On
average, 0 to 17 percent of surveyed claimants felt the benefits did not have a positive impact, were
insufficient, or were not fair and reasonable.
19 The DOL OIG audit team interviewed officials at the Regional Nebraska Department of Labor office in Scottsbluff, NE, which is located
approximately 100 miles from Sheridan County. Despite the distance, it serves as the closest location to the community.
20 Surveyors offered claimants a series of statements and, for each statement, asked claimants to tell them if they: (a) strongly agreed, (b)
somewhat agreed, (c) neither agreed nor disagreed, (d) somewhat disagreed, or (e) strongly disagreed.
Pandemic Response Accountability Committee 20
Figure 3: Surveyed Claimants Assessment of Benefits
Source: DOL OIG data analysis of claimant surveys conducted November 1–3, 2022.
Claimants Generally Still Experienced Difficulty in the Labor Market
Of those who responded, 23 percent of surveyed claimants reported they were not currently
working for pay, and 67 percent reported they were unable to find employment before benefits
ran out (see Figure 4).
Additionally, 69 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, ETA 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. Furthermore, an interview with the
regional state workforce agency office disclosed that staff that worked in re-employment services
had to switch to UI services.
Pandemic Response Accountability Committee 21
Figure 4: Surveyed Claimants Return to Work Assessment
Source: DOL OIG data analysis of claimant surveys conducted November 1–3, 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. DOL OIG identified
13.3 percent of the claims submitted from Sheridan County as potentially fraudulent (see Table
5).21
21 Potentially fraudulent claims are based on data analytics and have not been investigated, adjudicated, or confirmed as fraud by a state
UI agency. Flagged transactions may not be fraudulent, and not all fraudulent transactions may be flagged. More generally, these types of
potential fraud measures can be used to identify transactions that may be indicative of potential fraud. They cannot, though, be interpreted
directly as measures of the extent of fraud in any specific geographic area.
Pandemic Response Accountability Committee 22
Table 5: Sheridan County, NE – Fraud Indicatorsa
Category Claimants Percent of Total Amount Paid
Total Claimants 45 - $285,800
Claimants with Fraud Indicator:
Multistate 3 6.7% $28,608
Suspicious Email 3 6.7% $24,141
State Flagged -b -b -b
Deceased Person -b -b -b
All Preceding Fraud Indicators
(claimants with multiple indicators were 6 13.3% $52,749
only included once to avoid duplication)
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 using Social Security numbers of
deceased persons. 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 the 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
Programs during the pandemic, visit the
PRAC’s website.
Pandemic Response Accountability Committee 23
PROGRAM SNAPSHOT
Public Housing Operating
Fund – CARES Act
U.S. Department of Housing and Urban
Development
Sheridan County is a rural community in Western Nebraska. There are two public housing agencies
(PHA) in the county: Gordon Housing Authority and Hay Springs Housing Authority. These two PHAs
were not initially affected by coronavirus, and, overall, they experienced minimal impact to their
operations. Throughout the pandemic, the two PHAs kept their respective offices open with minor
adjustments. They modified some procedures to accommodate residents who preferred to limit
their contact with others and potential exposure to the virus. For example, the PHAs only conducted
in-person unit inspections if the residents felt comfortable with PHA staff entering their unit.
The Public Housing Operating Fund provides an operating subsidy to assist PHAs in serving low-,
very low-, and extremely low-income families in the operation
and management of public housing. This funding is made
available to PHAs, and the operating subsidy amount that a CLEAR GUIDANCE AND
PHA receives each year is determined by a formula. Eligible TECHNICAL SUPPORT
uses for these funds include, but are not limited to:
HUD provided PHAs with several resources
• Management and operation of public housing units, to ensure that the CARES Act supplemental
including the cost of review by an independent auditor operating funds were used as intended.
HUD issued notices, published frequently
• Routine preventive maintenance asked questions on its website, and held
• Anticrime and antidrug activities calls with PHAs to provide guidance on the
allocation and eligible uses of the funds.
• Rehabilitation and development of public housing units The executive director for the two PHAs in
The CARES Act (signed into law on March 27, 2020) provided Sheridan County believed the guidance
an additional $685 million in supplemental operating funds. provided by HUD was clear and HUD staff
The CARES Act required that HUD allocate the funds to PHAs was readily available to answer questions.
using the same formula applied to routine operating funds.
The CARES Act also expanded eligible uses of these funds to
include activities to prevent, prepare for, and respond to the coronavirus, including additional funds
for PHAs to maintain normal operations and take other necessary actions during the period in which
the program is impacted by coronavirus.
Pandemic Response Accountability Committee 24
As of September 30, 2021, HUD had provided $13,972 in supplemental operating funds to two
PHAs in Sheridan County: Gordon Housing Authority and Hays Springs Housing Authority.22 Gordon
Housing Authority received $9,519, and Hay Springs Housing Authority received $4,453. Both PHAs
spent all of their CARES Act supplemental operating funds by December 31, 2020.
HUD provided PHAs with several resources to ensure that the CARES Act supplemental operating
funds were used as intended. Specifically, HUD issued notices, published frequently asked
questions on its website, and held calls with PHAs to provide guidance on the allocation and eligible
uses of the additional funds. Further, HUD provided guidance explaining the flexible uses of CARES
Act supplemental operating funds for eligible Public Housing Operating Fund and Capital Fund
activities or for coronavirus purposes.23 Examples of eligible use include, but are not limited to:
• Sourcing and purchasing PPE for PHA staff
• Costs related to maintaining adequate social distancing
• Salaries of PHA staff unable to work because of the coronavirus public health restrictions
Program Impact on the Community
HUD OIG’s review found that the two PHAs in Sheridan County used their CARES Act supplemental
operating funds consistent with program goals and objectives, which were to prevent, prepare for,
and respond to coronavirus. Gordon Housing Authority and Hay Springs Housing Authority used the
CARES Act supplemental operating funds in a similar manner. Each PHA maintained an office in its
respective town, employed its own maintenance staff, and received a separate allocation of CARES
Act supplemental operating funds for its public housing units. Gordon Housing Authority received
$9,519 in CARES Act supplemental operating funds for its 25 units, and Hay Springs Housing
Authority received $4,453 for its 17 units.
The two PHAs in Sheridan County used their CARES Act supplemental operating funds to protect
their residents and staff and to continue normal operations. Specifically, they used the funds to
purchase PPE supplies, including masks, thermometers, and shields for their offices. The two
PHAs also used the funds to pay salaries for their maintenance staff and to pay for accounting
services. These expenditures were eligible and met the goals and objectives of the program. They
allowed the PHAs to maintain normal operations and assisted the PHAs with preventing, preparing
for, and responding to the coronavirus.
22 Gordon Housing Authority and Hays Springs Housing Authority were contractually managed by Scotts Bluff Housing Authority and had the same
Executive Director. It is not uncommon for small PHAs to be contract managed by another PHA.
23 An overview of Funding Flexibilities can be found in Notice PIH-2020-07; The Public Housing Capital Fund program provides funds to PHAs to
modernize public housing developments.
Pandemic Response Accountability Committee 25
Participant Experience
The executive director for the two PHAs in Sheridan County believed the amount of CARES Act
supplemental operating funds received from HUD was adequate in helping the PHAs to prevent,
prepare for, and respond to coronavirus in the community. Overall, the executive director also
indicated that the impact of coronavirus in the community was minimal, and the CARES Act
supplemental operating funds allowed the PHAs to continue operations while limiting exposure
for program participants and staff. Additionally, the executive director believed HUD’s guidance
provided through notices, online resources, and virtual meetings, was clear and HUD staff were
readily available to answer questions. This guidance assisted the two PHAs in Sheridan County,
allowing them to use their CARES Act supplemental operating funds for eligible expenditures in a
timely manner.
Pandemic Response Accountability Committee 26
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 the 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 three Sheridan County nursing homes in the U.S. Department of Health and Human Services
(HHS) OIG’s sample have had substantial financial challenges in responding to the pandemic.26
The nursing homes’ leaders reported lost revenue because the facilities had fewer residents during
the pandemic. They reported limiting admissions during outbreaks and at other times according
to COVID-19-related requirements to keep rooms available for residents who tested positive and
because of staff limitations. Leaders and staff reported that loved ones sometimes removed
residents from the facilities or did not admit them because they were worried that COVID-19
precautions would prevent them from visiting the residents. A chief financial officer (CFO) for one
nursing home described how temporary halts on elective procedures at a hospital within the same
health system caused a decrease in the number of short-term nursing home stays for patients
recovering from those procedures. She said that the loss in revenue from fewer short-term stays
was “absolutely devastating.”
Facility leaders from all three nursing homes reported that, while revenue declined, expenses
increased. Leaders and staff reported that significant increases in labor costs were a substantial
financial challenge, and that those costs still had not decreased as of August 2022. Leaders
attributed the increased costs to staffing shortages, which they explained worsened as the
pandemic continued, partially because of COVID-19 regulations and vaccine mandates. At the same
time, leaders and staff reported an increased need for staff to cover the facilities’ COVID-19
24 HHS OIG, COVID-19 Had a Devastating Impact on Medicare Beneficiaries in Nursing Homes During 2020, OEI-02-20-00490, June 2021; 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; 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.
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 skilled nursing facility [SNF]) according to common use.
Pandemic Response Accountability Committee 27
isolation units and the shifts of other staff who were out
INCREASED COSTS RELATED sick with COVID-19. Leaders and staff said the staffing
TO COVID-19 shortages coupled with the increased need created a
reliance on contracted staff from staffing agencies whose
All three nursing homes reported hourly rates were double or triple that of in house staff and
significant increases in labor costs. One were continuing to rise at the time HHS OIG collected its
reported providing pay bonuses of $50 to data. Leaders and staff also reported incurring additional
$150 per shift to incentivize staff to work labor-related expenses linked to overtime and hazard pay,
additional shifts on an as-needed basis. bonuses, paid sick leave, and in-house meals for staff.
Additionally, they described increased costs for other
COVID-19 related needs, including medical equipment and
supplies such as PPE and upgrades to facility infrastructure for improved infection control. For
example, one administrator reported that the cost of a case of gloves nearly tripled in price, from
$23 to $68. Leaders and staff at another nursing home reported replacing facility flooring with
flooring material that was easier to disinfect.
Nursing home leaders and staff reported both personal and operational challenges to providing
care during the COVID-19 pandemic. Leaders and staff said that early in the pandemic they faced
fear and uncertainty surrounding COVID-19. In one facility, seven staff members quit the day the
community had its first case because they were not willing to risk contracting the virus and exposing
loved ones. Staff said ongoing circumstances created by the pandemic also took an emotional
toll on them. One administrator described how some staff struggled emotionally with quarantining
residents and said that one nurse quit because she did not want to “lock [the residents] up.” Staff
reported that it was emotionally and physically challenging to keep residents and visitors apart. One
nursing home reported hiring security guards to enforce visitation restrictions because some family
members did not want to follow COVID-19 precautions. Across the nursing homes, leaders and staff
reported that additional staff left the facilities as the pandemic continued because of emotional
strain, disagreements over COVID-19 guidelines on vaccine mandates and PPE use, or staff
accepting higher paying jobs with staffing agencies or leaving the health care industry altogether.
The remaining staff and leaders reported working long hours due to resulting staffing shortages,
with one administrator working 80 hours per week to provide care.
Nursing home leaders, staff, and residents reported that residents experienced severe strain
during the COVID-19 pandemic. One nursing home administrator said that every resident tested
positive during the facility’s first outbreak in November 2020. Leaders and staff reported that—in
addition to contracting COVID-19—residents lost social interactions with staff members, other
residents, and family members because of the pandemic-related isolation. According to leaders,
staff, and residents, frequent changes to staffing and care and communication challenges created
by COVID-19-related protocols led to frustration and confusion among residents. One administrator
explained, “[Residents] can’t tell who we are when our faces are completely covered with goggles
and masks.” Leaders, staff, and residents also reported that because of isolation, residents faced
mental and physical health issues, including dementia-related cognitive decline and weight loss.
Staff said some residents quit eating or would not leave their rooms even when allowed to do so
Pandemic Response Accountability Committee 28
and had to be treated for depression. One resident stated it “felt like I couldn’t breathe” because of
increased anxiety from being confined to their room.
“When the pandemic started, [residents] were prisoners in their own home.”
—Nursing home staff member
Program Information
To reimburse health care providers for pandemic-related expenses and lost revenue, Congress
appropriated $178 billion to HHS during 2020 and 2021.27 To administer the funds, HHS
established the PRF and related programs.28 The Health Resources and Services Administration
(HRSA) is the HHS agency responsible for administering the PRF program.29 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).30 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 2023.31 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).32 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.33
27 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).
28 HRSA administered funds for other programs, such as for the Rural Health Clinic COVID-19 Testing and Mitigation Program, alongside PRF. HHS
also used $8.5 billion that Congress appropriated through the American Rescue Plan (ARP) Act of 2021 to establish the ARP Rural Distribution
as a separate program to administer payments to providers and suppliers who serve rural enrollees in Medicaid, the Children’s Health
Insurance Program, and Medicare, including nursing homes and certified SNFs. See HHS, news release, “Biden-Harris Administration Begins
Distributing American Rescue Plan Rural Funding to Support Providers Impacted by Pandemic,” November 23, 2021; HHS, news release, “HHS
to Begin Immediate Delivery of Initial $30 Billion of CARES Act Provider Relief Funding,” April 10, 2020.
29 86 Fed. Reg. 40064 (July 26, 2021).
30 HRSA, Past General Distributions, December 2021; HRSA, Past Targeted Distributions, November 2022.
31 HRSA, Provider Relief, June 2023.
32 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.
33 HRSA, Important Dates for Reporting. May 2023.
Pandemic Response Accountability Committee 29
Table 6: Timelines for Facility Receipt, Use, and Reports of PRF Payments
Reporting
Period Payment Received Period Deadline to Use Funds Reporting Time Period
April 10 to July 1 to
1 June 30, 2021
June 30, 2020 September 30, 2021a
July 1 to January 1 to
2 December 31, 2021
December 31, 2020 March 31, 2022
January 1 to July 1 to
3 June 30, 2022
June 30, 2021 September 30, 2022
July 1 to January 1 to
4 December 31, 2022
December 31, 2021 March 31, 2023
January 1 to July 1 to
5 June 30, 2023
June 30, 2022 September 30, 2023
July 1 to January 1 to
6 December 31, 2023b
December 31, 2022 March 31, 2024
January 1 to July 1 to
7 June 30, 2024b
June 30, 2023 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).34 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.35 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-19.36 HHS distributed the other $4.6 billion to facilities through
the Nursing Home Infection Control (NHIC) distribution, which included two types of allocations:
infection control payments to 12,787 facilities and Quality Incentive Payment (QIP) program
34 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 HHS OIG that HHS had obligated approximately $54.7 billion total to SNFs and nursing homes
across all PRF distributions; HRSA, Past Targeted Distributions, November 2022.
35 HRSA, Past Targeted Distributions, November 2022; CMS, Medicare Coverage of Skilled Nursing Facility Care, July 2019.
36 HRSA, Acceptance of Terms and Conditions, Skilled Nursing Facility Relief Fund Payment Terms and Conditions.
Pandemic Response Accountability Committee 30
payments to 11,819 facilities.37 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.38
Program Impact on the Community: PRF Payments to Nursing
Homes in Sheridan County
The three Sheridan County nursing homes received both general and targeted PRF payments.
As of December 2021, the sample nursing homes had received a total of $4,961,682 from PRF
distributions. Targeted payments included $542,500 from the SNF distribution and $557,114 from
NHIC distributions (see Table 7).
Table 7: PRF Payments to Nursing Homesa
Total Payments Distributed to Nursing Total Payments Distributed to the
Distribution Homes Nationally Sample Nursing Homes
SNF $4.8 billion $542,500
NHIC $4.6 billion $557,114
OTHERb $45.3 billion $3,862,068
TOTAL $54.7 billion $4,961,682c
Sources: 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 OIG in June 2023 the total amount paid to nursing homes, but it 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 $491,138 from the ARP Rural Distribution and $298,923 from the Rural Health Clinic
COVID-19 Testing (RHCCT) and Rural Health Clinic COVID-19 Testing and Mitigation (RHCCTM) programs. Although the ARP
Rural Distribution and the RHCCT and RHCCTM programs are separate from PRF, they are related to PRF in that they were
administered and included in HRSA’s data alongside PRF. The $491,138 from the ARP Rural Distribution included a payment
made to one local health system that included a hospital and rural health clinics in addition to the nursing home (see footnote
39); some of the ARP Rural funding was therefore unrelated to nursing home operations. The RHCCT and RHCCTM payments
also supported the rural health clinics; the purpose of those programs was to assist rural health clinics in maintaining and
increasing COVID-19 testing efforts, expanding access to testing in rural communities, and expanding the range of COVID-19
mitigation activities in local communities. See HRSA, Rural Health Clinic COVID-19 Testing and Mitigation (RHCCTM) Program,
August 2022.
37 HRSA, Past Targeted Distributions, November 2022.
38 HRSA, Acceptance of Terms and Conditions, Skilled Nursing Facility and Nursing Home Infection Control Relief Fund Payment Terms and
Conditions.
Pandemic Response Accountability Committee 31
Two nursing homes reported that they spent all the PRF payments they received during the first
two periods, and one nursing home returned a portion of the PRF payments. Responsibilities
for monitoring and reporting on use of the PRF funds differed among the three facilities. In one
facility, the CFO of the nursing home’s health system was responsible for those functions, while
facility administrators at the other two nursing homes managed the funds directly or worked with a
contracted management group to handle the funds.39
At the time of HHS OIG’s data collection, facilities were required only to have reported on the use of
PRF payments received during the first two periods (April through December 2020). Facility leaders
reported that the nursing homes used or returned all the funds they received during the first two
periods. Specifically, the three nursing homes reported using $4,665,111 in total PRF payments,
including $915,651 in payments targeted to nursing facilities ($542,500 in SNF payments and
$373,151 in NHIC payments) and $365 in interest earned on PRF payments.40 One facility returned
a $97,000 NHIC payment rather than using it.
Of the three nursing homes, one facility reported using the payments for both lost revenue and
expenses, one used the payments only for expenses, and the third used the payments it kept only
for lost revenue. 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 ($322,056)
for general and administrative expenses, such as payroll. They also used NHIC payments
($51,095) to offset health care-related expenses, such as medical equipment and supplies.
The facility that returned an NHIC payment ($97,000) to HRSA did so because the contracted
managers did not feel they could appropriately use the money for infection-related purchases
during the given time period.
• Collectively, the nursing homes reported using most of the other payments they received
($2,236,714) for general and administrative expenses. They also used $1,473,544 for health
care-related expenses and $581,702 to cover pandemic-related lost revenue.
Leaders at the Sheridan County nursing homes said HRSA’s guidance on allowable uses and
reporting requirements was initially unclear but improved over time. Leaders reported that they
sometimes had little or no notice that they would be receiving PRF payments, and that HRSA’s
guidance on use of the funds was initially broad and unclear. As a result, some were hesitant to
use the funds for fear that they would use the money incorrectly and be forced to pay it back later.
A representative from the contracted management group that worked with one of the nursing
homes stated that the first reporting period had the biggest learning curve because there was so
much information to read. An administrator at another nursing home stated that it was difficult to
find time to review the material and submit the reports. Leaders reported receiving supplemental
39 One facility contracted with an external management consulting company. Another facility was part of a local health system that also included
a hospital and two rural health clinics. Leaders for the health system reported PRF use for all system components to HRSA.
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 $200,000 during the first two reporting periods.
Pandemic Response Accountability Committee 32
guidance from outside organizations about PRF requirements and noted that HRSA’s guidance
improved over time.
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.
It reviewed the reports the nursing homes made to HRSA during the first two reporting periods,
along with summary supporting documentation. It did not audit the facilities’ financial reports or
supporting documents. HHS OIG 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. One nursing home’s documentation, however, appeared to show
that funds it reported using for general and administrative expenses were actually used for lost
revenue, which would mean that the facility incorrectly used NHIC payments. Documentation from
the remaining facility, which did not return or appear to incorrectly use its NHIC payments, generally
supported that the nursing home used NHIC payments for infection control-related expenses, as
intended. Examples included facility expenses on PPE and other medical 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: Results of Interviews with Nursing
Homes in Sheridan County
PRF payments have been integral to the three nursing homes’ pandemic response, according
to facility leaders and staff representing the Sheridan County nursing homes. Leaders and
staff reported that the PRF payments were instrumental in continuing operations and maintaining
infection control and quality of care during the pandemic. Representatives from the contracted
management group described using the payments to cover its nursing home’s lost revenue from
having fewer residents and said that the payments allowed flexibility to purchase additional
supplies and recognize nursing home staff for their hard work. One representative said, “It was new
money none of us knew was coming [and] it saved a lot of nursing homes from closing.” One CFO
stated that the PRF payments helped the facility better prepare for other emergencies beyond the
COVID-19 pandemic.
Pandemic Response Accountability Committee 33
“Things were getting bad and dangerous . . . Then this new money showed up that we weren’t expecting
but allowed us to address things . . . Thank God this money came through.”
—CEO, Contracted management group
Facility leaders from the nursing homes reported that they were grateful for the PRF payments and
that the facilities would benefit from additional relief funding. A representative from the contracted
management group said its nursing home was able to maintain operations using PRF and
assistance received from other sources, and the facility’s administrator stated that they appreciated
the assistance PRF provided. The CFO for another facility stated that although the PRF payments
were adequate for addressing the facility’s needs at the time received, the nursing home could not
have anticipated that the expenses for contracted labor and other costs would continue to increase.
The CFO noted that additional relief funding would be beneficial to the nursing home to further
offset costs. The administrator for the third nursing home also expressed gratitude for the PRF
payments but described COVID-19-related costs and lost revenue that significantly outweighed the
PRF amount that the facility received.
FOR MORE INFORMATION
For more information about Provider Relief Fund
program spending across the country, visit the PRAC’s
website, including an interactive dashboard.
Pandemic Response Accountability Committee 34
Appendix A: Acronyms
ARP Act American Rescue Plan Act of 2021
CARES Act Coronavirus Aid, Relief, and Economic Security Act
CIGIE Council of the Inspectors General for Integrity and Efficiency
CFO Chief Financial Officer
CRF Coronavirus Relief Fund
DOL U.S. Department of Labor
ED U.S. Department of Education
ESSER Elementary and Secondary School Emergency Relief
Food Box Program Farmers to Families Food Box Program
FPUC Federal Pandemic Unemployment Compensation
GAO Government Accountability Office
HHS U.S. Department of Health and Human Services
HRSA Health Resources and Services Administration
HUD U.S. Department of Housing and Urban Development
Nebraska ED State of Nebraska Department of Education
Nebraska HHS State of Nebraska Department of Health and Human Services
NHIC Nursing Home Infection Control
OIG Office of Inspector General
PEUC Pandemic Emergency Unemployment Compensation
PHA Public Housing Agencies
PPE Personal Protective Equipment
PPHD Panhandle Public Health District
PRAC Pandemic Response Accountability Committee
PRF Provider Relief Fund
Pandemic Response Accountability Committee 35
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
Pandemic Response Accountability Committee 36
Appendix B: Scope and Methodology
Scope
In October 2021, the PRAC, along with 10 of our OIG members, initiated a case-study-based review
that sought to identify the federal pandemic response funds provided to select geographic areas,
the purpose of those funds, and if the spending aligned with the intended goals and objectives. To
conduct our work, we divided the review into two phases. Phase one sought to determine how much
pandemic funding went to the six selected communities. The final report for phase one, Tracking
Pandemic Relief Funds that Went to Local Communities Reveals Persistent Data Gaps and Data
Reliability Issues, was issued July 6, 2023. Phase two of the review sought to gain more insight
into how the six communities used their pandemic relief funding; if spending generally aligned with
the goals and objectives of the programs and subprograms; and whether the funding helped the
six communities respond to the pandemic. The final insights report for phase two of this review,
Pandemic Relief Experiences: A Focus on Six Communities, was issued on March 28, 2024.
To conduct our work, we 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 the 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, six provided funding to recipients in
Sheridan County. In our review of the six programs, we sought to identify how the recipients used
the funds and if the uses generally aligned with the program’s goals and objectives. The programs
or subprograms selected for Sheridan County were:
• 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 | U.S. Department of Health and Human Services
More information about the scope and methodology for phase two of this review can be found in our
March 2024 report.
Pandemic Response Accountability Committee 37
Methodology
We visited Sheridan County in August 2022 and conducted interviews with government, community,
and business leaders to discuss the community’s experiences with the pandemic, federal guidance,
best practices, lessons learned, and suggestions for improvement. The overall methods we used to
achieve the objectives included reviewing laws, program guidelines, and background information
for the programs, as well as working with our OIG partners. The specific scope and methodology
used to review each of the selected programs and subprograms is provided in each of the program
sections.
Standards
Each OIG and 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, CIGIE’s Quality Standards
for Inspection and Evaluation, and internal OIG guidance. All these standards require that we
planned and performed this study to obtain sufficient and appropriate evidence to provide a
reasonable basis for the insights and conclusions. This work was completed between October
2021 and November 2023 and complies with the CIGIE’s Quality Standards for Inspection and
Evaluation.
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 Sheridan County (1)
used CRF award funds in alignment with program goals and objectives, and (2) believe that CRF
funding impacted (positively or negatively) their ability to respond to the pandemic.
The scope of Treasury OIG’s engagement covered CRF expenditures reported in GrantSolutions
from March 1, 2020 (Cycle 1) through June 30, 2022 (Cycle 9). Nebraska allocated $147,732 to
only one subrecipient, a minority resource center. Treasury OIG tested $76,424 (52 percent) of CRF
expenditures to determine whether the center used the CRF award funds in alignment with the
program’s goals and objectives.
To accomplish these objectives, Treasury OIG performed the following during engagement fieldwork
conducted from August through November 2022:
• Reviewed Title VI of the Social Security Act, as amended by Title V of Division A of the CARES
Act41
41 P. L. 116-136 (March 27, 2020).
Pandemic Response Accountability Committee 38
• Reviewed the Consolidated Appropriations Act, 202142
• Reviewed Treasury Guidance and Frequently Asked Questions published in the Federal
Register, Volume 86, No. 10 (January 15, 2021)
• Reviewed Nebraska and subrecipient policies and procedures for determining CRF eligible use
• Inquired about and analyzed Nebraska and subrecipient policies and procedures for
determining eligible use of CRF
• Interviewed subrecipient officials regarding CRF usage, experience, and impact
• Reviewed Nebraska and subrecipient Single Audit Reports for fiscal years 2020 and 2021 to
assess findings that may suggest risk with the subrecipients’ uses of CRF
• Reviewed media reports associated with the COVID-19 pandemic and CRF impacts within
Sheridan County and the state of Nebraska
• Reviewed supporting documentation to determine if the selected grant expenditures were
(1) necessary expenditures incurred due to the public health emergency with respect to
COVID-19; (2) for costs not accounted for in the budget most recently approved as of March
27, 2020; and (3) incurred between March 1, 2020, and December 31, 2021. Supporting
documentation includes grant agreements, invoices, purchase orders, application packages,
and data extracts from Nebraska and subrecipient accounting systems.
Standards
Treasury OIG conducted this engagement in accordance with CIGIE’s Quality Standards for
Inspection and Evaluation.
42 P. L. 116-260 (December 27, 2020).
Pandemic Response Accountability Committee 39
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 the two school districts that fall within the
boundaries of Sheridan County—Gordon-Rushville Public School District and Hay Springs Public
School District—and their use of three rounds of ESSER funding from program inception through
September 30, 2021. Our objectives were to identify how the districts used the ESSER funding it
received, and to determine whether the districts generally spent ESSER funds in alignment with
program goals and objectives. The PRAC staff coordinated this work with ED OIG.
Methodology | To answer these objectives, we:
• Reviewed applicable ESSER guidance including Frequently Asked Questions, Elementary and
Secondary School Emergency Relief Program Governor’s Emergency Relief Programs issued in
May 2021 and revised December 7, 2022.
• Obtained summary descriptions of ESSER spending from the districts.
• Determined if funding use descriptions aligned with ESSER’s objectives of helping the districts
prevent, prepare for, and respond to coronavirus, domestically or internationally.
• Interviewed district officials, local officials, and Nebraska ED officials about funding uses as
well as the effects the ESSER funds had on the districts’ ability to respond to and recover from
the pandemic.
Standards
We conducted this study in accordance with the Quality Standards for Inspection and Evaluation
issued by CIGIE.
Pandemic Response Accountability Committee 40
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 USDA’s Food Box Program
and its rounds of funding provided to the Sheridan County community from May 15, 2020, through
May 31, 2021. Our objectives were to identify how many food boxes went to the Sheridan County
community and whether the program met its goals and objectives in serving producers, distributors,
and the local food recipient organization as intended.
Methodology | To answer these objectives, we:
• Reviewed multiple federal reports evaluating the Food Box Program.
• Obtained and reviewed data showing the number of food boxes sent to the food recipient
organization serving the Sheridan County community.
• Interviewed a food box recipient to determine how the Food Box Program helped Sheridan
County respond to the pandemic.
• 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 the first part of this case-study-based
review. Part one of this review introduced data limitations which prevented us from determining if
the program served producers, distributors, and the food recipient organization in accordance with
program goals and objectives.
Standards
We conducted this study in accordance with CIGIE’s Quality Standards for Inspection and
Evaluation.
Pandemic Response Accountability Committee 41
Pandemic Unemployment Insurance | U.S. Department of
Labor, Office of Inspector General
Methodology
Scope | DOL OIG’s evaluation covered 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 of
2021 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, ARP 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 DOL 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 39 claimants with whom DOL OIG investigators
performed on-site interviews between November 1--3, 2022, for Sheridan County, NE.43 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.
43 Judgmental sampling is a non-probability sampling technique in which the sample members are chosen on the basis of the auditor’s
knowledge and judgment.
Pandemic Response Accountability Committee 42
Standards
DOL OIG conducted this study in accordance with CIGIE’s Quality Standards for Inspection and
Evaluation. Those standards require that it plans and performs the review to obtain sufficient,
appropriate evidence to provide a reasonable basis for its findings and conclusions based on DOL
OIG’s objective.
Public Housing Operating Fund – CARES Act | U.S.
Department of Housing and Urban Development, Office of
Inspector General
Methodology
Scope | HUD OIG conducted the review remotely from August through December 2022. Its review
covered the use of CARES Act supplemental operating funds by two PHAs in Sheridan County from
program inception through September 30, 2021. Its review objectives were to determine whether
the CARES Act supplemental operating funds were spent in alignment with program goals and
objectives and whether the funds positively or negatively impacted the PHAs’ ability to respond to
the pandemic.
Methodology | To accomplish its review objectives, HUD OIG:
• Reviewed applicable HUD requirements (HUD notices).
• Interviewed HUD staff to gain an understanding of the goals and objectives for the Public
Housing Operating Fund CARES Act funding.
• Interviewed the executive director of Scotts Bluff Housing Authority who managed the two
PHAs in Sheridan County (Gordon Housing Authority and Hay Springs Housing Authority) to
obtain an understanding of how the two PHAs used the CARES Act supplemental operating
funds to prevent, prepare for, and respond to the pandemic.
• Reviewed supporting documentation for all Public Housing Operating Fund CARES Act
expenditures, including ledgers, invoices, and payroll summaries.
The review universe consisted of two awards of the CARES Act supplemental operating funds made
to two PHAs in Sheridan County totaling $13,972. Of this amount, $9,519 was awarded to Gordon
Housing Authority, and $4,453 was awarded to Hay Springs Housing Authority. Both PHAs had spent
all of their CARES Act supplemental operating funds by December 31, 2020. HUD OIG reviewed all
expenditures to determine whether the PHAs spent CARES Act supplemental operating funds in
alignment with the program goals and objectives.
To achieve its objectives, HUD OIG relied in part on the PHAs’ computer-processed data. Although
HUD OIG did not perform a detailed assessment of the reliability of the data, it determined that the
Pandemic Response Accountability Committee 43
data was sufficiently reliable for the purposes of its review because it corroborated the data for the
expenditures against supporting documentation provided.
HUD OIG determined that internal controls were not relevant to its objectives. Its objectives were
not to evaluate or provide assurance of the PHAs’ internal controls. Therefore, it did not assess the
PHAs’ 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 plans and performs 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 | U.S. Department of Health and Human
Services, Office of Inspector General
Scope
HHS OIG examined the use of targeted PRF payments to three nursing homes in Sheridan County
during calendar years (CYs) 2020 and 2021. The selected facilities received direct PRF payments
through distributions that HHS targeted for nursing homes and certified SNFs.44 HHS OIG conducted
its data collection concurrently with the PRAC’s site visit to Sheridan County during August 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 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.
44 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 Sheridan County 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 44
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. It 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 them 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 facility leaders and staff
in each selected nursing home. Participants consisted of nursing home leadership, including
representatives from a larger health system and a contracted management group, and a small
number of clinical and nonclinical staff. It also conducted small group interviews with residents at
two of the three 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 was under
COVID-19 restrictions at the time of the review and had no residents available to speak with them.
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. It discussed
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, it
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
HHS OIG’s 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
within HRSA‘s Provider Relief Bureau. During the interviews, it gathered more detailed information
about PRF goals and performance metrics. It 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. 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
payments. They had, however, reported on most of the payments they received through the targeted
Pandemic Response Accountability Committee 45
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, it 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 HHS OIG’s Division of Data Analytics
accessed directly through its data use agreement with HRSA. It collected the PRF payment data in
preparation for the PRAC’s series of location site visits; the data was extracted on February 28,
2022, and, depending on whether 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 the study timeframe of CYs 2020 and 2021 (the first four distribution periods) and
were collected in time for HHS OIG 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. It 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 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. It 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 the Quality Standards for Inspection and
Evaluation issued by CIGIE.
Pandemic Response Accountability Committee 46
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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