A Review of Pandemic Relief Funding and How It Was Used in Six U.S. Communities: Marion County, Georgia
- Document type
- Report
- Date
- 2025-01-15
Summary
A January 2025 report by the Pandemic Response Accountability Committee, the fourth in a series on how six communities used federal pandemic funding, focusing on Marion County, Georgia. The report states that Marion County recipients received more than $38.8 million from 27 federal pandemic relief programs and subprograms, and it reviews 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 Georgia awarded $502,822 in CRF funds to recipients in the county and that residents received more than $7.3 million in pandemic-related unemployment benefits. Appendices set out abbreviations 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
Marion County, Georgia
January 2025
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: Marion County, GA ........................................ 1
Coronavirus Relief Fund...................................................................................................................... 5
Elementary and Secondary School Emergency Relief Program ...................................................... 9
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 .........................................................................26
Appendix A: Abbreviations and Acronyms........................................................................................33
Appendix B: Scope and Methodology ..............................................................................................35
Coronavirus Relief Fund................................................................................................................36
Elementary and Secondary School Emergency Relief Program ................................................38
Farmers to Families Food Box Program .......................................................................................39
Pandemic Unemployment Insurance Programs..........................................................................40
Public Housing Operating Fund – CARES Act .............................................................................. 41
Provider Relief Fund Payments to Nursing Homes .....................................................................42
ii
Taking a Closer Look at a
Community’s Experience:
MARION COUNTY, GEORGIA
This report is the fourth 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 Marion County,
GA, with a detailed look at six of the 27
pandemic programs that provided funding
to the community. For more information
about our review, see Appendix B.
Marion County, located in Southern
Georgia and 35 miles east of Columbus,
has a population of 7,449 and a poverty
rate of 21.3 percent. As of October 2021,
Marion County had experienced 960
recorded cases of COVID-19 and 38
deaths. By February 2022, COVID cases
increased to 1,086 and 47 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 Marion County recipients, including
the county government, small businesses,
and individuals, received more than $38.8
million from 27 federal pandemic relief
programs and subprograms during the
first 18 months of the pandemic. This
report provides a closer look at six of
these federal pandemic programs from a
U.S. Census Bureau data for counties and cities.
six federal agencies and the funding 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 county-
wide rate. Data as of May 30, 2023.
d
Data was obtained from the Marion County Health Department and represents totals for
Marion County as of February 28, 2022.
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.
they provided to Marion County. These programs
aimed to mitigate the effects of the pandemic by
addressing community development needs that
Programs Selected for
posed a serious threat to the health or welfare of Further Review
the community—for example, offering support to Coronavirus Relief Fund
essential workers with hazard pay so they could
U.S. Department of the Treasury
ensure the community’s safety and developing
learning loss remediation programs for local Elementary and Secondary School
schools. Emergency Relief Program
In this report, we offer insights into how Marion U.S. Department of Education
County used its pandemic relief funding, how Farmers to Families Food Box Program
the spending generally aligned with the goals
U.S. Department of Agriculture
and objectives of the federal programs and
subprograms, and whether the funding helped Pandemic Unemployment
Marion County residents respond to the pandemic. Insurance Programs
U.S. Department of Labor
Pandemic Impact on Public Housing Operating Fund
– CARES Act
the Community U.S. Department of Housing and Urban
Development
Similar to other communities we examined, the
pandemic impacted many aspects of life in Marion Provider Relief Fund Payments
County. We heard from multiple officials that a large to Nursing Homes
challenge for this small community was staffing U.S. Department of Health and Human Services
and maintaining essential positions. For example,
officials within the office of the county’s Board of
Commissioners said there was high turnover in
the county manager position because it paid less than the same position in surrounding counties.
We were told this affected several of the county’s activities because even before the pandemic,
the county manager was responsible for identifying federal and state grants that could benefit
the community. Other county officials noted that they held office as a part-time position, and it
was difficult for them to juggle both community duties and their full-time employment during the
pandemic.
According to county officials, Marion County’s Emergency Medical Services (EMS) also faced
staffing challenges to fill vacancies of part-time EMS employees due to the county’s low wages. To
protect the community and improve staff retention, Georgia distributed $330,104 from the U.S.
Department of the Treasury’s (Treasury) Coronavirus Relief Fund (CRF) to Marion County for EMS
payroll and benefits. In addition, officials shared that Marion County schools had difficulties hiring
and retaining educational staff. In response, the Marion County School System spent approximately
$1.4 million in U.S. Department of Education (ED) Elementary and Secondary School Emergency
Relief (ESSER) Program funds to pay salaries and benefits to ensure continuity of core staff and
services, as well as teacher bonuses to help retain staff.
Pandemic Response Accountability Committee 2
During the pandemic, the average unemployment rate in Marion County increased from 4.4 percent
in 2019 to 5 percent in 2020, peaking at 7.2 percent in April 2020 and resulting in Marion County
residents receiving more than $7.3 million in federal benefits from pandemic-related unemployment
insurance (UI) programs.
Program Impact on the Community
The Pandemic Response Accountability Committee (PRAC) and Offices of Inspectors General
(OIG) teams interviewed Marion County officials who offered a wide variety of responses when
asked about the community’s use of federal pandemic funds to address the impacts of COVID-19.
Other individuals in the community also told our teams that the federal government’s emergency
assistance helped with immediate responses to the pandemic. A sample of these programs:
• By September 30, 2022, Treasury had disbursed approximately $3.5 billion in CRF award
funds to Georgia, of which the state then awarded $502,822 to two subrecipients (Marion
County and the city of Buena Vista) and one beneficiary (a nonprofit senior-living campus in
Buena Vista) located in Marion County. These funds allowed recipients to cover EMS and law
enforcement salaries and benefits, purchase personal protective equipment (PPE) and COVID
testing supplies, and support food programs in the wake of the pandemic.
• The ESSER Program awarded Marion County approximately $7.6 million. As of September
30, 2021, the county’s schools spent around $1.4 million of the money to support programs
to reduce or mitigate the effects of the pandemic, such as reducing class sizes to allow for
smaller student-to-teacher ratios, increasing tutoring for students, and providing summer
programing.
• As of the program’s completion in May 2021, the U.S. Department of Agriculture (USDA)
Farmers to Families Food Box Program (Food Box) delivered 4,676 food boxes (valued at
$206,668) to two recipient organizations to feed families in the Marion County community.
• The Buena Vista Housing Authority, located in Marion County, received $36,366 from the
U.S. Department of Housing and Urban Development’s (HUD) Public Housing Operating Fund
to prevent, prepare for, and respond to COVID. The funds also allowed for the continued
management, equipment purchases, and related rehabilitation activities for its 79 housing
units during the pandemic.
Pandemic Response Accountability Committee 3
Participant Experience
During our site visit in December 2022, we received feedback from multiple Marion County officials
whose offices or organizations received federal pandemic funding. The officials shared their
experiences with federal response programs within Marion County, highlighting challenges and
successes in responding to the pandemic. For example:
• Marion County school officials told us that it was a challenge to provide homework
assignments to students and then grade the assignments. The school system used ESSER
funding to procure hotspots and devices for students so that they could be given their
assignments virtually and learn in a remote environment.
• Most UI program claimants surveyed as part of this report expressed overall satisfaction with
the application process, promptness of receiving benefits, and the certification process to
continue receiving benefits.
• Leaders from a Marion County nursing home reported that Provider Relief Fund (PRF)
payments were integral to the nursing home’s pandemic response but said that the payments
were not sufficient to address long-term costs related to COVID.
Pandemic Response Accountability Committee 4
PROGRAM SNAPSHOT
Coronavirus Relief Fund
U.S. Department of the Treasury
As of October 2021, Marion County had experienced 960 COVID-19 cases and 38 deaths.1 By
February 2022, cases increased to 1,086 and deaths to 47.2 In July 2022, the county had a
population of 7,449 and a poverty rate of 21.3 percent, nearly double the national average.3 During
the early stages of the COVID public health emergency, the county encountered shortages of
medical equipment, supplies, and public health employees, as well as challenges from inadequate
public infrastructure. Medical equipment and supply shortages emerged due to increased
demand statewide. Public health employee shortages and retention issues were primarily due to
underfunding and employees relocating to areas that offered more competitive wages and a better
socio-economic environment. Additionally, the county’s EMS Director stated that the number of part-
time EMS employees decreased from 18 to nine, and that it was challenging to fill the vacancies
due to the county’s low wages. The county also encountered challenges due to its inadequate
infrastructure. For example, the 180 miles of unpaved, sandy roads throughout the community
made it challenging for EMS vehicles to access and provide emergency services during the public
health emergency.
The city of Buena Vista, GA (Buena Vista or the city), located within Marion County, faced challenges
addressing food insecurity of vulnerable demographic groups and enforcing state ordinances
during the public health emergency. The city mayor stated that Buena Vista leveraged its recreation
department to deliver meals to homes of children who were dependent on the city’s summer food
service program and were unable to obtain meals in person during this period. The city mayor also
stated Buena Vista struggled to enforce state ordinances due to a limited operating budget, which
challenged the city’s ability to erect social distance barriers in public facilities and made it difficult
for law enforcement to ensure that the public adhered to state ordinances.
A nonprofit senior-living campus located in Buena Vista offered memory care, skilled nursing, and
rehabilitation to senior citizens. Campus officials stated that caring for COVID-positive patients
was a challenge during the early phase of the pandemic because of an increase in labor costs and
COVID testing and PPE supply costs. Campus officials explained that CRF award funds arrived at a
1 Georgia Department of Public Health COVID-19 reports, as of October 25, 2021.
https://westcentralhealthdistrict.com/wp-content/uploads/2021/10/Marion-4.pdf
2 Marion County Health Department totals for Marion County as of February 28, 2022.
3 U.S. Census Bureau population estimates as of July 1, 2022.
https://www.census.gov/quickfacts/fact/table/marioncountygeorgia/PST045222#PST045222
Pandemic Response Accountability Committee 5
time when the campus was in desperate need for a cash-flow infusion to offset COVID public health
emergency expenditures.
Program Information
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) established the CRF program
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”) to assist with necessary expenditures incurred due to the
COVID pandemic.4 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.5 CRF payments allowed
prime recipients, subrecipients, and beneficiaries to provide fast and direct economic assistance
to impacted workers, families, small businesses, and industries in response to the pandemic. For
example, CRF funds 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 COVID-19; (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).6 Prime recipients
were responsible for reporting their CRF award expenditures to Treasury on a quarterly basis during
the covered period in GrantSolutions.7
The State of Georgia’s responsibilities as a prime recipient included, but were not limited to,
providing guidance to subrecipients and beneficiaries, reiterating federal requirements, and
reviewing subrecipient and beneficiary expenditure reports to assess compliance with CRF
eligible use requirements. Georgia’s Office of Planning and Budget and the State Accounting
Office of Georgia oversee the regulatory compliance of CRF disbursement, expenditures, and
reporting of Georgia’s 159 counties, including Marion County. At the local level, the Georgia
4 Title V of the CARES Act, P.L. 116-136 (March 27, 2020), 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 program. The U.S.
territories are as follows: United States Virgin Islands, Guam, American Samoa, Puerto Rico, and Commonwealth of the Northern Mariana
Islands.
5 A subrecipient is an entity that received CRF payments from a prime recipient that received a CRF award directly from Treasury. Subrecipients
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 subrecipients but are 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 a definition of the grant
reporting system).
6 The Consolidated Appropriation Act, 2021, P.L. 116-260 (December 27, 2020), amended the CARES Act by extending the covered period for
all CRF recipients to use CRF award funds for eligible costs from December 30, 2020 to December 31, 2021. The covered period for Tribal
governments was further extended from December 31, 2021 to December 31, 2022, by the state, local, Tribal, and Territorial Fiscal Recovery,
Infrastructure, and Disaster Relief Flexibility Act, Division LL, Section 104 of the Consolidated Appropriations Act, 2023, P.L. 117-328,
December 29, 2022, 136 Stat. 4459.
7 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 6
Health Care Association, Georgia Municipal Association, and Department of Community Affairs
liaisons collaborated, prioritized, and disseminated guidance on CRF eligible use requirements to
subrecipients and beneficiaries.
Program Impact on the Community
As of September 30, 2022, Treasury disbursed approximately $3.5 billion in CRF award funds to
Georgia, which then awarded $502,822 to two subrecipients (Marion County and the city of Buena
Vista) and one beneficiary (a nonprofit senior-living campus in Buena Vista) geographically located
in Marion County. The two subrecipients and the beneficiary selected for review expended all CRF
award funds to assist the local communities with overcoming pandemic impacts. For detailed
review, Treasury OIG selected a sample of $463,987 (92 percent) of $502,822 in CRF award
expenditures to determine whether the funds were used in compliance with the program’s goals
and objectives.
The selected CRF subrecipients and beneficiary used the funds to cover EMS and law enforcement
salaries and benefits, purchase PPE and COVID testing supplies, and support food programs.
Additionally, based on Treasury OIG’s analysis of the sample expenditures, CRF award funds were
used in compliance with the program’s goals and objectives of preventing and mitigating the
impacts from the COVID public health emergency. The selected subrecipients and beneficiary
complied with the CARES Act, Treasury’s CRF guidance, and Treasury OIG’s guidance.8
Marion County
As of September 30, 2022, Georgia distributed $330,104 in CRF award funds to Marion
County, which expended all the funds. Prior to receiving the funds, the county’s EMS experienced
challenges providing emergency services to the community due to staff attrition and the spread of
COVID among personnel. The county used CRF award funds for EMS payroll and benefits.
City of Buena Vista
As of September 30, 2022, Georgia distributed $75,229 in CRF award funds to Buena Vista,
which expended all the funds. Prior to receiving the funds, the city struggled with enforcing
COVID public health ordinances and providing food program services to the community due to a
limited operating budget. The city used CRF award funds to cover the payroll and benefits of law
enforcement personnel, maintain regular operations, and support food programs. Buena Vista
utilized law enforcement and the zone and code enforcement personnel to ensure that the public
and businesses adhered to Georgia COVID public health emergency ordinances. They also erected
safety barriers in public facilities for social distancing. Additionally, they delivered meals to children
relying on food programs.
8 Department of the Treasury Office of Inspector General Coronavirus Relief Fund Frequently Asked Questions Related to Reporting and
Recordkeeping (OIG-CA-20-028R, March 2, 2021). The CARES Act provides Treasury OIG the responsibility for monitoring and oversight of
the receipt, disbursement, and use of CRF award funds. Treasury OIG also has authority to recover funds if it is determined recipients failed
to comply with the CRF use of funds requirements at 42 U.S.C. 801(d). Treasury OIG provided recipients reporting and record retention
requirements.
Pandemic Response Accountability Committee 7
Nonprofit Senior-Living Campus
As of September 30, 2022, Georgia distributed $97,489 in CRF award funds to a nonprofit
senior living campus in Buena Vista, which expended all the funds. The campus officials stated
they experienced a cash-flow shortage during the COVID public health emergency due to the
increasing cost of medical supplies. Campus officials used CRF award funds to cover expenditures
such as COVID testing and PPE. They prioritized purchasing COVID tests and lab tests to prevent and
mitigate the spread of COVID among employees working closely with COVID positive residents and
the rest of the staff and residents. Additionally, campus officials stated CRF award funds enabled
them to offset the rising cost of PPE caused by price gouging.
Participant Experience
Satisfaction
Both subrecipients and the one beneficiary selected for review expressed overall satisfaction
with the amount and timeliness of the allocation of CRF award funds. Buena Vista and Marion
County officials expressed that they may not have been able to pay for necessary expenditures
associated with the COVID public health emergency, such as PPE and COVID tests, without the
funding. Buena Vista officials were thankful for the funding to cover emergency personnel’s
salaries and wages and to supplement the city’s food programs, as dependency on the programs
substantially increased during the public health emergency. The nonprofit senior-living campus
officials stated the funding was timely and beneficial as they were experiencing a cash-flow
shortage, and they were able to obtain PPE and COVID tests for employees working in close
proximity to COVID positive patients.
Challenges
The selected subrecipients and beneficiary located in Marion County expressed that they had
a difficult time understanding CRF requirements and guidelines. Buena Vista officials stated
they were confused about the process to request funds from the state, which made them hesitant
to use CRF award funds. Buena Vista officials also believed that they could have benefited from
having a liaison such as a regional commission, which could provide rural communities with direct
guidance on requesting funding, identifying eligible uses of funds, and understanding federal and
state guidance and reporting procedures. The nonprofit senior-living campus officials expressed
that they relied on their own inference and external independent auditors to determine proper uses
of the CRF award funds due to the unclear and constantly changing guidance. Additionally, Marion
County officials explained that they faced unmet needs,
such as being unable to upgrade broadband services in the
FOR MORE INFORMATION county that would enable community residents to participate
For more information about Coronavirus in county meetings while social distancing. Buena Vista
Relief Fund program spending across officials also stated that rural communities faced greater
the country, visit the PRAC’s website, challenges obtaining funds in comparison to larger
including an interactive dashboard. communities.
Pandemic Response Accountability Committee 8
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 ED “to
prevent, prepare for, and respond to coronavirus, domestically or internationally.”9 The CARES Act
also created the ESSER program—a subprogram of the Education Stabilization Fund. The ESSER
program received funding through three pandemic-related laws, and each law created different
rounds in the program’s implementation. Each round varied in funding totals, program expiration
dates, and planning or reporting requirements. To support schools, ED first provided ESSER funding
to state education agencies, which then provided funds to the local education agencies (i.e., local
school districts).10
• 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 the pandemic had on elementary and
secondary schools across the country. ESSER I funds were intended to help schools safely
reopen, sustain safe operation, and address the pandemic’s impact on students.
• ESSER II: A second round of ESSER funding came from the Coronavirus Response and Relief
Supplemental Appropriations Act, 2021, and provided $54.31 billion. ESSER II funds were to
be used for the same purpose as ESSER I funds.
• ESSER III: A third round of ESSER funding came from the American Rescue Plan 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 agencies “within a reasonable timeline determined
by the [state education agency]” on the use of the funds, how it would engage and consult
with stakeholders when developing its plan, and how it intended to make the plan publicly
available. Each local education agency was also required to develop a plan for the safe return
to in-person instruction and continuity of services.11
The PRAC team worked closely with ED OIG to identify total awarded and expended ESSER funds.
9 See CARES Act, P.L. No. 116-136, Division B, Title VIII, (March 27, 2020).
10 State education agencies also reserved funds in accordance with the guidance described in the U.S. Department of Education’s ESSER and
GEER Use of Funds FAQs; December 7, 2022. See questions A-8 through A-12.
11 See ED’s ESSER and GEER Use of Funds FAQs from December 7, 2022, question A-4.
9
During phase one of this review, we found that the local education agency within the boundaries
of Marion County was awarded almost $7.6 million in ESSER funds and had spent around $1.4
million of these funds as of September 30, 2021. ESSER funds were distributed through the state
education agencies to the local education agencies. See Table 1 for more information.
Table 1: Marion County, GA, ESSER Funding Information, as of September 30, 2021
Total Awarded Total Spenta Expiration Date
ESSER I $515,064 $507,503 9/30/2022
ESSER II $2,224,291 $674,960 9/30/2023
ESSER III $4,894,884 $265,475 9/30/2024
Total $7,634,239 $1,447,938 -
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
The Marion County School System, the only public school district in the county, has two schools
consisting of approximately 1,350 students. The school district operates under the guidance of a
school board elected by the voters and a superintendent appointed by the board.
As shown in Table 2, Marion County Schools spent
most of the three ESSER rounds of funds on MARION COUNTY SCHOOLS
salaries and benefits to ensure continuity of core
staff and services, as well as teacher bonuses to
OPERATING STATUS
help retain staff. Educational materials purchased End of 2020 School Year
included student devices (i.e., laptops or tablets), Virtual after March 16.
software licenses, and instructional materials. The
school system also made building improvements, 2020–2021 School Year
including updating HVAC systems and water Hybrid – Parents decided if they wanted their
fountains—specifically, purchasing additional water child to attend in-person or virtually. At times, the
fountains as well as filters for existing fountains to school district had to transition from in-person to
reduce potential contaminants and transmission of remote learning.
pathogens that can lead to the spread of COVID-19. 2021–2022 School Year
This was an important area of concern for school
In-person only.a
officials to address because they previously shut
down schools due to water sanitation concerns
prior to the pandemic. a Exceptions included: blended learning continued as before
COVID-19, Georgia virtual school for classes not offered by
the school district, and alternative school.
Pandemic Response Accountability Committee 10
Table 2: ESSER Spending Categories for Marion County Public Schools
Description Spent
Salaries and Benefits $804,530
Building Improvements $280,134
Educational Materials Including Devices and Software $311,186
Personal Protective Equipment $35,085
Other $17,003
Total $1,447,938
We spoke with officials about future needs and the local school district’s overall response
throughout the pandemic. We also reviewed their ESSER III plan, which was required by ED. Under
ESSER III requirements, at least 20 percent of funds must be spent on mitigating lost instructional
time. According to the Marion County Schools’ ARP Act plan (ESSER III plan), the school district
sought to address lost instructional time with the following activities:
• Class size reduction (to allow for smaller student-to-teacher ratios)
• Extended school day
• High-frequency tutoring
• Summer programming
• Intern partnership with an institution of higher education
• Social-emotional learning materials
The superintendent explained that while ESSER funding could be used to hire and pay for new
staff, the school knew it would no longer be able to pay for them once the additional funding was
gone. As the superintendent noted, hiring for temporary jobs is difficult. To supplement staff without
hiring, the school worked with an institution of higher education within the community to create
an expanded internship partnership in which student teachers from the institution were allowed to
teach at the school and supplement existing staff on a year-to-year basis.
Participant Experience
A Marion County School official stated that at the onset of the pandemic, it was thought that COVID
would only result in an extended spring break and that students would return after their spring
break in April 2020. During April 2020, school officials realized the pandemic would be a long-term
challenge. School officials noted two additional challenges, the first being that people were fearful
to go into the schools to meet in-person due to the health risks of COVID. The second challenge was
that it was difficult to provide education to students who had internet connectivity issues. These
Pandemic Response Accountability Committee 11
challenges made it difficult to get assignments to students and grade them. Originally, assignments
were placed in plastic bags to be delivered to families. The COVID funding allowed Marion County
Schools to purchase hotspots and devices for students so that they could be given their assignment
virtually and learn in a remote environment.
Overall, officials at the Marion County School district believed that the guidance they received from
the Georgia Department of Education was clear. However, they felt they didn’t receive guidance fast
enough to make timely decisions.12 According to the Georgia Department of Education, it updated
guidance for the local education agencies as it was made available from ED. Marion County School
district staff also stated that the State of Georgia did issue technical guidance to the school districts
and offered project managers to assist them with the interpretation of the guidance.
SPOTLIGHT ON | FEEDING STUDENTS DURING THE PANDEMIC
While schools across the nation closed, students continued to have nutritional needs during the
regular school day during the pandemic. In response, the U.S. Department of Agriculture granted
schools more flexibility to feed 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
From May through August 2020, Marion County Schools participated in a grant program called
Meals-to-You that was operated by the partnership between USDA and Baylor University, an
institution of higher education. This grant program provided services to the school at no cost and
delivered boxes of food to the home addresses of the households enrolled in the program every
other week. To participate, families with eligible students were required to enroll with the institution
of higher education. Each box contained 10 breakfasts and 10 lunches or dinners for each child in
the household; 368 households participated in the program.
The Marion County Schools used kitchen staff to prepare and package food. Bus drivers delivered
these packages to students.
a U.S. Department of Education, Elementary and Secondary School Emergency Relief Programs and Governor’s Emergency Education Relief
Programs, Frequently Asked Questions, May 2021.
FOR MORE INFORMATION
For more information about the Education Stabilization
Fund, including Elementary and Secondary School 12 A U.S. Department of Education official told us they provided
guidance in December 2021 on what costs tied to COVID-19 meant.
Emergency Relief program spending across the See Fact-Sheet_COVID_connection_12.29.21_Final.pdf (ed.gov).
country, visit the PRAC’s website. December 2021.
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. The closures had
negative impacts on the food supply chain from farmers and other producers to distributors, food
services, and hospitality entities. As a result of these supply and logistical issues, and reports of
produce rotting in fields, the 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. The distributors would purchase the food, box it, 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.13 USDA contracted directly with distributors to administer
five rounds of the Food Box Program. According to USDA, this program delivered approximately
176 million food boxes worth $5.47 billion to nonprofit and governmental organizations from
May 2020 to May 2021.
Figure 1: Three Primary Goals of the Food Box Program
Providing an alternative outlet Helping Food Distributors that Providing food to families in
for domestic Food Producers supply and distribute food to need by delivering food boxes to
(e.g., farmers) faced with retain jobs that could have governmental and nonprofit Food
declining demand because of been lost because of closures Recipient Organizations that
closures of food service entities. of food service entities. gave the food to families in need.
13 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.
13
Program Impact on the Community
To perform our work, the PRAC team used data previously collected and analyzed by USDA OIG 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
that 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 4,676 boxes (valued at $206,668) to two food
box recipient organizations to feed families in the Marion County community.14 See Table 3 for
information about the two organizations that both participated in round two of the USDA food box
program.
Table 3: Food Boxes Distributed to Marion County, GA
Food Recipient Number of Food Type of Food Boxes
Round Number Value
Organization Boxes Delivered
Food Recipient
5 1,062 $35,975 Dairy Products Box
Organization 1
Food Recipient
3 3,614 $170,693 Dairy Products Box
Organization 2
Totals 4,676 $206,668
Source: USDA OIG analysis of USDA data on the Food Box Program.
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 Marion 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 Marion 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 Marion County.
14 Estimate is limited to incomplete data provided by USDA, which did not collect complete data to identify food source, or recipients of food boxes
received. In addition, the PRAC never received responses to our requests to visit a food recipient organization. As a result, we did not visit one
for this report.
Pandemic Response Accountability Committee 14
According to a Government Accountability
Office (GAO) report, USDA did not collect data
to evaluate whether the Food Box Program met LEARN MORE ABOUT THE FOOD
some of its primary goals—including assisting BOX PROGRAM
food producers with declining demand.15 Similarly,
USDA OIG and the Governmental Accountability Office
the PRAC observed a lack of data in our work,
(GAO) have released reports and data stories about
which limited our ability to determine the extent
the Food Box program:
to which USDA met the Food Box Program goals
in Marion County. Under the program structure set USDA OIG, COVID-19—Farmers to Families Food Box
up by USDA, the food distributors must include an Program Administration, Rpt. No. 01801-0001-22,
invoice detailing the number, type, and cost of the August 15, 2023
food boxes delivered, with high-level information
of the nonprofit and governmental organizations USDA OIG, COVID-19—Farmers to Families Food Box
receiving boxes. However, USDA did not require Program Administration—Interim Report, Rpt. No.
the food distributors to maintain producers’ (i.e., 01801-001-22(1), June 24, 2022
farmers’) information or governmental organizations
USDA OIG, USDA Farmers to Families Food Box
to maintain recipients’ (i.e., families’) information Program Data Story, June 22, 2022
for tracking and reporting purposes.
GAO, USDA Food Box Program: Key Information
and Opportunities to Better Assess Performance,
Participant Experience GAO-21-353, September 8, 2021
Because USDA did not collect contact information
for either the food producers or food box recipients, we could not identify recipients to meet with
and gather their feedback and user experiences. As a result, we could not determine how the Food
Box Program impacted families and individuals in the Marion County, GA, community.
15 GAO, USDA Food Box Program: Key Information and Opportunities to Better Assess Performance, GAO-21-353; September 2021.
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 also 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,
2021.16
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 the state UI (regular UI) or PUA, and 1.5 billion continued claims were
submitted for regular UI, PUA, or PEUC.17
The Marion County, GA, unemployment rate was marginally impacted by the COVID pandemic. The
U.S. Bureau of Labor Statistics estimated the unemployment rate in Marion County peaked in
April 2020 at 7.2 percent—24 percent greater than the prior year’s highest monthly rate (see
Table 4).
16 The state of Georgia ended its participation in the pandemic-related UI programs on June 26, 2021, prior to the programs’ statutory expiration
of September 6, 2021.
17 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.
16
Table 4: Marion County, GA – Unemployment Estimates
Marion County Marion County
Average Highest Monthly Georgia Average Georgia Highest
Unemployment Rate Unemployment Rate Unemployment Rate Unemployment Rate
Year (%) (%) (%) (%)
2018 5.2 6.0 4.0 4.5
2019 4.4 5.8 3.6 4.3
2020 5.0 7.2 6.5 11.9
2021 3.6 4.4 3.9 5.1
Source: DOL OIG analysis of the U.S. Bureau of Labor Statistics data.
In addition to regular UI, Georgia reported 824 unemployed workers in Marion County received
about $7,336,429 in federal UI benefits from FPUC, PUA, and PEUC (see Table 5).18
Table 5: Marion County, GA – CARES Act UI Benefits
CARES Act UI Program Total Benefits Paid
FPUC provided a $600 weekly supplement through July 31, 2020. FPUC
$5,229,782
resumed in December 2020 with a $300 weekly supplement.
PUA extended UI benefits to individuals not traditionally eligible for UI benefits,
$1,414,695
such as self-employed workers.19
PEUC provided additional weeks of UI benefits to individuals who had
$691,952
exhausted their regular unemployment benefits.
Total Benefits $7,336,429
Source: DOL OIG data analysis of Georgia state workforce agency claims data for the period March 27, 2020, to June 26, 2021.
18 State workforce agencies provided DOL OIG data about pandemic UI-related programs as part of a data disclosure process. The Georgia state
workforce agency provided this data as of February 9, 2022.
19 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.
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.20
State workforce agencies would then assess eligibility and provide the claimant with the applicable
regular UI or CARES Act UI program payments, or both, for each week certified by the claimant.
Participant Experience
CARES Act UI Program Participant Assessment
To assess the new CARES Act UI programs (FPUC, PUA, and PEUC), DOL OIG judgmentally selected
60 Marion County residents (claimants).21 DOL OIG investigators traveled to the area, confirmed
the individuals filed a UI claim, and performed in-person interviews with the claimants. Of the 60
claimants, 12 (20 percent) who received benefits from at least one of the three key pandemic UI
programs chose to respond. In Georgia, employers are permitted to file UI claims for employees. As
a result, claimants with an employer-filed claim were not asked certain questions, which is indicated
with an asterisk (*) in Figure 2 and Figure 4. The surveys were conducted November 14–18, 2022.
DOL OIG’s deliberative process for this project’s sample selection included removing possible
fraudulent claims to ensure interviews of only eligible UI claimants. To do so, DOL OIG used
fraud indicators. This removal also ensured that DOL OIG investigators did not impact ongoing
investigations or interact with possible subjects or targets of future DOL OIG investigations.
20 FPUC is provided as a supplement (add-on) benefit to an underlying UI payment, such as regular UI, PEUC, or PUA. Claimants did not file a
separate claim for FPUC benefits. FPUC benefits were added if the individuals met the eligibility requirements for the underlying week claimed.
21 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 18
Satisfaction with Key CARES Act UI Programs Was High—Both Overall and
with Specific Components
Generally, most surveyed claimants reported 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.22 Overall, satisfaction with the UI system was rated 3.6
on a 5-point scale, with 10 percent of surveyed claimants rating their experience as extremely
satisfying (see Figure 2).
One surveyed claimant reported they had difficulty with the forms and could not receive help
via phone calls. An interview with representatives from the regional state workforce agency
identified that, during this period, the office processed more UI claims than in the prior eight years
combined.23 The office was receiving 75 to 100 calls per day. Additionally, there were technological
issues associated with surveyed claimant identity verifications and sending payments to the correct
address.
22 Surveyors asked claimants a series of questions and claimants responded with a 5-point scale where one was extremely dissatisfied and five
was extremely satisfied.
23 DOL OIG and PRAC audit teams interviewed officials at the Georgia Department of Labor Career Center in Americus, GA, which is part of a
network of statewide career centers. The Georgia Department of Labor provides employment services through these centers.
Pandemic Response Accountability Committee 19
Figure 2: Surveyed Claimants Assessment of Claims Process
Source: DOL data analysis of claimant surveys conducted November 14–18, 2022.
Surveyed Claimants Generally Felt the CARES Act UI Programs Were
Impactful, Sufficient, and Fair
Most 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
necessities, and were fair and reasonable (see Figure 3).24 The surveyed claimants also agreed
24 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
or strongly agreed that the number of weeks benefits were provided was sufficient. On average, 8
percent of surveyed claimants felt the benefits did not have a positive impact, were insufficient, or
were not fair and reasonable.
The interview with regional state workforce agency officials noted that some employers felt
claimants could earn more by collecting UI and, therefore, would not return to work. However, the
regional state workforce agency noted there were also labor shortages prior to the pandemic.
Figure 3: Surveyed Claimants Assessment of Benefits
Source: DOL data analysis of claimant surveys conducted November 14–18, 2022.
Pandemic Response Accountability Committee 21
Surveyed Claimants Generally Still Experienced Difficulty in the Labor
Market
Of those who responded, 25 percent of surveyed claimants reported they were not currently
working for pay, and 60 percent reported they were unable to find employment before benefits
ran out (see Figure 4).
Additionally, 100 percent of surveyed claimants reported the state workforce agency did not assist
them with finding employment. The survey did not address whether claimants were aware of the
state workforce agency’s job placement services. However, Employment and Training Administration
officials reported that, during the pandemic, initial claims for federal and state programs rose to 10
times pre-pandemic levels, far higher than state systems were designed to handle. Furthermore,
an interview with regional state workforce agency officials identified that staff had to switch from
employment services to assist with processing claims.
Figure 4: Surveyed Claimants Return to Work Assessment
Source: DOL OIG data analysis of claimant surveys conducted November 14–18, 2022.
Pandemic Response Accountability Committee 22
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
12.5 percent of the claims submitted from Marion County as potentially fraudulent (see Table 6).25
Table 6: Marion County, GA – Fraud Indicators26
Category Claimants Percent of Total Amount Paid
Total Claimants 824 - $7,336,429
Claimants with Fraud Indicator:
Multistate 40 4.9% $521,595
Suspicious Email 73 8.9% $876,400
State Flagged -a -a -a
Deceased Person -a -a -a
All Preceding Fraud Indicators
(claimants with multiple indicators were 103 12.5% $1,273,149
only included once to avoid duplication)
Source: DOL OIG data analysis of state workforce agency claimant claims data for the period March 27, 2020, to June 26, 2021.
a
No fraud indicator identified.
Prior to the release of this report, potentially
fraudulent claims were referred to DOL OIG’s Office FOR MORE INFORMATION
of Investigations to assess and determine if the
For more information about unemployment
claims warrant investigation. If the claims did not
warrant investigation, DOL OIG referred them to the insurance programs during the pandemic, visit
state workforce agency. the PRAC’s website.
25 Please note that potentially fraudulent claims are based on data analytics and have not been investigated, adjudicated, or confirmed as fraud
by a state UI agency. Flagged transactions may not be fraudulent, and not all fraudulent transactions may be flagged. More generally, these
types of potential fraud measures can be used to identify transactions that may be indicative of potential fraud. They cannot, though, be
interpreted directly as measures of the extent of fraud in any specific geographic area.
26 The DOL OIG created fraud indicators 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 used an email address indicative
of common fraud tactics. Also flagged were claimants with Social Security numbers of a person that was deceased. Additionally, the state
workforce agency flagged certain claimants as potentially fraudulent. It is important to note that this does not assume the potential fraud was
committed by citizens of this area.
Pandemic Response Accountability Committee 23
PROGRAM SNAPSHOT
Public Housing Operating
Funds – CARES Act
U.S. Department of Housing and Urban
Development
Marion County in Southern Georgia is about 35 miles east of Columbus, GA. The county seat, Buena
Vista, is also home to the county’s only public housing agency (PHA), the Buena Vista Housing
Authority (the Authority). The Authority did not experience any major challenges due to COVID-19. It
was considered an essential function and as such kept its office open with some modifications. The
Authority modified some procedures to accommodate residents who preferred to limit their contact
with others and potential exposure to the virus. For example, it required appointments for office
visits, maintenance employees went into units for emergencies only, and board meetings were
conducted virtually. The Authority also protected its employees and residents by installing shields
and requiring masks and social distancing.
The Public Housing Operating Fund provides an operating
subsidy to assist PHAs in serving low-, very low-, and CLEAR GUIDANCE AND
extremely low-income families in the operation and TECHNICAL SUPPORT
management of public housing. The operating subsidy
amount that a PHA receives each year is determined by a HUD provided PHAs with several resources
formula. Eligible uses for these funds include, but are not to ensure that the CARES Act supplemental
limited to: operating funds were used as intended.
HUD issued notices, published frequently
• Management and operation of public housing units, asked questions on its website, and held
including the cost of review by an independent auditor. calls with PHAs to provide guidance on the
allocation and eligible uses of the funds.
• Routine preventive maintenance. The Authority’s chief financial officer (CFO)
• Anticrime and antidrug activities. stated that they relied on HUD’s Public
Indian Housing (PIH) notices for guidance
• Rehabilitation and development of public housing on eligible uses for the funds. They believed
units. that guidance was clear and easy to find.
The CARES Act, signed into law on March 27, 2020, provided
an additional $685 million in supplemental operating funds.
The CARES Act required that HUD allocate the funds to PHAs using the same formula as ordinary
operating funds. The CARES Act also expanded eligible uses for these funds to include activities
to prevent, prepare for, and respond to COVID, including to provide additional funds for PHAs to
Pandemic Response Accountability Committee 24
maintain normal operations and take other necessary actions during the period in which the
program was impacted by COVID.
As of September 30, 2021, HUD had provided $36,366 in supplemental operating funds to the
Authority, and the Authority had spent all the funds by December 31, 2020.
HUD provided PHAs with several resources to ensure that the CARES Act supplemental operating
funds were used as intended. HUD issued notices and published frequently asked questions
on its website, and the local field office provided additional guidance and reminders via email.
Additionally, 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.27 Examples of eligible use include, but are not limited to, sourcing and
purchasing PPE for PHA staff and costs related to maintaining adequate social distancing.
Program Impact on the Community
HUD OIG’s review found that the Authority used its CARES Act supplemental operating funds in
alignment with program goals and objectives, which were to prevent, prepare for, and respond
to COVID. The Columbus Housing Authority contractually manages the Authority. The Authority
received $36,366 in supplemental operating funds for its 79 units. Also, the Authority has a local
office staffed by a general manager, housing manager, and three maintenance employees.
The CARES Act supplemental operating funds allowed the Authority to maintain normal operations
and purchase supplies to reduce the spread of the coronavirus. The Authority stated that its rental
income diminished after the county implemented an eviction moratorium. Many residents applied
for hardships to reduce their rents or stopped paying altogether. This resulted in a budget shortfall
for the Authority as the budget was based on residents paying their pre-pandemic portion of rent.
Therefore, the Authority used its CARES Act supplemental operating funds primarily to continue
normal operations. Specifically, it used the funds to pay maintenance staff, purchase appliances,
and purchase various other supplies necessary to maintain the properties. The Authority also
purchased supplies, such as gloves and disinfectant wipes, to help reduce the spread of COVID.
Participant Experience
Overall, the Authority’s chief financial officer (CFO) believed the Authority’s biggest accomplishment
was maintaining normal operations and providing constant communication and reassurance
to its residents. The CFO also believed that the Authority could have used additional CARES Act
supplemental operating funds. The additional funds could have been used to provide COVID testing
for the Authority’s residents and to further supplement its operating funds, which were impacted
by its inability to collect rents after the county implemented an eviction moratorium. The Authority
stated that it relied primarily on HUD’s Office of Public and Indian Housing notices for guidance on
eligible uses for the funds and believed the guidance was clear and easy to find.
27 The Public Housing Capital Fund program provides funds to PHAs to modernize public housing developments.
Pandemic Response Accountability Committee 25
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.28 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.29
The Marion County nursing home in the U.S. Department of Health and Human Services (HHS)
OIG’s sample has had substantial financial challenges in responding to the pandemic.30 The
nursing home’s leaders, including chief executives from the nursing home’s chain that included
several other facilities, described lost revenue because the facilities had fewer residents during the
pandemic. The nursing home Administrator explained that the nursing home closed admissions of
new residents during COVID outbreaks. Chief executives said that staffing shortages also limited the
number of residents the nursing home chain could admit, and that changes to hospital discharge
patterns resulted in fewer short-term stays at the chain’s nursing homes following elective
procedures.
Nursing home leaders reported that, while revenue
INCREASED COSTS RELATED declined, expenses increased. Leaders reported that
TO COVID-19 significant increases in staffing costs were one of the
biggest financial challenges. They attributed the increased
Staffing shortages increased the use of costs to shortages of nurses and other staff. Leaders and
contracted agency staff who were three staff explained that the pandemic exacerbated existing
times more expensive than in house staff. staffing shortages because staff left the facility or were
unable to come to work while caring for their children
during COVID-related school closures. Staffing shortages
caused the nursing home to rely on contracted agency
28 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.; and, Lauren Weber, "Nursing Homes Keep Losing Workers," The Wall Street Journal, August 25, 2021.
29 Centers for Medicare & Medicaid Services (CMS), COVID-19 Nursing Home Data.
30 For the purposes of HHS OIG’s review, the term “nursing home” refers to the facility in its sample regardless of technical status (i.e., nursing
facility and/or skilled nursing facility [SNF]) according to common use.
26
staff who chief executives said cost $120 per hour compared to $35 per hour for permanent staff
working the same shift. They reported incurring other labor-related expenses linked to hazard pay
and bonuses for staff. Nursing home leaders and staff also described increased costs for other
COVID and care-related needs not related to staffing, such as testing, PPE, and other supplies.
For example, the Administrator said the cost of a case of gloves increased from less than $100 to
almost $500. Facility staff described significant costs for food, cleaning chemicals, mattresses, and
paper products. One staff member said that the cost of linen bags increased from $77 to $177.
Nursing home leaders and staff reported both personal and operational challenges to providing
care during the COVID pandemic. Leaders and staff said that early in the pandemic they faced
fear and uncertainty surrounding COVID. The Chief Operating Officer explained that the facility’s
community experienced one of the country’s first COVID outbreaks, and the Administrator said staff
were afraid of contracting the virus or bringing it home to their families. Leaders and staff said
ongoing circumstances created by the pandemic took a physical and emotional toll on them. The
Administrator explained that extra COVID-related duties—such as data entry, donning and doffing
PPE, and conducting testing during outbreaks—were “a lot of extra work” and anxiety-inducing. The
Administrator said that staff struggled emotionally with taking care of and losing long-term residents
with whom they had formed close bonds. It was also challenging for staff to keep residents and
family members apart when COVID-related visitation restrictions were in place. A staff member
explained that nurses were burned out from working long hours during the pandemic, and that
some were suffering from post-traumatic stress disorder. Leaders and staff said that some staff left
the nursing home as the pandemic continued due to fear and burnout or because they accepted
higher paying jobs with staffing agencies or left the health care industry altogether.
Nursing home leaders and staff reported that residents experienced severe strain during the
COVID pandemic. Nursing home leaders reported that at times during the pandemic residents
were confined to their rooms and unable to participate in social gatherings such as communal
dining and activities. A staff member said that isolation and separation from other residents and
visitors caused some residents to become depressed, which led to an increase in the dispensing of
antidepressants in the facility. One leader said that residents “bore the brunt, sadly, of all of this.
The effects of isolation and the decrease in socialization probably had the greatest effect on all
the residents.” Leaders and staff described facility efforts to lessen the impact of the pandemic on
residents’ mental health. The Administrator said the facility used laptops so that residents could
meet virtually with loved ones. Staff said they worked diligently to provide activities when possible,
such as going room to room to do exercises or playing bingo from a hallway to “keep residents
motivated.”
Pandemic Response Accountability Committee 27
Program Information
To reimburse health care providers for pandemic-related expenses and lost revenue, Congress
appropriated $178 billion to HHS during 2020 and 2021.31 To administer the funds, HHS
established the PRF and related programs.32 The Health Resources and Services Administration
(HRSA) is the HHS agency responsible for administering the PRF program.33 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 challenges, such as
those highly impacted by COVID or serving high-need and vulnerable populations (e.g., nursing
homes).34
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
2023.35 For reporting purposes, HHS established periods during which recipients of both types
of PRF distributions had to use and report on the funds (see Table 7).36 In general, recipients had
to use the funds within one year after the payment period ended and report on their use during a
subsequent three-month period.37
31 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).
32 HRSA administered funds for other programs, such as for the Rural Health Clinic COVID-19 Testing and Mitigation Program, alongside PRF.
HHS also used $8.5 billion that Congress appropriated through the ARP Act of 2021 to establish the ARP Rural Distribution as a separate
program to administer payments to providers and suppliers who serve rural enrollees in Medicaid, the Children’s Health Insurance Program,
and Medicare, including nursing homes and certified SNFs. See HHS, news release, “Biden-Harris Administration Begins Distributing American
Rescue Plan Rural Funding to Support Providers Impacted by Pandemic,” November 23, 2021; HHS, news release, “HHS to Begin Immediate
Delivery of Initial $30 Billion of CARES Act Provider Relief Funding,” April 10, 2020.
33 86 Fed. Reg. 40064 (July 26, 2021).
34 HRSA, Past General Distributions, December 2021; and HRSA, Past Targeted Distributions, November 2022.
35 HRSA, Provider Relief, June 2023.
36 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.
37 HRSA, Important Dates for Reporting, May 2023.
Pandemic Response Accountability Committee 28
Table 7: 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 could 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).38 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.39 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-19.40 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
38 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.
39 HRSA, Past Targeted Distributions, November 2022; CMS, Medicare Coverage of Skilled Nursing Facility Care, July 2019.
40 HRSA, Acceptance of Terms and Conditions, Skilled Nursing Facility Relief Fund Payment Terms and Conditions.
Pandemic Response Accountability Committee 29
payments to 11,819 facilities.41 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
testing and reporting, and recruiting staff.42
Program Impact
The Marion County nursing home received both general and targeted PRF payments. As of
December 2021, the nursing home had received a total of $504,617 from general and targeted
PRF distributions. Targeted payments included $225,000 from the SNF distribution and $186,958
from NHIC distributions (see Table 8).
Table 8: 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 $225,000
NHIC $4.6 billion $186,958
Otherb $45.3 billionb $92,659
Total $54.7 billionb $504,617
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 distribution are current through
September 2022. PRF payment data for HHS OIG’s sample nursing home are current through December 2021.
b “Other” includes all other payments to nursing homes (i.e., PRF payments made through distributions that are not SNF and
NHIC distributions). HRSA reported to 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. The figure HRSA reported to OIG includes amounts
paid to standalone nursing homes, as well as larger entities that include nursing homes or SNFs, meaning that only a portion
of the funds received by the larger entities may have actually been allocated to the entities’ nursing homes. As a result, the
total amount distributed to nursing homes is less than stated. HRSA also does not publicly report total amounts from other PRF
distributions—other than the SNF and NHIC distribution—that may have gone to those facilities.
The nursing home reported that it spent all the PRF funds distributed to it during the first two
payment received periods and used the money for COVID-related expenses. Leaders for the
chain of nursing homes that included the sample facility gathered input from facility leaders and
determined for which expenses to use PRF. Those leaders also reported the facility’s PRF use to
HRSA.
At the time of HHS OIG’s data collection, the facility was required only to have reported on the use
of PRF payments received during the first three periods (April 2020 through June 2021). HHS OIG’s
41 HRSA, Past Targeted Distributions, November 2022.
42 HRSA, Acceptance of Terms and Conditions, Skilled Nursing Facility and Nursing Home Infection Control Relief Fund Payment Terms and
Conditions.
Pandemic Response Accountability Committee 30
analysis included only facility reports made during the first two periods. Leaders reported that the
nursing home used all the funds it received during the first two periods. Specifically, the nursing
home reported using $457,963 in total PRF payments, including $365,304 in payments targeted
to nursing facilities ($225,000 in SNF payments and $140,304 in NHIC payments) and $106 in
interest earned on PRF payments.43
The nursing home reported using the payments to cover general and administrative expenses and
health care-related expenses. HRSA required providers to report the use of NHIC payments and all
other payments (including SNF payments) separately:
• The nursing home reported using its NHIC payments ($140,304) for general and
administrative expenses ($128,675), such as staffing, and for health care-related expenses
($11,629), such as PPE.
• The nursing home also reported using the other payments it received ($317,659) for general
and administrative expenses ($287,428) and for health care-related expenses ($30,231).
Leaders at the Marion County nursing home said HRSA’s guidance on allowable uses and
reporting requirements was sometimes unclear. The Chief Operating Officer for the nursing home
chain said that although there was a “ton of guidance,” the guidance was not very specific, and
providers often had to infer the allowable uses. An external auditor who conducted audits of the
chain agreed that the guidance was unclear and stated that there was so much guidance that it
was difficult for her client to figure out which resource was relevant while in the midst of importing
data and filling out the report. The CFO explained that “a 90- or 100-page manual [is] a perfect
example of . . . saying, ‘Here’s your manual; it’s here to help.’ The last thing in the facility [that] you
have time to do is sit and try and decipher a technical manual.”
HHS OIG reviewed documentation that generally supported that the nursing home’s reported
use of the funds during the first two reporting periods aligned with PRF goals and objectives.
HHS OIG reviewed the reports the nursing home made to HRSA during the first two reporting
periods, along with summary supporting documentation. HHS OIG did not audit the facility’s
financial reports or supporting documents. HHS OIG observed that the information the facility
reported to HRSA was generally supported by underlying facility data and appeared to align
with allowable uses of the general and targeted distributions. Facility documentation generally
supported that the nursing home used NHIC payments for infection control-related expenses, as
intended. The nursing home was, however, unable to support its use of $106 in interest earned on
infection control payments included in its first report. The CFO told HHS OIG that the staff member
who submitted the first report was no longer with the organization, and without his assistance,
leadership was unable to determine why the $106 was included.
In 2022, HRSA described its plans to review nursing home reports to assess use of PRF
payments. For each reporting period or combination of reporting periods, HRSA planned to select
43 These figures do not match the figures in Table 8 because the nursing home was not yet required to report its use of the remaining
approximately $50,000 during the first two reporting periods.
Pandemic Response Accountability Committee 31
a sample of providers’ reports about how they used the funds to be audited, including reports
from nursing homes. HRSA contracted with audit firms to audit the reports according to a risk-
based strategy to verify compliance with the terms and conditions of the program and recoup
any inappropriately used funds. HRSA also planned to conduct an ongoing analysis of providers’
reported spending, seeking to identify trends in how providers spent PRF payments to provide
services during the pandemic.
Participant Experience
PRF payments have been integral to the nursing home’s pandemic response, according
to leaders and staff representing the Marion County nursing home. Nursing home leaders
reported that the PRF payments were instrumental in responding to the pandemic. They said the
PRF payments allowed them to pay for staffing and bonuses, which helped staff feel appreciated.
Leaders also indicated that the funding enabled them to focus on “infection control, education,
and compliance,” which benefited the residents. The facility Administrator said that it “would have
been difficult to continue” without the PRF payments, and that staff and residents likely would
have been left “unprotected” without the additional funding for purchasing PPE. One leader and a
staff member said that the infection control improvements they made during COVID 19, including
improvements made using PRF, helped the nursing home during flu and other outbreaks in 2021
and 2022.
Facility leaders reported that PRF payments were not sufficient to address long-term costs
related to COVID, and that the facility would benefit from additional relief funding. Leaders
reported that, at the time of HHS OIG’s data collection, the facility was still experiencing increased
costs and lost revenue because of COVID and other factors. For example, the nursing home
Administrator said the facility currently had the highest number of contracted agency staff ever.
Other leaders and staff described ongoing cost increases related to infection control and resident
care, such as mask costs. The CFO added that, at the same time, the nursing home chain was still
experiencing a reduction in residents from short-term stays. The CFO stated that additional funding
would “absolutely” help address the ongoing financial challenges.
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 32
Appendix A: Abbreviations and
Acronyms
ARP Act American Rescue Plan Act of 2021
CARES Act Coronavirus Aid, Relief, and Economic Security Act
CFO Chief Financial Officer
CIGIE Council of the Inspectors General on Integrity and Efficiency
CMS Centers for Medicare & Medicaid Services
COVID-19 Coronavirus disease 2019
CRF Coronavirus Relief Fund
DOL U.S. Department of Labor
ED U.S. Department of Education
EMS Emergency Medical Services
ESSER Elementary and Secondary School Emergency Relief
Food Box Program Farmers to Families Food Box Program
FPUC Federal Pandemic Unemployment Compensation
GAO U.S. 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
NHIC Nursing Home Infection Control
OIG Office of Inspector General
PEUC Pandemic Emergency Unemployment Compensation
PHA public housing agency
PIH Public and Indian Housing
PPE personal protective equipment
Pandemic Response Accountability Committee 33
PRAC Pandemic Response Accountability Committee
PRF Provider Relief Fund
PUA Pandemic Unemployment Assistance
QIP Quality Incentive Payment
SNF skilled nursing facility
Treasury U.S. Department of the Treasury
UI unemployment insurance
USDA U.S. Department of Agriculture
Pandemic Response Accountability Committee 34
Appendix B: Scope and Methodology
Scope
In October 2021, the PRAC along with 10 of our OIG members, initiated a case-study-based review
that sought to identify the federal pandemic response funds provided to select geographic areas,
the purpose of those funds, and if the spending aligned with intended goals and objectives. To
conduct our work, we divided the review into two phases. Phase one sought to determine how much
pandemic funding went to the six selected communities. The final report for phase one, Tracking
Pandemic Relief Funds that Went to Local Communities Reveals Persistent Data Gaps and Data
Reliability Issues, was issued July 6, 2023. Phase two of the review sought to gain more insight
into how the six communities used their pandemic relief funding, if the spending generally aligned
with goals and objectives of the programs and subprograms, and whether the funding helped the
six communities respond to the pandemic. The final insights report for phase two of this review,
Pandemic Relief Experiences: A Focus on Six Communities, was issued 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
Marion 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 respective program goals and objectives. The programs
or subprograms selected for Marion 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
• Public Housing Operating Funds – CARES Act | U.S. Department of Housing and Urban
Development
• Provider Relief Fund Payments to Nursing Homes | U.S. Department of Health and Human
Services
More information about the scope and methodology for phase two of this review can be found in our
March 2024 report.
Pandemic Response Accountability Committee 35
Methodology
We visited Marion County, GA, in December 2022 and conducted interviews with government,
community, and business leaders to discuss the community’s experiences with the pandemic,
federal response and relief funds, federal guidance, best practices, lessons learned, and
suggestions for improvement. The overall methods we used to achieve the objectives included
working with our OIG partners to review laws, as well as program guidelines and background
information. The specific scope and methodology used to review each of the selected programs and
subprograms is provided in the program sections below.
Standards
Each OIG and the PRAC conducted this study in accordance with its own respective processes
and standards to ensure that all the contributions to this report met quality standards issued
in accordance with the generally accepted government auditing standards, the Council of the
Inspectors General on Integrity and Efficiency’s (CIGIE’s) Quality Standards for Inspection and
Evaluation, and internal OIG guidance. All these standards required that we planned and performed
this study to obtain sufficient and appropriate evidence to provide a reasonable basis for the
insights and conclusions. This work was completed between November 2022 and February 2024
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 the subrecipients and beneficiary located in
Marion County (1) used CRF award funds in alignment with program goals and objectives, and (2)
believed that CRF award funds 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 September 30, 2022 (cycle 10). Treasury OIG selected two
subrecipients and one beneficiary for the review, respectively: (1) Marion County, (2) city of Buena
Vista, and (3) a nonprofit senior-living campus. Treasury OIG sampled a total of $463,987 of
$502,822 (four transactions, or 92 percent) of CRF expenditures, representing all payment types,
for the three entities to determine whether they used the CRF award funds in alignment with the
program’s goals and objectives.44
44 Transfers and Grants.
Pandemic Response Accountability Committee 36
To accomplish these objectives, Treasury OIG performed the following activities during engagement
fieldwork conducted from August 2022 through April 2023:
• Reviewed Title VI of the Social Security Act, as amended by Title V of Division A of the
Coronavirus Aid, Relief, and Economic Security Act (CARES Act).45
• Reviewed the Consolidated Appropriations Act, 2021.46
• Reviewed Treasury Guidance and Frequently Asked Questions published in the Federal
Register, Volume 86, No. 10 (January 15, 2021).
• Reviewed the State of Georgia’s policies and procedures for determining CRF eligible use.
• Interviewed subrecipients and beneficiary officials regarding CRF usage, experience, and
impact.
• Reviewed the State of Georgia’s and the nonprofit senior-living campus’s Single Audit Reports
for fiscal years 2020 and 2021 to assess findings that may pose risk to the subrecipients' and
beneficiaries' eligible uses of CRF; there were no Single Audit Reports completed for Marion
County and the city of Buena Vista for fiscal years 2020 and 2021.
• Reviewed the fiscal year 2020 Independent Auditor’s Report on Financial Statements for
Marion County, which included the city of Buena Vista, to assess findings that may pose risk to
the subrecipient’s eligible uses of CRF.
• Reviewed media reports associated with the COVID 19 pandemic and CRF impacts within the
State of Georgia and Marion County.
• Reviewed supporting documentation to determine if the four sample transactions were
(1) necessary expenditures incurred due to the public health emergency with respect to
COVID-19; (2) not accounted for in the budget most recently approved as of March 27, 2020;
and (3) for costs incurred between March 1, 2020, and December 31, 2021. Supporting
documentation included grant agreements, invoices, timesheets, labor distribution reports,
and data extracts from the State of Georgia, Marion County, the city of Buena Vista, and the
nonprofit senior-living campus, as applicable.
Standards
Treasury OIG conducted this engagement in accordance with CIGIE’s Quality Standards for
Inspection and Evaluation.
45 P.L. 116-136 (March 27, 2020).
46 P.L. 116-260 (December 27, 2020).
Pandemic Response Accountability Committee 37
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 Marion County Schools’ use of ESSER funds
(all three rounds of funding) from program inception through September 30, 2021. Our review
objectives were to identify how the local school district used the ESSER funding it received and to
determine whether the local school district 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 Programs and Governor’s Emergency Relief Programs
issued in May 2021 and revised December 7, 2022.
• Obtained summary descriptions of ESSER spending from the school district.
• Determined if the descriptions of the funding uses aligned with ESSER’s objectives of helping
the districts prevent, prepare for, and respond to coronavirus, domestically or internationally.
• Interviewed Marion County district officials, local officials, and Georgia Department of
Education officials about uses of funds as well as the effects the ESSER funds had on the
school district’s 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 38
Farmers to Families Food Box Program | Pandemic
Response Accountability Committee and U.S. Department of
Agriculture, Office of Inspector General
Methodology
Scope | The PRAC and USDA OIG’s review covered the use and impact of the Food Box program
implemented by USDA. We included all five rounds of the program in our review—to the extent that
the data was available, and when boxes were provided to Marion County community from May 15,
2020, though May 31, 2021. Our review objective was to determine whether the program served
producers, distributors, and food recipient organizations in accordance with program goals and
objectives.
Methodology | To try to determine if the program served producers, distributors, and food recipient
organizations in accordance with program goals and objectives in Marion County, we:
• Reviewed multiple federal reports evaluating the Food Box program.
• Obtained and reviewed data showing the number of food boxes sent to food recipient
organizations serving the Marion County community.
We also worked with USDA OIG to obtain data about the total number of food recipients and to
ensure that we fully understood the program objectives and structure. However, the PRAC never
received responses to our requests to visit a food recipient organization. As a result, we did not visit
one for this report.
Data Limitations
We used data collected and analyzed by USDA OIG during part one of this case-study-based review.
Part one introduced data limitations that prevented us from determining if the program served
producers, distributors, and food recipient organizations in accordance with program goals and
objectives.
Standards
We conducted this study in accordance with CIGIE’s Quality Standards for Inspection and
Evaluation.
Pandemic Response Accountability Committee 39
Pandemic Unemployment Insurance | U.S. Department of
Labor, Office of Inspector General
Methodology
Scope | The evaluation covered DOL’s UI response to the COVID-19 pandemic. Specifically, DOL
OIG reviewed federal UI benefits from the following three key CARES Act UI programs: FPUC, PUA,
and PEUC. These three CARES Act UI programs were extended or resumed under the Continued
Assistance for Unemployed Workers Act of 2020 and extended by the ARP Act until September
6, 2021. Three states ended the expanded UI programs early. Specifically, Nebraska and Idaho
ended their programs on June 19, 2021, and Georgia on June 26, 2021. DOL OIG’s evaluation
included any benefits that claimants received from these programs as reported by the states. These
programs were selected based on federal spending research and program funding amounts.
Data Sources | The DOL OIG team assessed UI payments to individuals in the designated
geographic areas based upon UI claims data transfers from state workforce agencies to DOL OIG.
Additionally, the DOL OIG team performed on-site surveys of claimants confirmed to have collected
benefits from FPUC, PUA, or PEUC.
Methodology | To answer the objective, the DOL OIG team reviewed the CARES Act, the Continued
Assistance for Unemployed Workers Act of 2020, the ARP Act, Employment and Training
Administration guidance, Federal Emergency Management Agency guidance, state agreements,
PandemicOversight.gov, and USAspending data. To determine the amount of fraud flags for the
three key CARES Act programs paid in the designated geographic areas, the review team worked
with OIG data scientists to assess claimants in the designated area for several key fraud indicators.
To assess the participants’ experiences with the three key CARES Act UI programs in the designated
geographic areas, DOL OIG judgmentally selected 60 claimants with whom DOL OIG investigators
performed on-site interviews.47 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.
47 Judgmental sampling is a nonprobability sampling technique in which the sample members are chosen based on the auditor’s knowledge and
judgment.
Pandemic Response Accountability Committee 40
Standards
DOL OIG conducted this study in accordance with the Quality Standards for Inspections and
Evaluations issued by CIGIE. Those standards require that DOL OIG plan and perform 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 July 2022 through September 2023. HUD
OIG’s review covered Marion County’s use of supplemental operating funds from program inception
through September 30, 2021. HUD OIG’s review objectives were to determine whether the county
spent the supplemental operating funds in alignment with program goals and objectives and
whether the funds positively or negatively impacted the county’s ability to respond to the pandemic.
Methodology | To accomplish HUD OIG’s review objectives, it:
• Reviewed applicable HUD requirements (HUD notices).
• Interviewed HUD staff to gain an understanding of HUD’s goals and objectives for the Public
Housing Operating Fund CARES Act funding.
• Interviewed the CFO of the Columbus Housing Authority, who manages the Buena Vista
Housing Authority, to obtain an understanding of how the Authority used its CARES Act
supplemental operating funds to prepare for, prevent, and respond to the pandemic.
• Reviewed supporting documentation for a sample of Public Housing Operating Fund
expenditures, including ledgers, invoices, and payroll.
The Buena Vista Housing Authority received $36,366 in CARES Act supplemental public housing
operating funds. It had spent all these funds by December 31, 2020. HUD OIG reviewed a random
sample of 52 expenditures totaling $11,883 and reviewed supporting documentation to determine
whether the Authority spent CARES Act supplemental public housing operating funds in alignment
with the program goals and objectives.
HUD OIG reviewed a random sample of the Authority’s operating fund expenditures because it did
not account for the supplemental operating funds separately. The Authority drew all its CARES Act
supplemental operating funds, and those funds were commingled with its regular operating funds.48
48 HUD OIG determined it to be acceptable that the Authority comingled its CARES Act supplemental operating funds with its regular operating
funds because the supplemental funds can be used for the same purposes as the regular operating funds. Office of Public and Indian Housing
(PIH) Notice PIH-2020-07 states that the supplemental operating funds may also be used to maintain normal operations.
Pandemic Response Accountability Committee 41
The funds were used to maintain normal operations and to purchase PPE without differentiating
between the sources of funds. In its financial statements, the Authority attributed the CARES Act
supplemental operating funds to three accounts. Therefore, HUD OIG selected a random sample
from a universe of all expenditures made in the three accounts during this audit period.49
To achieve HUD OIG’s objective, it relied in part on the Authority’s computer-processed data.
Although HUD OIG did not perform a detailed assessment of the reliability of the data, it determined
that the 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 objective. HUD OIG’s objective
was not to evaluate or provide assurance of the Authority’s internal controls. Therefore, HUD OIG did
not assess the Authority’s controls or express an opinion on them.
Standards
HUD OIG conducted this review in accordance with generally accepted government auditing
standards. Those standards require that it plan and perform the review to obtain sufficient,
appropriate evidence to provide a reasonable basis for its findings and conclusions based on
its objective(s). HUD OIG believes the evidence obtained provides a reasonable basis for its
conclusions based on its 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 one nursing home in Marion County during
calendar years 2020 and 2021. The selected facility was the only facility within Marion County
that received direct PRF payments through distributions that HHS targeted for nursing homes and
certified SNFs.50 HHS OIG conducted its data collection concurrently with the PRAC’s site visit to
Marion County during December 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 home used the PRF payments
and whether it experienced any challenges using these funds. Through its review, HHS OIG also
gathered the perspectives of facility leaders, staff, residents, and family members regarding
whether the PRF payments helped them prevent, prepare for, and respond to COVID-19, and
whether the facility complied with terms and conditions related to PRF use.
49 The universe consisted of 218 expenditures totaling $53,995.
50 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 Marion 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 42
Methodology
Data Sources
Interviews
To evaluate the nursing home’s use of PRF payments, HHS OIG interviewed leadership, staff, and a
small number of residents and family members from the selected facility. HHS OIG also conducted
two group interviews with HRSA officials who were responsible for administering and overseeing the
payments. HHS OIG employed adaptable interview protocols that allowed it to modify questions, as
needed, and follow up on additional issues as it learned new information and identified key issues.
Nursing Home Interviews | HHS OIG conducted group interviews with corporate and facility
leaders and staff in the selected nursing home. Participants included corporate executives, facility
leadership, a representative from an external audit firm that conducts single audits of the chain
of nursing homes, and a small number of clinical and nonclinical staff. HHS OIG also conducted a
small group interview with residents and family members as a way of gathering additional insights
and illustrations about facility services and resident perceptions about the effects of the funding.
During these interviews, HHS OIG discussed how the nursing home used the PRF payments and its
experiences in using the funds and reporting the information to HRSA. HHS OIG discussed facility
leadership and staff perceptions of how the payments helped the facility prevent, prepare for,
and respond to COVID, and challenges that hindered their use of the funds. Additionally, HHS OIG
discussed nursing home interactions with HRSA officials related to PRF use and oversight, and any
additional assistance from HRSA that the facility 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 facility received.
HRSA Interviews | HHS OIG conducted a few group interviews with PRF program administrators in
HRSA’s Provider Relief Bureau. The interviews gathered more detailed information about PRF goals
and performance metrics. HHS OIG also discussed HRSA’s efforts to manage and oversee the PRF,
including the agency’s efforts related to PRF payment distribution, provider reporting processes,
audits, the recovery of improper or unintended payments, and other efforts.
Document Review
HHS OIG collected available funding receipt attestations and reports to HRSA about how the nursing
home used the PRF payments. The documents were extracted directly by HHS OIG’s Division of
Data Analytics, using a data use agreement it has with HRSA, during late April 2022 in preparation
for the PRAC’s series of location site visits, which began in May 2022. At that time, only two of
four required reporting periods had passed, so the facility had not yet reported on its use of all
PRF payments. It had, however, reported on most of the payments it received through the targeted
distributions to nursing homes and certified SNFs. HHS OIG also requested and reviewed summary
documentation from the facility supporting expenses outlined in those reports. Additionally, HHS
OIG requested any correspondence between HRSA officials and the facility about the PRF money
Pandemic Response Accountability Committee 43
and the reports, as well as any documentation of HRSA’s actions to assess and enforce terms and
conditions related to use of the funds or to rescind funds not used according to those requirements.
As of June 8, 2022, HRSA had no documentation of oversight actions related to the facility.
Data
To summarize the PRF payments the nursing home received and kept, HHS OIG reviewed PRF
payment data from HRSA for the selected facility, which its Division of Data Analytics accessed
directly through its data use agreement with HRSA. HHS OIG collected the PRF payment data in
preparation for the PRAC’s series of location site visits; the data was extracted on February 28,
2022, and, depending on whether the payments were made electronically or by check, were current
through the beginning of January or February 2022. The data therefore included all payments made
during HHS OIG’s timeframe of calendar years 2020 and 2021 (the first four distribution periods)
and was 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
home and HRSA. HHS OIG used its analysis to gain a deeper understanding of PRF program
strengths and weaknesses from the perspective of the nursing home. This analysis also helped
HHS OIG to determine how the selected nursing home used targeted payments to improve infection
control and address health care expenses and lost revenue related to the pandemic.
HHS OIG conducted a quantitative review of PRF payment data and the nursing home’s financial
documentation. HHS OIG used its analysis of the data to briefly summarize the types and amounts
of PRF payments the facility received and how the funds were used.
Limitations
HHS OIG focused only on the experiences of the selected nursing home. Its findings cannot be
extrapolated to all nursing homes that received PRF payments.
Although HHS OIG compared the nursing home’s reports to HRSA against supporting
documentation and PRF terms and conditions to assess appropriateness, it did not conduct an
audit of the facility’s financial documentation to verify its reports and supporting material.
Standards
HHS OIG conducted this study in accordance with the Quality Standards for Inspection and
Evaluation issued by CIGIE.
Pandemic Response Accountability Committee 44
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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