A Review of Pandemic Relief Funding and How It Was Used in Six U.S. Communities: White Earth Nation Reservation in Minnesota

Document type: Report
Date: 2025-03-04

Summary

A Pandemic Response Accountability Committee report dated March 2025, the fifth in its series A Review of Pandemic Relief Funding and How It Was Used in Six U.S. Communities, focused on the White Earth Nation Reservation in Minnesota. The report states that reservation recipients received more than $278 million from 56 federal pandemic relief programs and subprograms, and it examines 10 of those programs from seven federal agencies. Sections cover the Indian Housing Block Grant under the CARES Act, the Coronavirus Relief Fund, school emergency relief, the Farmers to Families Food Box Program, pandemic unemployment insurance and Provider Relief Fund payments to nursing homes. It reports, for example, that the White Earth Housing Authority received $1,010,296 to purchase 12 modular homes. Appendices give abbreviations and scope and methodology.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

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

White Earth Nation
Reservation in Minnesota
March 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:
White Earth Nation Reservation in Minnesota.................................................................................. 1
Indian Housing Block Grant – CARES Act .......................................................................................... 5
Coronavirus Relief Fund...................................................................................................................... 8
Elementary and Secondary School Emergency Relief Program .................................................... 14
Farmers to Families Food Box Program ...........................................................................................20
Pandemic Funding ............................................................................................................................23
Pandemic Unemployment Insurance Programs.............................................................................. 27
Provider Relief Fund Payments to Nursing Homes .........................................................................34
Appendix A: Abbreviations and Acronyms........................................................................................ 41
Appendix B: Scope and Methodology ..............................................................................................43
Indian Housing Block Grant – CARES Act ....................................................................................44
Coronavirus Relief Fund................................................................................................................46
Elementary and Secondary School Emergency Relief Program ................................................ 47
Farmers to Families Food Box Program .......................................................................................48
Pandemic Funding ........................................................................................................................49
Pandemic Unemployment Insurance Programs..........................................................................50
Provider Relief Fund Payments to Nursing Homes ..................................................................... 51

Pandemic Response Accountability Committee

Taking a Closer Look at a
Community’s Experience:
WHITE EARTH NATION RESERVATION
IN MINNESOTA
This report is the fifth in a series taking
an in-depth look at how six communities
used federal pandemic funding to address
a wide range of community-based needs.
In this report, we focus on the White Earth
Nation Reservation in Minnesota, with a
detailed look at 10 of the 56 pandemic
programs that provided funding to the
community. For more information about
our review, see Appendix B.
The White Earth Nation Tribe has
approximately 17,000 members, some of
whom reside on the White Earth Nation
Reservation in northwestern Minnesota.1
The White Earth Nation Reservation
comprises approximately 1,300 square
miles, covering all of Mahnomen County
plus parts of Becker and Clearwater
Counties. In 2022, the reservation had
a population of 9,991. As of February
28, 2023, Mahnomen County, which
encompasses a majority of White Earth
Nation Reservation’s population, had
1

The PRAC’s scope for this project covers pandemic
funding for recipients located within the geographical
boundaries of the White Earth Nation Reservation. One
of the major recipients of funding within the reservation
is the White Earth Nation Tribal government. However,
additional recipients within the reservation are not
affiliated with the Tribe. As such, the PRAC uses the
term “White Earth Nation Reservation” to describe the
geographical area and all its inhabitants, whether or
not they are members of the Tribe. Similarly, the PRAC
uses the term “White Earth Nation Tribal government” to
specifically describe the Tribe.

U.S. Census Bureau data for Tribal areas.
Land area size information was obtained from the Tribe’s website.
c
Because individuals may be considered a member of more than one racial
demographic, the percentages may not equal 100 percent.
d
Centers for Disease Control and Prevention (CDC) data based on the rate of individuals
who received at least two doses of the vaccine. The vaccination rate represents the
countywide rate and is not specific to the White Earth Nation Reservation borders.
Data as of May 30, 2023.
e
Data was obtained from the White Earth Nation’s Tribal Health Department and
identified totals for Mahnomen County, which encompasses a majority of White Earth
Nation Reservation’s population, as of February 28, 2023.
f
U.S. Census Bureau. The poverty line varies depending on factors such as the year and
household size. Please see Poverty Thresholds for more information.
a

experienced 1,875 recorded cases of COVID-19,
with 18 recorded deaths.2
In our July 2023 report, Tracking Pandemic
Relief Funds that Went to Local Communities
Reveals Persistent Data Gaps and Data
Reliability Issues, we found that White Earth
Nation Reservation recipients, including the
Tribal government, small businesses, and
individuals, received more than $278 million
from 56 federal pandemic relief programs and
subprograms from March 2020 to September
2021. This report provides a closer look
at the funding provided from 10 of these
pandemic relief programs and subprograms
from seven federal agencies.3 These programs
sought to respond to and mitigate the effects
of the pandemic by addressing community
development needs, such as a lack of adequate
housing, that posed a serious threat to the
health or welfare of the community; supporting
nursing homes to ensure that they could
prevent, prepare for, and respond to the spread
of COVID; providing food to ensure that people
in need did not go hungry; and other health,
education, and economic efforts. Through this
review, we sought to gain insight into how White
Earth Nation Reservation used its pandemic
relief funding, how the spending aligned with
the goals and objectives of the federal relief
programs, and whether the funding assisted
the reservation’s residents in responding to the
pandemic.

2
3

Programs Selected for
Further Review
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

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

Pandemic Programs
U.S. Department of the Interior

Pandemic Unemployment
Insurance Programs
U.S. Department of Labor

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

The White Earth Nation Tribal government’s COVID emergency response team tracked COVID data within its boundaries until the team was
decommissioned in mid-2021. As a result, White Earth Nation health officials provided COVID data for Mahnomen County as the closest
representation of White Earth Nation Reservation COVID cases and death statistics at the time of our request.
The U.S. Department of the Interior (DOI) Office of Inspector General (OIG) reviewed four programs within a single section (“Pandemic
Programs”). These four programs are Indian Housing Assistance, Indian Schools Student Transportation, Assistance to Tribally Controlled
Community Colleges and Universities, and Indian Self-Determination Contract Support.

Pandemic Response Accountability Committee

Pandemic Impact on the Community
According to residents and local officials, the pandemic impacted multiple aspects of life on White
Earth Nation Reservation. For example, the average unemployment rate in Mahnomen County
increased from 5 percent in 2019 to 13.3 percent in 2020, peaking at 25.3 percent in May 2020.
To help address unemployment, White Earth Nation Reservation residents received more than
$25.9 million in federal benefits from pandemic-related unemployment insurance (UI) programs.
White Earth Nation Tribal government officials also highlighted that the COVID pandemic affected
their community in unique ways that necessitated a tailored approach to address cultural
sensitivities and prioritized the well-being of Tribal members. These officials noted that given
the historical distrust in the federal government and Western medicine, they used familiar and
trusted cultural symbols and practices to more effectively reach their community. As we previously
highlighted in our March 2024 report, Pandemic Relief Experience: A Focus on Six Communities,
these officials developed a public health risk indicator that incorporated Centers for Disease Control
and Prevention (CDC) guidance into their traditional medicine wheel.4 They also used the local
casino that is owned and operated by the Tribe as a center to coordinate their pandemic response.
The casino served as a testing and vaccination center as well as a staging ground for a food
preparation and delivery program. These efforts enabled the White Earth Nation Tribal government
to provide services to its community while also employing a portion of the casino’s workforce, a
majority of whom are members of the Tribe.

Program Impact on the Community
The officials we interviewed offered a wide variety of responses about the community’s use of
federal pandemic funds to address the impacts of COVID. Sample responses include:
• The White Earth Housing Authority received $1,010,296 from the Coronavirus Aid, Relief, and
Economic Security (CARES) Act and the U.S. Department of Housing and Urban Development’s
(HUD) Indian Housing Block Grant (IHBG) to purchase 12 modular homes to address
overcrowding and reduce the risk of COVID transmission in the community.
• The U.S. Department of Agriculture (USDA) Office of Inspector General (OIG) estimated that,
as part of the Farmers to Families Food Box Program (Food Box Program), food distributors
delivered 19,152 food boxes (valued at $746,982) to three organizations to feed residents in
the White Earth Nation Reservation community.
• The U.S. Department of the Interior (DOI) awarded $19,591,617 to the White Earth Nation
Reservation to support day-to-day Tribal government operations, transportation, law
enforcement, and education services.
4

The medicine wheel is a traditional symbol used by many Native American Tribes. The Anishinaabe medicine wheel is central to teaching the
Anishinaabe people of Minnesota’s cultural and spiritual values and conveying cycles of life, growth, understanding, and achievement. The
medicine wheel is oriented and depicted using the traditional directions and colors. Yellow is always East, red is always South, black is always
West, and white is always North. Life begins in the East and proceeds in a circle, clockwise, finishing in the North. White Earth Nation Tribal
government’s use of the Anishinaabe medicine wheel was highlighted by CDC in its “Stories from the Field” blog series to show how tailoring
public health practices to a specific community’s values can build trust and long-lasting partnership, which can lead to better health outcomes.

Pandemic Response Accountability Committee

Participant Experience
During our visit to the reservation in October 2022, we received feedback from multiple officials
whose offices or organizations received federal funding. They shared their experiences with federal
pandemic response programs and highlighted the challenges and successes. For example:
• Tribal officials said that the Coronavirus Relief Fund (CRF) bolstered initiatives that provided
food security for the elderly and offered COVID testing to the entire community. They also
stated that the “Feeding Our Families” and food shelf initiatives were established using the
Tribe’s CRF award and enabled the Tribe to provide two boxes of mostly nonperishable food
items per household.
• Mahnomen Public School District officials noted that the Elementary and Secondary School
Emergency Relief (ESSER) Program funds that the school district received allowed them to
practice effective social distancing with their students. The ESSER funds allowed the district to
double the bus routes, add staff for distance learning, and increase cafeteria space.
• Most surveyed claimants for the UI program expressed overall satisfaction with the application
process, promptness of receiving benefits, and the certification process to continue receiving
benefits.
• Leaders for a nursing home located on the White Earth Nation Reservation reported that
Provider Relief Fund (PRF) payments helped the facility respond to the COVID pandemic,
improve infection control practices, and maintain resident safety and care.

Pandemic Response Accountability Committee

PROGRAM SNAPSHOT

Indian Housing Block Grant –
CARES Act
U.S. Department of Housing and Urban
Development
The White Earth Nation has approximately 17,000 members, some of whom reside on the White
Earth Nation Reservation in northwestern Minnesota. The reservation is home to more than 9,000
residents (Tribal members and nonmembers). White Earth Nation Tribal government officials
stated that the reservation experienced a lower mortality rate compared to other Native American
communities during the pandemic. However, the losses experienced were traumatic. White Earth
Nation Tribal government officials stated that it managed to limit the effects of the coronavirus
through quick, decisive action. Specifically, in March 2020, White Earth Nation Tribal government
established an emergency operations center (EOC) to coordinate COVID priorities and community
needs, such as obtaining personal protective equipment (PPE), ensuring food security, expanding
public health outreach, and coordinating vaccination efforts.
The White Earth Housing Authority (Authority) assists enrolled members in obtaining affordable
housing. HUD OIG interviewed the former executive director of the Authority who was in position
during the period the pandemic funds were spent.5 The official told HUD OIG that the Authority
had experienced some challenges due to COVID. For example, at the onset of the pandemic the
Authority was rehabilitating its housing stock, and some of these construction projects were
delayed. As the pandemic continued and projects resumed, the Authority found that the cost of
materials had increased substantially. The Authority stated that it tried to minimize the impact of
COVID on its community and staff by limiting face-to-face business interactions. For example, the
Authority closed its office for three months and transitioned eligible employees to remote work.

The White Earth Housing Authority is the Tribally Designated Housing Entity (TDHE) of the White Earth Nation. For IHBG, the TDHE is the agency
that administers the funds to develop or support rental or ownership housing or provide housing services to benefit low-income Indian families
on Indian reservations and other Indian areas.

Pandemic Response Accountability Committee

HUD’s IHBG is a formula grant that provides a
range of affordable housing activities on Indian
reservations and in Indian areas. IHBG funds may
be used for housing construction and acquisition
and the modernization and operating expenses
for housing previously developed under the Indian
Housing Program. Other eligible activities include
housing services to eligible families and individuals,
crime prevention and safety, and model activities
that provide creative approaches to solving
affordable housing problems.

CLEAR GUIDANCE AND
TECHNICAL SUPPORT
HUD provided guidance to IHBG CARES Act
recipients in various formats, including notices,
guidance letters, and webinars. These guidance
materials were available on HUD’s public website.
The Authority’s former executive director stated that
HUD held regular meetings to discuss the program
and provided clear guidance.

The CARES Act, signed into law on March 27,
2020, provided an additional $200 million in IHBG funds.6 Eligible uses for IHBG CARES Act funds
included:
• Activities, projects, or programs to prevent, prepare for, and respond to COVID
• Maintaining normal operations7
• Funding eligible affordable housing activities (under the Native American Housing Assistance
and Self-Determination Act)
Additionally, HUD guidance added that eligible uses of the funds included activities, projects, or
programs that would reduce or mitigate the short-term, medium-term, and longer-term risks and
vulnerabilities of Tribal communities to COVID, such as activities that reduce overcrowding.
HUD provided guidance to IHBG CARES Act recipients in various formats, including notices,
guidance letters, and webinars. These guidance materials were available on HUD’s public website.
The Authority’s executive director in charge at the time stated that HUD held regular meetings with
his office to discuss the program and provided clear guidance. The executive director added that
staff at HUD’s Eastern Woodlands Office of Native American Programs were very helpful.

6
7

The funds were allocated through a formula based on fiscal year 2020 Tribal allocations in which each Tribe received 30.57 percent of its IHBG
formula allocation.
One example of maintaining normal operations is using funds to carry out eligible activities that the recipient initially planned to carry out with
its regular IHBG funds but did not because it had to use its regular IHBG funds to carry out an unplanned activity related to COVID.

Pandemic Response Accountability Committee

Program Impact on the Community
HUD required Tribes to submit an abbreviated housing plan to identify their intended use(s) of
IHBG CARES Act funds. Authority officials stated that a housing study of the White Earth Nation
Reservation community found that the Tribe needed an additional 1,000 housing units to
address overcrowding. Specifically, the Authority’s plan documented the purchase of 12, threebedroom modular homes to be placed on lots leased from the Tribe, and HUD reviewed the plan
for compliance with the CARES Act. The Authority then used the funds to purchase the homes
and prepared the sites in a way to help reduce the overcrowding and lower the risk of COVID
transmission in its community.
As of September 30, 2021, the Authority spent all of the more than $1 million in IHBG CARES
Act funds awarded by HUD.8 The Authority demonstrated that the program funds were used as
intended to construct the modular homes and for other expenses related to construction of the
homes, including installing decks and establishing electrical, water, and gas access. HUD OIG’s
review showed that the Authority generally used its IHBG CARES Act funds in accordance with
the goals and objectives of the program.

Participant Experience
The Authority’s former executive director, who was in charge at the time when it received and spent
the funding, stated that the Authority successfully used its IHBG CARES Act funds to respond to the
coronavirus with the purchase and installation of the new housing.9 He also stated that because
overcrowding in the community was significant, the Authority could have used additional funding to
further mitigate its overcrowding problem. The reservation needed 1,000 housing units to address
overcrowding before the pandemic, so the pandemic
exacerbated the existing overcrowding in the community and
FOR MORE INFORMATION
need for funding. He further stated that HUD was supportive
For more information about Indian
by providing guidance on eligible uses, holding monthly calls,
Housing Block Grant – CARES Act
and having local field office staff available for assistance.
program spending across the country,
visit the PRAC’s website.

8
9

Although the Authority was awarded more than $1 million in IHBG CARES Act funds and more than $2.3 million in IHBG American Rescue Plan
Act funds, HUD OIG’s review was limited to its use of IHBG CARES Act funds because only IHBG CARES Act funds had been spent during its
review period, as of September 30, 2021.
HUD OIG interviewed the former executive director because he was the executive director during the expenditure period.

Pandemic Response Accountability Committee

PROGRAM SNAPSHOT

Coronavirus Relief Fund
U.S. Department of the Treasury

As of February 2023, the White Earth Nation Reservation experienced 1,875 COVID cases and
18 deaths.10 White Earth Nation’s reservation contains approximately 1,300 square miles in
northwestern Minnesota and has a population of 9,991.11
During the early stages of the COVID pandemic,
the White Earth Nation Tribal government faced
WHITE EARTH DEMOGRAPHICS
significant challenges including addressing public
White Earth Nation Tribal government is a
health misinformation; the financial strain of paying
federally recognized Tribe. White Earth Nation
salaries and wages; developing remote work and
Reservation contains approximately 1,300 square
learning platforms; and addressing food insecurity of
miles in northwestern Minnesota and has a
vulnerable demographic groups. For example, White
population of 9,991.
Earth Nation Tribal government officials encountered
obstacles in disseminating accurate COVID information
to the community because some Tribal and non-Tribal
members have a historically rooted distrust in the federal government and Western medicine. White
Earth Nation Tribal government activated an EOC as part of a COVID response public information
campaign. The EOC provided weekly updates to the public to emphasize the importance of social
distancing, wearing masks, and checking on elders; and to provide information for both active and
cumulative cases of COVID within the reservation.
A casino, the largest employer within the White Earth Nation Reservation, experienced difficulties
paying salaries and wages to its employees. About 40 to 50 percent of the Tribe’s revenues come
from the casino, and it closed for six months due to the public health emergency. Casino officials
stated they experienced a decrease in staffing by approximately 50 percent and a decrease in
customers by 40 percent due to fears of contracting COVID. The officials also stated they leveraged
the CRF to hire additional employees and make modifications to the casino’s COVID protocols by
implementing social distancing of gaming equipment, adding tobacco smokehouses, and dispersing
sanitation stations throughout the casino. White Earth Nation Tribal government also struggled to
facilitate remote work and distance learning in the early stages of the pandemic and had to install
10 Data was obtained from the White Earth Nation’s Tribal Health Department and identified totals for Mahnomen County, which encompasses a
majority of White Earth Nation Reservation’s population, as of February 28, 2023.
11 U.S. Census Bureau for Indian Tribes (2017--2021 American Community Survey Estimates, pulled on May 31, 2023).

Pandemic Response Accountability Committee

fiber optics and purchase technology equipment. Additionally, the White Earth Nation Reservation
experienced food insecurity as food shelf managers were unsuccessful reaching various food
suppliers to obtain food for the community. White Earth Nation Tribal government employees made
supply runs to a neighboring city to obtain bulk supplies of food that they packaged and delivered to
the elderly and other affected residents within the community.

Program Information
The CARES Act established the CRF program and appropriated $150 billion for the U.S. Department
of the Treasury (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 COVID.12 As of December 31, 2022, Treasury
disbursed CRF award funds to 964 prime recipients, which subsequently distributed the award
funds to 89,969 subrecipients through contracts, grants, loans, direct payments, or fund
transfers.13 CRF award funds allowed prime recipients and subrecipients to provide fast and direct
economic assistance to impacted workers, families, small businesses, and industries in response
to the COVID pandemic. For example, CRF award funds could be used to address medical or public
health needs, 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; (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), except for Tribal governments
whose covered period was extended to December 31, 2022.14 Prime recipients are responsible for
reporting CRF award funds expenditures to Treasury on a quarterly basis during the covered period
in GrantSolutions.15

12 P.L. 116-136 (March 27, 2020); Title V of the CARES Act defines a unit of local government as a county, municipality, town, township, village,
parish, borough, or other unit of general government below the state level with a population that exceeds 500,000; an eligible unit of local
government serves a population of over 500,000 and certified its proposed uses of the funds received from the CRF program; and, the U.S.
territories are as follows: United States Virgin Islands, Guam, American Samoa, Puerto Rico, and the Commonwealth of the Northern Mariana
Islands.
13 A subrecipient is an entity that received CRF payments from a prime recipient that received a CRF award directly from Treasury. Subrecipients
assist with carrying out the requirements of CRF awards. Subrecipients can also include recipients of transfers from a prime recipient that is a
state, territory, local government, or Tribal government. Individuals and organizations (e.g., businesses, non-profits, or educational institutions)
that directly benefit from an assistance program established using payments from CRF awards 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 15 for definition of the grant reporting system).
14 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 their 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, included in Division LL, Section 104 of the Consolidated Appropriations Act, 2023, P.L. 117328, December 29, 2022, 136 Stat. 4459.
15 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

White Earth Nation Tribal government received CRF award funds both directly from Treasury as a
prime recipient, as well as from the State of Minnesota as a subrecipient. Additionally, two other
Tribal governments received their CRF award funds directly from Treasury as prime recipients
and distributed CRF award funds to two businesses (beneficiaries) located within the geographic
boundaries of the White Earth Nation Reservation.16
As a prime recipient, White Earth Nation Tribal government’s responsibilities included, but were
not limited to, providing guidance to subrecipients, reiterating federal requirements, and reviewing
subrecipients’ expenditure reports to assess compliance with the CRF program’s eligible use
requirements. White Earth Nation Tribal government followed its Finance Department’s fiscal
policies and procedures to administer its CRF award funds and to assure the accurate recording
and timely reporting of all financial transactions completed to meet the objectives of the White
Earth Nation Reservation Tribal Council and comply with all federal laws and regulations set forth
in each grant or other funding source. White Earth Nation Tribal government’s Finance Department
used journal entries to track the use of CRF award funds, and reviewed program and financial
reports quarterly. White Earth Nation Tribal government’s subrecipients also utilized Treasury’s CRF
Frequently Asked Questions (FAQs) for additional guidance on eligible uses of CRF award funds.

Program Impact on the Community
As of June 30, 2022, Treasury disbursed approximately $32.3 million in CRF award funds to
White Earth Nation Tribal government as a prime recipient. White Earth Nation Tribal government
awarded all the funds to several subrecipients and beneficiaries located within White Earth
Nation Reservation through transfers, direct payments, aggregate direct payments, and aggregate
payments to individuals. Additionally, the State of Minnesota disbursed approximately $899,000 of
the total $1.9 billion in CRF award funds it received from Treasury to the White Earth Nation Tribal
government as a subrecipient.
Treasury also disbursed approximately $280,000 in CRF award funds to two other Tribal
governments as prime recipients, who distributed all the funds to two businesses (beneficiaries)
located within the geographic boundaries of White Earth Nation Reservation. As of June 30, 2022,
all subrecipients and beneficiaries located within the reservation’s geographic boundaries received
and expended a total of $33.43 million of CRF funding awarded to assist with overcoming local
community pandemic impacts.
Treasury OIG selected a sample of $1.3 million (3.9 percent) of $33.43 million in CRF expenditures
for the casino, various other subrecipients and beneficiaries geographically located within White
Earth Nation Reservation, and White Earth Nation Tribal government itself as a subrecipient
to determine whether CRF award funds were used in alignment with the program’s goals and
objectives.17 The selected CRF subrecipients and beneficiaries used the funds in response to the
16 The two other Tribal governments that received CRF award funds on the reservation are based out of Minnesota and Oklahoma, respectively.
17 The results of the review of expenditures cannot be extrapolated to the population of expenditures as Treasury OIG judgmentally selected the
sample.

Pandemic Response Accountability Committee

COVID public health emergency in various ways, including renovating and enhancing the casino to
comply with CDC’s COVID protocols, to address food insecurity within the community by securing
food supply inventories, to facilitate distance learning and remote work in order to mitigate the
spread of the pandemic, to provide emergency financial assistance to members of the community
directly impacted by a loss of income or hardships due to COVID, and to pay payroll expenses for
public health and safety workers.
Based on Treasury OIG’s analysis of the sampled expenditures, CRF award funds were used in
alignment with the program’s goals and objectives of preventing and mitigating the impacts from
the COVID public health emergency. The selected subrecipients and beneficiaries complied with the
CARES Act, Treasury’s guidance, and Treasury OIG’s guidance.18 Specifically, the White Earth Nation
Tribal government and other subrecipients and beneficiaries geographically located within the
reservation used the $33.43 million CRF award funds as described below.

White Earth Nation Tribal Government (as Prime Recipient)
As of June 30, 2022, Treasury disbursed approximately $32.3 million in CRF award funds to
White Earth Nation Tribal government as a prime recipient, which distributed the funds to various
subrecipients and beneficiaries through transfers, direct payments, aggregate direct payments, and
aggregate payments to individuals. Specifically, White Earth Nation Tribal government distributed
CRF award funds to the following subrecipients and beneficiaries to address the COVID public
health emergency as follows:
• Casino – The casino, a subrecipient that received the largest amount of CRF award funds
from the White Earth Nation Tribal government, it received a total of $2.3 million in CRF
award funds through transfers and direct payments. Of this amount, Treasury OIG reviewed
approximately $387,000 distributed to the casino. Treasury OIG found that the casino used
the funds in a variety of ways to respond to the pandemic, such as to purchase casino
equipment and software necessary to reduce face-to-face interactions, to provide for low-touch
kiosks and contactless options for check-ins, to rearrange casino layouts and install plexiglass
shields to facilitate social distancing, to replace doors for automatic/low-touch operation, to
increase the inventory of bed linens to prevent disease transmission, and to purchase a new
fingerprinting scanner and software to digitize the fingerprinting process to reduce prolonged
contact between staff and new hires and provide for a clean and sanitized fingerprinting
surface for each user. The casino also used the funds for payroll of security personnel
guarding food distribution sites to prevent looting of the food inventory that was in short supply
due to COVID. Additionally, the casino used the funds to host food programs to feed the Tribal
community, to modify its event center to accommodate the EOC’s COVID operations, and to
upgrade communal areas to meet public health guidelines.
18 Department of the Treasury Office of Inspector General Coronavirus Relief Fund Frequently Asked Questions Related to Reporting and
Recordkeeping (OIG-CA-20-028R, March 2, 2021). The CARES Act provides Treasury OIG the responsibility for monitoring and oversight of
the receipt, disbursement, and use of CRF payments. Treasury OIG also has authority to recover funds if it is determined recipients failed to
comply with the requirements of subsection 601(d) of the Social Security Act, as amended, (42 U.S.C. 801(d)). Treasury OIG provided recipients
reporting and record retention requirements.

Pandemic Response Accountability Committee

• Other subrecipients and beneficiaries – White Earth Nation Tribal government also distributed
approximately $30 million in CRF award funds to several other subrecipients and beneficiaries
including food supply companies, technology companies, COVID rapid testing laboratories,
and reservation residents through direct payments, aggregate direct payments, and aggregate
payments to individuals. Of this amount, Treasury OIG reviewed approximately $647,000
distributed to various subrecipients and beneficiaries. Overall, Treasury OIG found funds were
used to facilitate distance learning for students and remote work for employees, to provide
emergency financial assistance to individuals and families directly impacted by a loss of
income or hardships due to COVID, to provide food for families during stay-at-home orders, and
to pay payroll expenses for public health and safety employees, such as police officers and
employees that work on the elderly nutrition program.

White Earth Nation Tribal Government (as a State of Minnesota Subrecipient)
The State of Minnesota, a prime recipient, distributed approximately $899,000 of the $1.9 billion
in CRF award funds it received from Treasury to the White Earth Nation Tribal government through
a CRF Tribal Public Health grant. Of this amount, Treasury OIG reviewed approximately $271,000
of grant expenditures and found the funds were used to purchase COVID rapid tests and supplies,
a COVID rapid response test machine, and COVID antigen tests, as well as to pay payroll costs of
public health employees, to include registered nurses, home health registered nurses, and health
education specialists.

Other Tribal Government Beneficiaries (not White Earth Nation Tribal government) within
White Earth Nation Reservation
Two other Tribal governments, as prime recipients, distributed approximately $280,000 in CRF
award funds to two businesses (beneficiaries) geographically located within the White Earth Nation
Reservation. Treasury OIG did not review expenditures for these beneficiaries. However, the prime
recipients reported that the CRF award funds were used to purchase PPE and pay other medical
expenses in response to the public health emergency.

Pandemic Response Accountability Committee

Participant Experience
Satisfaction
White Earth Nation Tribal government officials expressed overall satisfaction with the ability to use
CRF award funds to address their needs and challenges due to the pandemic. The officials noted
that initiatives such as providing food security for the elderly and offering COVID testing went
very well after CRF monies were distributed. They also stated that the “Feeding Our Families”
and food shelf initiatives were established using its CRF award and enabled the Tribe to provide
two boxes of mostly nonperishable food items per household. Additionally, they stated CRF
monies were used to purchase laptops for students and teachers, purchase wireless hot spots, and
provide technology support to facilitate distance learning. Furthermore, they expressed that CRF
reporting was a lot faster to process and was less detailed compared to other program funding. In
addition, the casino officials stated the funding helped the casino reset and continue operations.

Challenges
White Earth Nation Tribal government officials expressed that its main challenges with the CRF
program were frequently changing federal rules and policies and the limited timeframe to expend
the funds. The officials stated they would have liked additional guidance from Treasury as to what
items were eligible for purchase with the CRF award. Additionally, the officials expressed difficulties
with hiring contractors due to the limited timeline for expending the funds. They also expressed that
it was difficult to verify individual financial assistance applications and issue assistance checks in
such a short amount of time.

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

Pandemic Response Accountability Committee

PROGRAM SNAPSHOT

Elementary and Secondary School
Emergency Relief Program
U.S. Department of Education
The CARES Act created the Education Stabilization Fund, which provided $30.75 billion to the U.S.
Department of Education (ED) “to prevent, prepare for, and respond to coronavirus, domestically
or internationally…”19 The CARES Act also created the ESSER program — a subprogram of the
Education Stabilization Fund. The ESSER program received funding through three pandemic
related laws, and each law created different rounds in the program’s implementation. Each round
had different funding totals, program expiration dates, and planning or reporting requirements. To
support local schools, ED first provided ESSER funding to state educational agencies, which in turn
provided funds to the local school districts.20
• ESSER I: A first round of ESSER funding came from the CARES Act and provided $13.23
billion to prevent, prepare for, and respond to the coronavirus pandemic, 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 operations, and address the pandemic’s impact on
students.
• ESSER II: A second round of ESSER funding totaling $54.31 billion came from the Coronavirus
Response and Relief Supplemental Appropriations Act, 2021. ESSER II funds were to be used
for the same purpose as ESSER I funds.
• ESSER III: A third round of ESSER funding came from the American Rescue Plan (ARP) Act and
provided $121.97 billion for ESSER. At least 20 percent of local educational 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.
For ESSER III, each local educational agency was also required to submit a plan to the state
educational agencies “within a reasonable timeline determined by the [state educational
agency]” on the use of the funds, how it would engage and consult with stakeholders when
developing its plan, and how it intended to make the plan publicly available and explain the
safe return to in-person instruction and continuity of services.21
19 See CARES Act, P.L. No. 116-136, Division B, Title VIII, (March 27, 2020).
20 State education agencies also reserved funds in accordance with the guidance described in ED’s Elementary and Secondary School
Emergency Relief Programs and Governor’s Emergency Education Relief Programs, FAQs, December 7, 2022, Update. See questions A-8
through A-12.
21 See ED’s ESSER and GEER Use of Funds FAQs from December 7, 2022, question A-4.

Pandemic Response Accountability Committee

During phase one of this review, we found that the schools and school districts within the
boundaries of the White Earth Nation Reservation were awarded about $11.1 million in ESSER
funds, and had spent around $2.0 million in ESSER I and ESSER II funds.22 As of September 30,
2021, they had not yet spent any ESSER III funds.23 See Table 1 for more information about the total
ESSER funding for the schools and school districts within the White Earth Nation Reservation, with
awards and expenditures noted for Mahnomen Public School District and Waubun-Ogema-White
Earth Public School District—the two school districts that we selected for further review.
Table 1: White Earth Nation Reservation in Minnesota Schools ESSER Funding Information, as of
September 30, 2021
Total Awarded

Total Spenta

Expiration Date

ESSER I

$829,034

$819,035

9/30/2022

Mahnomen Public School
District

$418,075

Waubun-Ogema-White Earth
Public School District

$277,107

ESSER II

$3,232,321

$1,241,935

Mahnomen Public School
District

$1,606,087

$800,000

Waubun-Ogema-White Earth
Public School District

$1,145,834

$167,529

ESSER III

$7,057,762

Mahnomen Public School
District

$3,607,044

Waubun-Ogema-White Earth
Public School District

$2.573,381

Total

$11,119,117

$2,060,970

9/30/2023

9/30/2024

a Total Expended reflects the total amount of funding expended by the local educational agencies for which the state educational
agency has issued a reimbursement.

22 A total of six schools and school districts located within the geographic boundaries of the White Earth Nation Reservation received funding
from ESSER I and/or ESSER II.
23 ESSER III funds were not dispersed to states until March 2021.

Pandemic Response Accountability Committee

Program Impact
Our work covered two school districts within the White Earth Nation Reservation: the Mahnomen
Public School District and the Waubun-Ogema-White Earth Public School District. Spending by the
Mahnomen Public School District and the
Waubun-Ogema-White Earth Public School
District encompassed over 80 percent of the
MAHNOMEN PUBLIC SCHOOLS
total ESSER funding provided to schools within
OPERATING STATUS
the White Earth Nation Reservation.
End of 2020 School Year

Mahnomen Public School District

The Mahnomen Public School District has
three schools and a total student population of
approximately 700. The district is governed by
an elected school board. As of September 30,
2021, the Mahnomen Public School District
had spent all of its ESSER I funding and about
49.8 percent of its ESSER II funding. The
district spent ESSER funds to purchase items
to assist with cleaning schools, promoting
social distancing, and improving air ventilation
within the schools. See Table 2 for details on
spending by category at the Mahnomen Public
School District.

Fully remote learning.

2020–2021 School Year
Hybrid learning, with different portions of the
student body coming into the school on different
days to manage the total number of students
in-person at one time. Also, fully in-person or fully
remote learning was offered, if chosen by the
parents.

2021–2022 School Year
In-person with hybrid options available. Fully
in-person or fully remote could be selected by
parents. In-person schooling included four inperson days and one remote day.

Table 2: White Earth Nation Reservation in Minnesota Schools ESSER Spending by Category, as of
September 30, 2021 – Mahnomen Public School District
Description

ESSER I

ESSER II

Total

Staff/Benefits

$143,914

$162,955

$306,869

Transportation

$232,261

$303,189

$535,450

Supplies/Technology

$41,900

$302

$42,202

Cleaning Services

$126,795

Building Improvements

$206,759

$418,075

$800,000

$1,218,075

Total

The Mahnomen Public School District took several actions to help with social distancing during
in-person learning. This included doubling the bus routes to reduce the number of children on a
bus at any one time and purchasing an additional bus to assist with the increase in routes, hiring

Pandemic Response Accountability Committee

additional drivers, and paying for extended driver hours. The district also decreased class sizes to
allow for social distancing, which in turn required hiring additional staff to support a larger number
of classes. In addition, the district purchased cleaning services and made updates to its buildings’
HVAC systems to improve the cleanliness and air quality in the schools.
We spoke with officials about future needs and the district’s overall response throughout the
pandemic and reviewed their ESSER III plan—required by ED. Under ESSER III requirements, at least
20 percent of those funds must be spent on mitigating the academic impacts of lost instructional
time (i.e., learning loss).
According to the ESSER III application for the Mahnomen Public School District, planned uses of the
ESSER III funds included:
• Hiring a social worker to address students’ social emotional, and physical health.
• Bringing on additional teachers to create smaller class sizes.
• Providing a six-week summer school program, through the hiring of 15 teachers to provide
instruction and clerical and paraprofessional support staff to assist with the summer school
interventions, as well as covering the associated breakfast and lunch food service costs and
transportation costs.
• Conducting an after-school tutoring program four days a week, and an after-school credit
recovery program two days a week, which required hiring additional tutors and staff and
covering the associated transportation costs to take children home after the sessions.

Waubun-Ogema-White Earth Public School District
The Waubun-Ogema-White Earth Public School District has five schools and approximately 700
students. The district is governed by an elected school board. As of September 30, 2021, the
Waubun-Ogema-White Earth Public School District
had spent all of its ESSER I funding and about
WAUBUN-OGEMA-WHITE
14.6 percent of its ESSER II funding. See Table
3 for details on spending by category at the
EARTH PUBLIC SCHOOL
Waubun-Ogema-White Earth Public School District.
DISTRICT OPERATING STATUS
According to expenditure summaries provided
by officials of the Waubun-Ogema-White Earth
Public School District, staff/benefits costs were
related to providing an additional nurse to address
pandemic-related health issues, additional staff
for childcare, and costs related to paid leave
provisions of the Families First Coronavirus
Response Act. According to school district staff,
childcare had to be provided pursuant to the

Pandemic Response Accountability Committee

End of 2020 School Year
Fully remote learning.

2020–2021 School Year
Hybrid learning through winter break, and
transition to fully in-person by the end February
2022.

2021–2022 School Year
In-person all year.

Minnesota Governor’s Emergency Executive Order 20-02, which stated “schools are directed to
provide care to, at a minimum, district-enrolled students aged 12 and under who are children of
emergency workers.” Supplies/technology costs included funding for cameras, learning apps for
online access, Wi-Fi access for students, PPE, seating for outdoor learning spaces, supplemental
classroom manipulatives, and supplies for learning packets.
Table 3: ESSER I and ESSER II Spending by Category, as of September 30, 2021 -- Waubun-Ogema-White
Earth Public School District
Description

ESSER I

ESSER II

Total

Staff/Benefits

$107,897

$2,200

$110,097

Supplies/Technology

$169,210

$165,329

$334,539

Total

$277,107

$167,529

$444,636

We also spoke with officials about future needs and the district’s overall response throughout
the pandemic, and we reviewed their ESSER III plan—required by ED. According to the ESSER III
application for Waubun-Ogema-White Earth Public School District, planned uses of the ESSER III
funds included:
• Using a family engagement and community coordinator to work with Indian Education
programs, staff, students, and parents to increase engagement and attendance.
• Implementing a blended program for pre-kindergarten and kindergarten to address COVID
learning loss.
• Providing on-site mental health services to those in need.

Participant Experience
Mahnomen Public School District
District staff noted that “one size does not fit all” when it comes to responding to a pandemic
and having flexibility regarding allowable uses of funds makes a difference. Staff stated that
use of ESSER funds was broad and they appreciated the flexibility. According to local officials,
the district was able to pivot quickly at the beginning of the pandemic to purchase items they
needed. An official told us that the district followed guidance from the State of Minnesota
Department of Education (Minnesota ED) on how to fill out applications and determine allowable
ESSER expenditures. In addition, district officials said they found value in the webinars hosted by
Minnesota ED. The question-and-answer format of the webinars helped them better understand the
guidance. While district officials said they did not have any significant issues completing required
reporting or the applications for assistance, Minnesota ED was helpful when minor issues did arise.

Pandemic Response Accountability Committee

A school official told us they felt that without the ESSER funds the school would not have been
able to take the actions that it did, including doubling the bus routes, adding staff for distance
learning, and adding cafeteria space.

Waubun-Ogema-White Earth Public School District
Officials we spoke with appreciated that Minnesota ED used similar processes for ESSER funds as
it did for other assistance. The use of the same system and a similar application made it easier for
the school officials to understand and use.
Officials from the Waubun-Ogema-White Earth Public School District also felt that the guidance
from Minnesota ED was clear. Officials stated that the state did a great job providing the guidance
regarding which costs could be funded by ESSER funds and were responsive to questions.
Overall, the school district officials felt that the ESSER funds helped, and in some cases, the
amounts were more than sufficient. Officials said the district was able to use the money in
creative ways to assist children and do things they otherwise could not have done such as
purchasing additional instructional materials. However, given the large amounts of money spent in
a short period of time, staff expressed
concern about sustainability after September
FOR MORE INFORMATION
30, 2024, including how the temporary
For more information about the Education Stabilization
nature of the funding would require them to
Fund, including Elementary and Secondary School
review and assess their priorities over time.
Emergency Relief program spending across the
country, visit the PRAC’s website.

Pandemic Response Accountability Committee

PROGRAM SNAPSHOT

Farmers to Families Food
Box Program
U.S. Department of Agriculture
At the onset of the COVID pandemic, many restaurants, hotels, schools, and other food service
entities were forced to close or scale back operations to ensure public safety. These closures had
negative impacts on the food supply chain from farmers and other producers, distributors, food
services, and hospitality entities. As a result of these supply and logistical issues, as well as reports
of produce rotting in fields, the USDA established the Farmers to Families Food Box Program (Food
Box Program) to mitigate the problems.
The purpose of the Food Box Program was to connect food—which would have otherwise been
sold to restaurants, hotels, schools, and other food service entities—to regional and local food
distributors. These distributors would purchase the food, package it in boxes, and deliver fresh
produce, dairy, and meat products to nonprofit and governmental organizations, which in turn
would distribute the boxes to families and individuals in need.24 USDA contracted directly with
the distributors to administer five rounds of the Food Box Program. According to USDA, this
program delivered approximately 176 million food boxes worth $5.47 billion to nonprofit and
governmental organizations from May 2020 to May 2021.
Figure 1: Three Primary Goals of the Food Box Program

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

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

Providing food to families in
need by delivering food boxes to
governmental and nonprofit Food
Recipient Organizations that
gave the food to families in need.

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

Pandemic Response Accountability Committee

Program Impact on the Community
To perform our work, the PRAC team used data previously collected and analyzed by USDA OIG
in PRAC’s July 2023, 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 distributors delivered 19,152 food boxes (valued at $746,982) to three recipient
organizations to feed families in the White Earth Nation Reservation community. Based on the
data obtained from USDA for these three organizations, we noted one organization, the White
Earth Nation Tribal government, participated in rounds three and five of the food box programs
while a second organization only participated in round three of the program and third organization
participated in rounds four and five of the program. See Table 4 for more information about the food
boxes that went to the White Earth Nation Reservation.
Table 4: Food Boxes Distributed to White Earth Nation Reservation in Minnesota, as of September 30, 2021
Food Recipient
Organization
White Earth Nation
Tribal government
Food Recipient
Organization 2
Food Recipient
Organization 3

Round Number

Number of Food
Boxes

Value

2,074

$120,962

2,493

$82,751

1,037

$60,481

7,448

$280,268

6,100

$202,520

19,152

$746,982

Totals

Type of Food Boxes
Delivered
Combination Box
Combination Box
Combination Box

Source: USDA OIG analysis of USDA data on the Food Box Program.

According to a Government Accountability Office (GAO) report, USDA did not collect data to
evaluate whether the Food Box Program met some of its primary goals—including assisting food
producers with declining demand.25 Similarly, the PRAC observed a lack of data in our work,
which limited our ability to determine the extent to which USDA met the Food Box Program
goals in White Earth Nation Reservation.

25 GAO, USDA Food Box Program: Key Information and Opportunities to Better Assess Performance, GAO-21-353; September 2021.

Pandemic Response Accountability Committee

Under the program structure set up by USDA, food
distributors provided 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, this structure did not provide
USDA with information about which food producers
(i.e., farmers) the program helped and how many
of those boxes were actually provided to families
(and how many families), or consistent information
about which organizations received food boxes for
distribution. Given this reporting structure, the total
number of food boxes distributed to White Earth
Nation Reservation could have been less or more
—for example, another organization not identified
in the data could have received and distributed
boxes to White Earth Nation Reservation residents,
or a lesser percentage of residents than projected
could have picked up boxes. In addition, these data
limitations prevented us from obtaining communityspecific information on the total number of
individuals or families in need served on the White
Earth Nation Reservation.

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

Participant Experience
During our field work in White Earth Nation Reservation, PRAC officials met with White Earth Nation
Tribal government officials who received and distributed boxes to the community. According to the
Tribal government officials, the food box program helped with food insecurity concerns during the
pandemic. White Earth Nation Tribal government received a total of three shipments from the Food
Box Program. A White Earth Nation Tribal government official told us that the Tribe’s EOC worked
with community councils across the reservation to distribute food boxes to community centers and
churches for Tribal members to pick up.

Pandemic Response Accountability Committee

PROGRAM SNAPSHOT

Pandemic Funding
U.S. Department of the Interior

As of September 30, 2021, DOI awarded approximately $19.6 million to the White Earth Nation
Reservation in Minnesota for its pandemic response. As the PRAC reported in Tracking Pandemic
Relief Funds that Went to Local Communities Reveals Persistent Data Gaps and Data Reliability
Issues, based on expenditure summaries from DOI’s accounting system of record, the Financial and
Business Management System, the White Earth Nation Reservation used these funds to support
day-to-day Tribal government operations, transportation, law enforcement, and education services.26
These funds were provided to the community through the following programs:
• Indian Housing Assistance
• Indian Schools Student Transportation
• Assistance to Tribally Controlled Community Colleges and Universities
• Indian Self-Determination Contract Support
See Table 5 for details on the funding awarded.

26 DOI OIG validated the accounting system’s records against data within USAspending.gov.

Pandemic Response Accountability Committee

Table 5: DOI Pandemic Funding Awarded to the White Earth Nation Tribal government, as of
September 30, 2021
Program Description

Appropriation

Awarded Amount

ARP Act

$4,938,543

Indian Housing Assistance Coronavirus Response and Relief
Supplemental Appropriations Act

$525,207

ARP Act

$2,307,100

CARES Act

$681,156

Coronavirus Response and Relief
Supplemental Appropriations Act

$952,460

Assistance to Tribally
Controlled Community
Colleges

ARP Act

$3,952,163

CARES Act

$901,719

Coronavirus Response and Relief
Supplemental Appropriations Act

$2,615,009

Indian Self-Determination
Contract Support

CARES Act

$2,718,260

Indian Schools Student
Transportation

Total

Total
$5,463,750

$3,940,716

$7,468,891

$2,718,260
$19,591,617

Program Impact on the Community
According to White Earth Nation Tribal government
officials, pandemic funding was helpful, timely,
PANDEMIC FUNDING
and sufficient to mitigate hardships encountered
According to White Earth Nation Tribal government
due to COVID. As of October 2022, the White Earth
leadership, it used DOI pandemic funding to protect
Nation Tribal government had used most of its
its elder community from COVID by adding security
funding to ensure it met program goals despite
to monitor visitor interaction at a retirement facility.
COVID challenges. One challenge leadership
identified to DOI OIG was ensuring food security
and providing traditional medicines to its citizens.27
The leadership also used pandemic funding to support what it described as underfunded law
enforcement operations. In particular, White Earth Nation Reservation officials stated that its Tribal
law enforcement program was underfunded during COVID because casino profits usually used to
cover costs decreased while the casino was closed for several months, lowering profits and

27 Traditional medicine, as defined by the World Health Organization, is the sum of knowledge, skills, and practices based on the theories, beliefs,
and experiences indigenous to different cultures, used in the maintenance of health as well as in the prevention, diagnosis, improvement, or
treatment of physical and mental health.

Pandemic Response Accountability Committee

hampering the Nation’s ability to fully fund programs reliant on casino revenue. Officials told DOI
OIG that the pandemic funding allowed for continued operations for law enforcement and increased
flexibility for new challenges. For instance, according to the Nation’s law enforcement staff,
security guards were added at a retirement facility to protect residents from possible infection from
unauthorized visitors.

Participant Experience with Programs
The White Earth Nation Reservation received funding from multiple federal agencies over a short
period. In addition to funds from DOI, the reservation also received funding from nine other
agencies totaling approximately $277.4 million.28 Tribal government officials stated that DOI funds
included some guidance; however, they also stated that overarching or detailed expenditure
guidance for all federal pandemic funding would have expedited the Nation’s response time to meet
its citizens’ needs. In April 2020, DOI’s Assistant Secretary for Indian Affairs sent a letter to Tribal
leaders outlining general funding guidance, but the letter failed to provide detailed expenditure
guidance. Instead, the letter required that funds be used for the general purposes of “prevention,
preparedness, and response to COVID–19.”
Tribal government officials stated that detailed guidance about allowable or prohibited expenses
would have helped the Tribe expend funds more efficiently. What the White Earth Nation Tribal
government officials described as the lack of detailed and uniform federal guidance may pose a
risk of misuse or mismanagement of funds.29 Without specific federal guidance for allowable and
prohibited expenses, the Nation applied its own determinations on expense allowability, which,
according to the Nation, delayed spending.
According to Tribal government leadership, the Nation did not initially know whether it could use
pandemic funds for construction purposes. Finance officials at the White Earth Tribal Community
College stated that about $7 million in Bureau of Indian Education (BIE) pandemic response
funds had been obligated but not spent because officials believed construction was a prohibited
expenditure. According to finance officials, the BIE eventually provided additional expenditure
guidance that allowed the Tribal college to apply the entire amount toward the construction of a
new cafeteria. However, the officials reported that their initial uncertainty about the allowable use of
pandemic funds caused what they described as delays in the construction of the cafeteria.30 White

28 Aside from the funding sources listed in Table 5, the White Earth Nation Reservation received funding from USDA, ED, HUD, DOL, Treasury,
U.S. Department of Transportation, U.S. Department of Health and Human Services, U.S. Department of Homeland Security, and U.S. Small
Business Administration.
29 Through other oversight work, DOI OIG noted instances in which the Bureau of Indian Affairs (BIA) may not have provided sufficient guidance
to recipients of DOI COVID funding. For example, DOI OIG performed an inspection to determine whether the BIA and BIE developed controls
to prevent or detect multi-dipping to reduce the potential for misuse of pandemic response funds. DOI OIG found that the BIA and the BIE
provided CARES Act and ARP Act FAQs guidance to Tribes, but this guidance did not state that Tribes cannot use funds from multiple federal
programs for the same expenses.
30 The college planned to begin construction on the new cafeteria in 2023.

Pandemic Response Accountability Committee

Earth Nation officials stated that these delays could have been avoided if the DOI provided clear
guidance on allowable expenditures when it awarded the funds.

FUNDING SOURCE MATRIX
The White Earth Nation Tribal government developed a matrix to spend pandemic funding from
different sources according to the allowability and expiration period. Using the matrix, Tribal
government leadership matched program needs to available funding. White Earth Nation Tribal
government officials stated that this method increased the Nation’s efficiency in spending funds
from the most restrictive sources first.

FOR MORE INFORMATION
For more information about the Department of the
Interior’s programs during the pandemic, visit the
PRAC’s website.

Pandemic Response Accountability Committee

PROGRAM SNAPSHOT

Pandemic Unemployment
Insurance Programs
U.S. Department of Labor
The federal-state UI program, created by the Social Security Act of 1935, offers an economic line of
defense against the ripple effects of unemployment. Specifically, UI benefits are intended to provide
temporary financial assistance to workers who are unemployed through no fault of their own.
On March 27, 2020, the CARES Act was signed into law with the intent to provide expanded
UI benefits to workers who were unable to work as a direct result of the COVID pandemic. The
CARES Act was designed to mitigate the economic effects of the pandemic in a variety of ways,
including the establishment of three key CARES Act UI programs: Federal Pandemic Unemployment
Compensation (FPUC), Pandemic Emergency Unemployment Compensation (PEUC) and Pandemic
Unemployment Assistance (PUA). The three programs were later extended by the Continued
Assistance for Unemployed Workers Act of 2020 (CAA) and ARP Act, ending on September 6, 2021.
The COVID pandemic was historic in its impact on the UI system. From March 28, 2020, to
September 4, 2021, the U.S. Department of Labor (DOL) reported approximately 110 million initial
jobless claims were filed for state UI (regular UI) and PUA, and 1.5 billion continued claims were
submitted for regular UI, PUA, and PEUC.31
The White Earth Nation Reservation is located in north-central Minnesota and includes all of
Mahnomen County, plus parts of Becker and Clearwater Counties. The Mahnomen County
unemployment rate was drastically impacted by the COVID pandemic. Minnesota estimated the
unemployment rate in Mahnomen County peaked in May 2020 at 25.3 percent—over 261
percent greater than the prior year’s highest monthly rate (see Table 6).

31 Regular UI, also known as state UI, is a program administered by state workforce agencies in the United States to provide temporary financial
assistance to eligible workers who have lost their jobs through no fault of their own; continued claims are ongoing weekly unemployment
benefit claims by workers who previously filed an initial claim.

Pandemic Response Accountability Committee

TTable 6: Mahnomen County and Minnesota – Unemployment Estimates

Year

Mahnomen
County Average
Unemployment Rate
(%)

Mahnomen County
Highest Monthly
Unemployment Rate
(%)

Minnesota Average
Unemployment Rate
(%)

Minnesota Highest
Unemployment Rate
(%)

2018

4.9

6.6

3.1

3.9

2019

5.0

7.0

3.4

4.4

2020

13.3

25.3

6.3

10.9

2021

5.9

9.4

3.4

5.0

Source: DOL OIG analysis of Minnesota unemployment data.

In addition to regular UI, Minnesota reported 2,324 unemployed workers in White Earth Nation
Reservation received about $25.9 million in federal UI benefits from FPUC, PUA, and PEUC (see
Table 7).32
Table 7: White Earth Nation Reservation in Minnesota – CARES Act UI Benefits
CARES Act UI Program

Total Benefits Paid

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

$18,885,300

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

$4,461,353

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

$2,553,359

Total Benefits

$25,900,012

Source: DOL OIG data analysis of Minnesota state workforce agency claims data for the period March 27, 2020, to September 6,
2021.
a PUA also included independent contractors, those with limited work history, and those who otherwise did not qualify for regular
UI or extended benefits under state or federal law or under PEUC.

32 State workforce agencies provided DOL OIG data about pandemic UI-related programs as part of a data disclosure process. The Minnesota
state workforce agency provided this data as of May 2, 2022.

Pandemic Response Accountability Committee

Program Information
To participate in these three CARES Act UI programs, states signed an agreement with DOL. State
workforce agencies, which administer unemployment programs on behalf of the state, were then
allowed to provide benefits to eligible UI claimants. DOL made funding available to cover additional
benefits, ongoing administrative costs, and reasonable implementation costs.
DOL’s Employment and Training Administration provides leadership, direction, and assistance
to state workforce agencies in the implementation and administration of state UI programs and
federal unemployment compensation programs. The Employment and Training Administration
provided program guidance to state workforce agencies through Unemployment Insurance Program
Letters, Training and Employment Notices, and webinars available through the UI community of
practice page located on the WorkforceGPS website, which is sponsored by the Employment and
Training Administration. As the CARES Act UI programs were temporary, the Employment and
Training Administration did not establish performance metrics specific to these programs.
Under these three new UI programs, claimants were required to file a UI claim to receive benefits.
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.33

Participant Experience
CARES Act UI Program Participant Assessment
To assess the new CARES Act UI programs (FPUC, PEUC, and PUA), DOL OIG judgmentally sampled
60 White Earth Nation Reservation residents (claimants).34 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, 15 (25 percent) who received benefits from at least one of the
three key pandemic UI programs chose to respond. The surveys were conducted December 5–9,
2022.
DOL OIG’s deliberative process for this project’s sample selection included removing possible
fraudulent claims to ensure interviews of only eligible UI claimants. To do so, DOL OIG used
fraud indicators. This removal also ensured that DOL OIG investigators did not impact ongoing
investigations or interact with possible subjects or targets of future DOL OIG investigations.

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
33 FPUC was provided as a supplement (or 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.
34 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

continue to receive benefits as satisfying.35 Overall, satisfaction with the UI system was rated 4.3
on a 5-point scale, with 53 percent of surveyed claimants rating their experience as extremely
satisfying (see Figure 2).
The accessibility of the UI office to answer questions and offer assistance was rated the lowest of
all aspects—20 percent of surveyed claimants rated their experiences as extremely dissatisfying.
Further, surveyed claimants identified difficulties completing the application process, such as
problems with gathering requisite information.
Figure 2: Surveyed Claimants Assessment of Claims Process

Source: DOL OIG data analysis of claimant surveys conducted December 5–9, 2022.
35 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.

Pandemic Response Accountability Committee

Surveyed Claimants Generally Felt the CARES Act UI Programs Were
Impactful, Sufficient, and Fair
The majority of surveyed claimants reported either agreeing or strongly agreeing the benefits
provided by the CARES Act had a positive impact on their ability to meet their needs, were sufficient
to pay for basic necessities, and were fair and reasonable (see Figure 3).36 The surveyed claimants
also agreed or strongly agreed that the number of weeks of benefits were provided was sufficient.
On average, 0 to 13 percent of surveyed claimants felt the benefits did not have a positive impact,
were insufficient, or were not fair and reasonable.
Figure 3: Surveyed Claimants Assessment of Benefits

Source: DOL OIG data analysis of claimant surveys conducted December 5–9, 2022.
36 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

Surveyed Claimants Generally Still Experienced Difficulty in the Labor
Market
Of those who responded, 27 percent of surveyed claimants reported they were not currently working
for pay as of December 2022, and 13 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 the surveyed claimants were
aware of the state workforce agency’s job placement services. However, Employment and Training
Administration officials reported that, during the pandemic, initial claims for federal and state
programs rose to 10 times pre-pandemic levels, far higher than state systems were designed to
handle. Therefore, processing may have impacted other services offered, such as job placement.
Figure 4: Surveyed Claimants Return to Work Assessment

Source: DOL OIG data analysis of claimant surveys conducted December 5–9, 2022.

Program Integrity
With the passage of the CARES Act and subsequent pandemic legislation, pandemic-related UI
programs became a target for fraud. DOL OIG investigators, auditors, and data scientists have
created a series of fraud indicators to identify potentially fraudulent UI claims.37
37 Importantly, this does not imply that the fraud was committed by residents of this area. According to the Employment and Training
Administration, many of the estimated fraudulent overpayments, especially those from the pandemic, involve UI identity fraud, where the
perpetrator of the fraud is unknown. Identity fraud is often perpetrated by sophisticated criminal organizations, with many of these fraud rings
operating outside of the United States.

Pandemic Response Accountability Committee

DOL OIG identified 8.1 percent of claims submitted from White Earth Nation Reservation in
Minnesota as potentially fraudulent (see Table 8).38
Table 8: White Earth Nation Reservation in Minnesota – Fraud Indicatorsa
Category

Claimants

Percent of Total

Amount Paid

2,324

$25,900,012

Multistate

2.1%

$564,824

Suspicious Email

144

6.2%

$1,639,529

State Flagged

-b

Deceased Person

-b

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

188

8.1%

$2,237,411

Total Claimants
Claimants with Fraud Indicator:

Source: DOL OIG data analysis of state workforce agency claims data for the period March 27, 2020, to September 6, 2021.
a
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.
b
No fraud indicator identified.

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

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

38 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.

Pandemic Response Accountability Committee

PROGRAM SNAPSHOT

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

Nursing homes and their residents have been among those hardest hit by the COVID pandemic,
due in part to residents’ ages and underlying medical conditions, close living quarters, and nursing
homes’ longstanding challenges with staffing and infection control.39 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, with approximately 155,000 deaths.40
The U.S. Department of Health and Human Services (HHS) OIG sample nursing home located on
the White Earth Nation Reservation has had substantial financial challenges in responding to
the pandemic.41 The facility’s leaders reported lost revenue as a result of having fewer residents
during the pandemic.42 The director of nursing explained that staffing shortages limited the number
of residents the nursing home could admit. The director also explained that, to a certain degree, the
facility was afraid to admit residents for fear of COVID, and that fear caused some family members
to remove residents from the facility or to decline admitting them altogether.
Nursing home leaders reported that, while revenue declined, expenses increased. Leaders
reported to HHS OIG that significant increases in staffing costs were the nursing home’s biggest
financial hardship during the pandemic. A leader explained
that the nursing home had ongoing staffing shortages and
Example: Increased Costs
difficulties recruiting because of the facility’s rural location,
Related to COVID
and that those shortages were exacerbated during the
pandemic. At the same time, the facility had to designate
Staffing shortages increased the use of
separate staff to work in its COVID isolation unit. Leaders
contracted staff who were up to four times
said that the staffing shortages created a reliance on
more expensive than in-house staff.
contracted staff from staffing agencies, which cost up to
39 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; CDC, People Who Live in a Nursing Home or Long-Term Care Facility; GAO, Infection Control Deficiencies
Were Widespread and Persistent in Nursing Homes Prior to COVID-19 Pandemic, GAO-20-576R, May 20, 2020, p. 1; Lauren Weber, “Nursing
Homes Keep Losing Workers,” The Wall Street Journal, August 25, 2021.
40 Centers for Medicare & Medicaid Services (CMS), COVID-19 Nursing Home Data.
41 For the purposes of HHS OIG’s review, the term “nursing home(s)” refers to facilities regardless of technical status (e.g., nursing facility)
according to common use.
42 The nursing home in HHS OIG’s sample was part of a local health system that also included other health care facility types. HHS OIG uses the
terms “leaders” and “facility leaders” throughout to refer to leaders for the nursing home, including those who manage the overarching health
system.

Pandemic Response Accountability Committee

four times more than in-house staff. They also reported incurring labor-related expenses linked to
wage increases and incentive pay for staff working in the COVID unit. Leaders described additional
increased costs and difficulty securing other items, such as PPE and food for residents.
Nursing home leaders and a staff member reported both personal and operational challenges
to providing care during the COVID pandemic. Leaders said that despite incentive pay, staff
were afraid to work in the COVID unit early in the pandemic. Leaders said that because PPE was
difficult to obtain, staff sometimes had to wear ill-fitting N95 masks or garbage bags instead of
gowns, which were physically uncomfortable. A staff member explained that donning PPE was
time consuming, and that wearing it was uncomfortable and made communicating with residents
difficult. Leaders and a staff member also described working long hours and performing irregular
duties to cover for other staff who were not at work. The director of nursing said that staff were
emotionally strained by the fear of having residents contract the virus and having to watch their
health decline. One staff member stated that “the traumatic part is not just working all the time, but
… the effect [COVID] had on residents because we care for them.” The director of nursing estimated
that roughly 25 percent of the staff left the nursing home during the pandemic, partially due to the
physical and emotional challenges caused by COVID.
Nursing home leaders, a staff member, and a resident reported that residents experienced
severe strain during the COVID pandemic. Nursing home leaders stated that transitioning
residents in and out of the COVID unit had a negative effect on residents’ mental health. They
reported that three or four residents passed away early in the pandemic, not because of COVID but
because of a “failure to thrive” caused by being isolated while sick. A staff member explained that
the residents “couldn’t come back from not seeing their family and friends. The disease itself was
tough enough, but it was more so their heartbreak from not being able to see people.” Leaders,
staff, and a resident described facility efforts to lessen the impact of the pandemic on resident
mental health. For example, leaders and a staff member noted isolating residents in their own
rooms rather than moving them to the COVID unit and working with the state to allow loved ones to
visit again. A resident reported that staff spent one-on-one time with them while in isolation so they
would not be alone.

Pandemic Response Accountability Committee

Program Information
To reimburse health care providers for pandemic-related expenses and lost revenue, Congress
appropriated $178 billion to HHS during 2020 and 2021.43 To administer the funds, HHS
established the PRF and related programs.44 The Health Resources and Services Administration
(HRSA) is the HHS agency responsible for administering the PRF program.45 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).46
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
2023.47 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 9).48 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.49

43 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).
44 HRSA administered funds for other programs, such as for the Rural Health Clinic COVID Testing and Mitigation Program, alongside PRF.
HHS also used $8.5 billion that Congress appropriated through the ARP Act of 2021 for 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.
45 86 FR 40064 (July 26, 2021).
46 HRSA, Past General Distributions, December 2021; HRSA, Past Targeted Distributions, November 2022.
47 HRSA, Provider Relief, June 2023.
48 For HHS OIG’s analysis, it reviewed payments made during the first four periods and nursing home reports on PRF use made during the first
two periods.
49 HRSA, Important Dates for Reporting, May 2023.

Pandemic Response Accountability Committee

Table 9: Timelines for Facility Receipt, Use, and Reports of PRF Payments
Period

Payment Received Period

Deadline to Use Funds

Reporting Time Period

April 10 to
June 30, 2020

June 30, 2021

July 1 to
September 30, 2021a

July 1 to
December 31, 2020

December 31, 2021

January 1 to
March 31, 2022

January 1 to
June 30, 2021

June 30, 2022

July 1 to
September 30, 2022

July 1 to
December 31, 2021

December 31, 2022

January 1 to
March 31, 2023

January 1 to
June 30, 2022

June 30, 2023

July 1 to
September 30, 2023

July 1 to
December 31, 2022

December 31, 2023b

January 1 to
March 31, 2024

January 1 to
June 30, 2023

June 30, 2024b

July 1 to
September 30, 2024

Source: HRSA, Important Dates for Reporting, December 2023.
a HRSA allowed a grace period for this reporting time period, which ended on November 30, 2021.
b PRF payments not fully expended on expenses attributable to COVID may only be applied to lost revenue up to the end of the
quarter in which the public health emergency ended (i.e., June 30, 2023). See HRSA, How to Calculate Lost Revenues for PRF
and ARP Rural Reporting, February 2023.

HRSA distributed approximately $9.4 billion in targeted PRF payments directly to nursing
homes and certified skilled nursing facilities (SNFs).50 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.51 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.52 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

50 In addition to these targeted distributions, some nursing homes may have also qualified for additional funding through general and other PRF
distributions. In June 2023, HRSA reported to OIG that HHS had obligated approximately $54.7 billion total to SNFs and nursing homes across
all PRF distributions. HRSA, Past Targeted Distributions, November 2022.
51 HRSA, Past Targeted Distributions, November 2022; CMS, Medicare Coverage of Skilled Nursing Facility Care, July 2019
52 HRSA, Acceptance of Terms and Conditions, Skilled Nursing Facility Relief Fund Payment Terms and Conditions.

Pandemic Response Accountability Committee

payments to 11,819 facilities.53 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.54

Program Impact
The nursing home on the White Earth Nation Reservation received both general and targeted
PRF payments. As of December 2021, the nursing home as part of a larger entity received a total
of $3,832,346 from general and targeted PRF distributions. Targeted payments included $130,000
from the SNF distribution and $167,955 from NHIC distributions (see Table 10).
Table 10: PRF Payments to Nursing Homesa
Total Payments Distributed to Nursing
Homes Nationally

Total Payments Distributed to the
Sample Nursing Home

SNF

$4.8 billion

$130,000

NHIC

$4.6 billion

$167,955

Otherb

$45.3 billionb

$3,534,391

Total

$54.7 billionb

$3,832,346

Distribution

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 HHS OIG in June 2023 the total amount paid to nursing homes but does not publicly
report total amounts distributed to specific provider types for general distributions. 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 distributions—that may have gone to those facilities.

The nursing home reported to HRSA that it spent all the PRF payments it received during the
first two periods and used the money for COVID related expenses and lost revenue. The nursing
home in HHS OIG’s sample was part of a local health system that also included a hospital and an
assisted living facility. Leaders for the overarching health system gathered input from staff and
determined for which expenses to use PRF. Those leaders reported PRF use collectively for all
system components, including the nursing home, to HRSA.

53 HRSA, Past Targeted Distributions, November 2022.
54 HRSA, Acceptance of Terms and Conditions, Skilled Nursing Facility and Nursing Home Infection Control Relief Fund Payment Terms and
Conditions.

Pandemic Response Accountability Committee

At the time of HHS OIG’s data collection, PRF recipients were 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 analysis included only facility reports made during the first two periods. The health
system’s reports showed that the system, including the nursing home, used all the funds it received
during the first two periods. Specifically, the health system reported using $3,800,019 in total
PRF payments, including $255,130 in payments targeted to nursing facilities ($130,000 in SNF
payments and $125,130 in NHIC payments) and $10,498 in interest earned on PRF payments.55
The health system reported using the payments to cover lost revenue, 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 health system reported
using:
• Its NHIC payments ($125,130) to offset health care-related expenses for the nursing home,
such as expenses for medical supplies and equipment.
• Most of the other payments it received ($3,674,889) for health care related expenses
($1,743,790) and to offset COVID related lost revenue ($1,499,288). The health system also
used $431,811 for general and administrative expenses, such as payroll.
Leaders at the nursing home said HRSA’s guidance on allowable uses and reporting
requirements was sometimes unclear. Leaders reported that they often had little or no notice that
they would receive PRF payments, and that HRSA’s guidance and communication about allowable
uses of the funds were often lacking or unclear. The chief executive officer of the health system
explained that sometimes it was even unclear whether a payment was meant to be used by the
nursing home or the hospital. Leaders said the unclear guidance made them hesitant to use the
funds for fear that they would use the money incorrectly and be forced to pay it back. They said that
although HRSA provided additional guidance as time went on, the guidance frequently changed
and was difficult to monitor given their other duties. Monitoring PRF guidance and reporting on PRF
use was tedious, they added, and had to be done in addition to an already “incredible” amount of
COVID-related data tracking and reporting.
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 reports the health system made to HRSA during the first two reporting periods,
along with summary supporting documentation. HHS OIG did not audit the system’s financial
reports or supporting documents. HHS OIG observed that the information the system reported
to HRSA about its use of the SNF and NHIC payments was generally supported by underlying
facility data and appeared to align with the allowable uses of the distributions. Documentation
also generally supported that the nursing home used NHIC payments for infection control-related
expenses, as intended. Although the reported expenses were supported by facility documentation,
the dates those expenses were incurred did not appear to be consistent with the reports.
55 These figures do not match the figures in Table 10 because the facility was not yet required to report its use of the remaining funds of
approximately $40,000 during the first two reporting periods.

Pandemic Response Accountability Committee

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
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 riskbased 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: Results of Interviews with the Nursing
Home on the White Earth Nation Reservation
PRF payments have been integral to the nursing home’s pandemic response, according to
facility leaders and a staff member representing the nursing home. Leaders reported that the
PRF payments helped the facility manage the COVID crisis, improve infection control practices,
and maintain resident safety and care. They reported that the PRF funds allowed the facility to
better support staff by providing higher wages and pay bonuses. Leaders also said that the funds
allowed the facility to purchase equipment, such as disinfection devices and computer tablets
that allowed residents to participate in activities and communicate with family members. A staff
member indicated that facility leaders sent emails to staff that said how grateful they were for the
PRF payments. The staff member also reported that the PRF payments were “very successful” and
that the bonuses the facility provided to staff were a “nice little hurrah” for front-line workers putting
themselves at risk.
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. The finance
director for the health system reported that, at the time of HHS OIG’s data collection, the facility
was still paying increased care-related costs as a result of COVID and inflation. Furthermore, one
leader stated that although the PRF payments allowed the facility to increase wages to recruit and
retain staff, it had become difficult to maintain
the higher pay when the PRF funds were no longer
FOR MORE INFORMATION
available. The leader also said that additional relief
funding would help the facility address long-term
For more information about Provider Relief Fund
COVID-related costs.
program spending across the country, visit the PRAC’s
website, including an interactive dashboard.

Pandemic Response Accountability Committee

Appendix A: Acronyms and
Abbreviations
ARP Act

American Rescue Plan Act of 2021

Authority

White Earth Housing Authority

BIA

Bureau of Indian Affairs

BIE

Bureau of Indian Education

CARES Act

Coronavirus Aid, Relief, and Economic Security Act

CIGIE

Council of the Inspectors General on Integrity and Efficiency

COVID-19

coronavirus disease 2019

CRF

Coronavirus Relief Fund

CSP

COVID-19 Supplemental Payments

DOI

U.S. Department of the Interior

DOL

U.S. Department of Labor

U.S. Department of Education

EOC

emergency operations center

ESSER

Elementary and Secondary School Emergency Relief

FAQ

Frequently Asked Question

Food Box Program

Farmers to Families Food Box Program

FPUC

Federal Pandemic Unemployment Compensation

GAO

U.S. Government Accountability Office

GEER

Governor’s Emergency Education Relief

HHS

U.S. Department of Health and Human Services

HRSA

Health Resources and Services Administration

HUD

U.S. Department of Housing and Urban Development

IHBG

Indian Housing Block Grant

Pandemic Response Accountability Committee

Minnesota ED

State of Minnesota Department of Education

NHIC

Nursing Home Infection Control

OIG

Office of Inspector General

PEUC

Pandemic Emergency Unemployment Compensation

PPE

personal protective equipment

PRAC

Pandemic Response Accountability Committee

PRF

Provider Relief Fund

PUA

Pandemic Unemployment Assistance

QIP

Quality Incentive Payment

SNF

skilled nursing facility

Treasury

U.S. Department of the Treasury

TDHE

Tribally Designated Housing Entity

unemployment insurance

USDA

U.S. Department of Agriculture

Pandemic Response Accountability Committee

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

Pandemic Response Accountability Committee

• Indian Self-Determination Contract Support | U.S. Department of the Interior
• Pandemic Unemployment Insurance | U.S. Department of Labor
• Provider Relief Fund Payments to Nursing Homes | U.S. Department of Health and Human
Services
More information about the scope and methodology for phase two of this review can be found in our
March 2024 report.

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

Standards
Each OIG and the PRAC conducted this study in accordance with its own respective processes
and standards to ensure that all the contributions to this report met quality standards issued
in accordance with the generally accepted government auditing standards, the Council of the
Inspectors General on Integrity and Efficiency’s (CIGIE) Quality Standards for Inspection and
Evaluation, and internal OIG guidance. All these standards required that we plan and perform this
study to obtain sufficient and appropriate evidence to provide a reasonable basis for the insights
and conclusions. This work was completed between October 2021 and May 2024 and complies
with the CIGIE’s Quality Standards for Inspection and Evaluation.

Indian Housing Block Grant – CARES Act | U.S. Department
of Housing and Urban Development, Office of Inspector
General
Methodology
Scope | HUD OIG conducted the review remotely from October 2022 through May 2023. Its review
covered the White Earth Housing Authority’s use of IHBG CARES Act funds from program inception

Pandemic Response Accountability Committee

through September 30, 2021. Its review objectives were to determine whether the Authority spent
IHBG CARES Act funds in alignment with program goals and objectives and whether the funds
positively or negatively impacted its ability to respond to the coronavirus.
Methodology | To accomplish HUD OIG’s review objectives, it:
• Reviewed applicable HUD requirements.
• Interviewed HUD staff to gain an understanding of the goals and objectives for the IHBG
CARES Act funding.
• Interviewed the Authority’s former executive director, who was in the role when federal funds
were received, to obtain an understanding of how the Authority used the IHBG CARES Act
funds.
• Reviewed the Authority’s Indian housing plans, annual performance plans, and financial
reports.
• Reviewed supporting documentation for a sample of IHBG CARES Act expenses, including
ledgers, invoices, and contracts.
The review universe consisted of 159 expenditure transactions totaling more than $1 million
between May 5, 2020, and September 30, 2021. HUD OIG selected a statistical sample of 48
expenditures totaling $535,535 for review.56 It then reviewed supporting documentation for all
expenditures in its sample to determine whether the Authority used IHBG CARES Act funds in
alignment with the program goals and objectives.
To achieve its objective, HUD OIG relied in part on the Authority’s computer-processed data.
Although it did not perform a detailed assessment of the reliability of the data, it determined that
the data were 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. Its objective was not
to evaluate or provide assurance of the Authority’s internal controls. Therefore, it did not assess the
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 HUD OIG 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). It believes the evidence obtained provides a reasonable basis for its conclusions based
on its objectives.
56 Total cost for purchasing and installing the modular homes exceeded the Authority’s IHBG CARES Act funds. The Authority paid for the cost
overage using its general fund.

Pandemic Response Accountability Committee

Coronavirus Relief Fund | U.S. Department of the Treasury,
Office of Inspector General
Objectives/Scope/Methodology
Treasury OIG’s objectives were to determine whether subrecipients and beneficiaries located
in White Earth Nation Reservation used CRF award funds in alignment with program goals and
objectives and whether they believe that CRF funding impacted (positively or negatively) their ability
to respond to the pandemic.
The scope of its engagement covered CRF expenditures reported in GrantSolutions from March 1,
2020 (cycle 1) through June 30, 2022 (cycle 9). For the review, Treasury OIG selected a sample of
$1.3 million (3.9 percent) of $33.43 million in CRF expenditures, representing all payment types for
a casino, various other subrecipients and beneficiaries geographically located within White Earth
Nation Reservation, and White Earth Nation Tribal government itself as a subrecipient, to determine
whether CRF award funds were used in alignment with the program’s goals and objectives.57
To accomplish these objectives, Treasury OIG performed the following activities during engagement
fieldwork conducted from October 2022 through November 2023:
• Reviewed Title VI of the Social Security Act, as amended by Title V of Division A of the CARES
Act58
• Reviewed the Consolidated Appropriations Act, 202159
• Reviewed Treasury’s Guidance and FAQs published in the Federal Register, Volume 86, No. 10
(January 15, 2021)
• Reviewed White Earth Nation Tribal government's policies and procedures for administering
CRF
• Interviewed subrecipient officials regarding use of the CRF award funds, experience, and
impact
• Reviewed Minnesota’s and White Earth Nation Tribal government's Single Audit Reports for
fiscal years 2020, 2021, and 2022 to assess findings that may pose risk to the subrecipients’
and beneficiaries’ uses of CRF award funds
• Reviewed media reports associated with the COVID pandemic and CRF impacts within White
Earth Nation Reservation
• Reviewed supporting documentation to determine if the selected sample were (1) necessary
expenditures incurred due to the public health emergency with respect to COVID; (2) for costs
not accounted for in the recipients’ budget most recently approved as of March 27, 2020; and
57 Direct payments, transfers, grants, aggregate payments to individuals, and aggregate direct payments.
58 P.L. 116-136 (March 27, 2020).
59 P.L. 116-260 (December 27, 2020).

Pandemic Response Accountability Committee

(3) for costs incurred from March 1, 2020, to December 31, 2021, for non-tribal recipients
and in the case of Tribal recipients, costs incurred from March 1, 2020 to December 31,
2022. (Supporting documentation includes invoices, purchase orders, emergency financial
assistance application packages, checks, and data extracts from Minnesota’s and White Earth
Nation Tribal government's accounting systems.)

Standards
Treasury OIG conducted this engagement in accordance with CIGIE’s Quality Standards for
Inspection and Evaluation.

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 two school districts that fall within the boundaries
of the White Earth Nation Reservation—Mahnomen School District and Waubun-Ogema-White Earth
School District (the districts)—and their use of ESSER funding from program inception through
September 30, 2021. Our objectives were to identify how the districts used the ESSER funding it
received, and to determine whether the districts generally spent ESSER funds in alignment with
program goals and objectives. The PRAC staff coordinated this work with ED OIG.
Methodology | To fulfill these objectives, we:
• Reviewed applicable ESSER guidance including FAQs, Elementary and Secondary School
Emergency Relief Program and Governor’s Emergency Education Relief Programs issued in
May 2021 and revised on December 7, 2022.
• Obtained summary descriptions of ESSER spending from both districts.
• Determined if funding use descriptions aligned with ESSER’s objectives of helping the districts
prepare for, and respond to coronavirus, domestically or internationally.
• Interviewed both districts’ officials from the Circle of Life Academy that is located on the
reservation and Minnesota ED officials about uses of funds as well as the effects the ESSER
funds had on the districts’ ability to respond to the pandemic.

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

Pandemic Response Accountability Committee

Farmers to Families Food Box Program | Pandemic
Response Accountability Committee and U.S. Department of
Agriculture, Office of Inspector General
Methodology
Scope | The PRAC and USDA OIG’s review covered the use and impact of USDA’s Food Box Program
and its rounds of funding provided to the White Earth Nation Reservation community from May
15, 2020, through May 31, 2021. Our objectives were to identify how many food boxes went
to the reservation and whether the program served producers, distributors, and food recipient
organizations as intended.
Methodology | To fulfill the objectives, 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 White Earth Nation Reservation community.
• Interviewed a food box recipient organization to determine how the Food Box program helped
White Earth Nation Reservation respond to the pandemic.
• Worked with USDA OIG to obtain data about the total number of food recipients and to ensure
that we fully understood the program objectives and structure.

Data Limitations
We used data collected and analyzed by USDA OIG during part one of this case-study-based
review. Part one of this review introduced data limitations which prevented us from determining if
the program served producers, distributors, and 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

Pandemic Funding | U.S. Department of the Interior, Office of
Inspector General
Methodology
Scope | DOI OIG reviewed the purpose and resulting community impacts of DOI pandemic response
funds provided to the White Earth Nation Reservation as of September 30, 2021. DOI OIG focused
its review on the impact that $19.6 million in funding had on the White Earth Nation programs and
the experiences of community stakeholders. (See Table 5 on page 24 for program funding details.)
Due to the limited scope of this review and collaboration with other agencies, DOI OIG did not
evaluate if expenditures were allowable according to fund source requirements. It spoke with
program managers to obtain their perspective on the impact funds had on programs and reviewed
funding and expenditure summaries.
Methodology | To accomplish its objective, DOI OIG:
• Traveled to the White Earth Nation Reservation and interviewed officials responsible for
programs that received DOI pandemic funding.
• Gathered and reviewed pandemic response legislation, funding summaries, and program
descriptions.
• Identified and reviewed DOI and other federal guidance related to pandemic response funding.
• Determined the community’s general use of funds through interviews and review of budgetary
reports.

Limitations
Based on the scope of this review, DOI OIG did not examine the accuracy or allowability of Tribal
expenditures. It also did not examine the federal pandemic response funds provided by other
agencies.
Data Quality | DOI OIG pulled funding data from DOI’s Financial and Business Management System
and validated it based on USAspending.gov data.

Standards
DOI OIG conducted this evaluation in accordance with CIGIE’s Quality Standards for Inspection
and Evaluation. DOI OIG believes that the work performed provides a reasonable basis for its
conclusions.

Pandemic Response Accountability Committee

Pandemic Unemployment Insurance | U.S. Department of
Labor, Office of Inspector General
Methodology
Scope | The evaluation covered DOL’s UI response to the COVID pandemic. Specifically, DOL OIG
reviewed federal UI benefits from the following three key CARES Act UI programs: FPUC, PEUC,
and PUA. 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, PEUC, or PUA.
Methodology | To answer the objective, the DOL OIG team reviewed the CARES Act, Continued
Assistance for Unemployed Workers Act of 2020, ARP Act of 2021, 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 DOL OIG data scientists to assess claimants in the designated area for several key fraud
indicators.
To assess the participants’ experiences with the three key CARES Act UI programs in the designated
geographic areas, DOL OIG judgmentally selected 60 claimants with whom DOL OIG investigators
performed on-site interviews.60 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.
DOL OIG investigators traveled to the area and performed in-person interviews with the claimants.
The surveys were conducted December 5–9, 2022. The survey results were then aggregated to
present an overall depiction of the participants’ experiences in the area.

Data Limitations
Because 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.
60 Judgmental sampling is a nonprobability sampling technique in which the sample members are chosen on the basis of the auditor’s knowledge
and judgment

Pandemic Response Accountability Committee

Standards
DOL OIG conducted this study in accordance with CIGIE’s Quality Standards for Inspection and
Evaluation. Those standards require that DOL OIG plans and performs the review to obtain
sufficient, appropriate evidence to provide a reasonable basis for its findings and conclusions based
on its objective.

Provider Relief Fund Payments to Nursing Homes | U.S.
Department of Health and Human Services, Office of Inspector
General
Scope
HHS OIG examined the use of targeted PRF payments to one nursing home located on the White
Earth Nation Reservation during calendar years 2020 and 2021. The selected facility was the
only facility within the White Earth Nation Reservation that received direct PRF payments through
distributions that HHS targeted for nursing homes and certified SNFs.61 HHS OIG conducted
its data collection concurrently with the PRAC’s site visit to the White Earth Nation Reservation
during October 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, a staff member, and a resident regarding whether the PRF payments helped them prevent,
prepare for, and respond to COVID, and whether the facility complied with terms and conditions
related to PRF use.

Methodology
Data Sources
Interviews
To evaluate the nursing home’s use of PRF payments, HHS OIG interviewed leadership, a staff
member, and a resident 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.
61 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 the White Earth Nation Reservation 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

Nursing Home Interviews | HHS OIG conducted group interviews with facility leaders and an
individual interview with a staff member in the selected nursing home. Participants included
leadership for the broader health system and the nursing home specifically, as well as a staff
member from the nursing home. HHS OIG also conducted an interview with a resident 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. During the interviews, it 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 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 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,

Pandemic Response Accountability Committee

2022, and, depending on whether the payments were made electronically or by check, was 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 it to conduct an initial analysis prior to the site visits.

Data Analysis
HHS OIG conducted a qualitative analysis of interview data and documentation from the nursing
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 reports and supporting material.

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

Pandemic Response Accountability Committee

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

Visit us at:
PandemicOversight.gov

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

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

File and source

File: 2025-03-04-six-communities-white-earth-nation-mn.pdf
Size: 1,528,688 bytes
SHA-256: e032e940cb2cd0f886f16f47657e877d280a2b56d94a5988ab7d9bf8fe76870c
Our copy: 2025-03-04-six-communities-white-earth-nation-mn.pdf
Original: www.oversight.gov

A Review of Pandemic Relief Funding and How It Was Used in Six U.S. Communities: White Earth Nation Reservation in Minnesota

Summary

Full text

File and source

Related records