COVID-19 Relief: State and Local Fiscal Recovery Funds (GAO)
Summary
GAO-24-106027, a GAO report to congressional addressees dated December 14, 2023, reviews Treasury's administration and oversight of the Coronavirus State and Local Fiscal Recovery Funds (SLFRF). The American Rescue Plan Act of 2021 appropriated $350 billion for SLFRF, of which $325.5 billion was allocated to state and local governments. As of March 31, 2023, states reported obligating 60 percent and spending 45 percent of their awards, and localities 54 percent and 38 percent. Of officials GAO interviewed in 18 states and 18 localities, those in some states said performance indicators do not always align with their uses of awards, and those in most states said Contact Center assistance was not timely. GAO finds Treasury did not document changed monitoring procedures or issue timely management decisions on single audit findings; Treasury generally agreed with its four recommendations.
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United States Government Accountability Office
Report to Congressional Addressees
COVID-19 RELIEF
December 2023
Treasury Could
Improve Its
Administration and
Oversight of State and
Local Fiscal Recovery
Funds
GAO-24-106027
December 2023
COVID-19 RELIEF
Treasury Could Improve Its Administration and
Oversight of State and Local Fiscal Recovery Funds
Highlights of GAO-24-106027, a report to
congressional addressees
Why GAO Did This Study What GAO Found
In March 2021, the American Rescue Nearly all—$325.5 billion—of the $350 billion in State and Local Fiscal Recovery
Plan Act of 2021 appropriated $350 Funds (SLFRF) was allocated to state and local governments. As of March 31,
billion through the SLFRF to help tribal 2023, states reported obligating 60 percent and spending 45 percent of SLFRF
governments, states, localities, the awards they received. Localities reported obligating 54 percent and spending 38
District of Columbia, and U.S. percent, of SLFRF awards they received. Recipients have until December 31,
territories cover costs stemming from 2024, to obligate, and until December 31, 2026, to spend their awards.
the health and economic effects of the
COVID-19 pandemic. Officials in all 18 selected states and most larger selected localities GAO
reviewed said they expanded their capacity to manage their awards, such as by
The CARES Act includes a provision
reassigning existing or hiring new staff. Officials in most smaller localities said
for GAO to report on its ongoing
they administered their SLFRF awards with their existing staff and processes.
monitoring and oversight efforts related
to the pandemic. GAO was also asked Officials in most selected states and localities told GAO they benefitted from
to review Treasury’s administration of using their SLFRF awards to replace revenue lost during the pandemic—an
SLFRF. This report, part of a series on allowable use under the SLFRF program. Specifically, they said that using funds
COVID-19 assistance to recipients, to replace lost revenue (1) enhanced spending flexibilities by allowing funding of
examines selected states’ and a broad range of government services; and (2) made it easier to meet the
localities’ (1) actions to administer their Department of the Treasury’s reporting requirements.
awards, and (2) benefits and
challenges they experienced, as well State and local officials identified a range of challenges in using their SLFRF
as (3) Treasury’s plan to monitor the awards, such as those related to
use of awards and the extent to which
it has been implemented. • Performance indicators. Officials in some selected states and one selected
locality told GAO that the performance indicators they are required to report
GAO reviewed documents and do not always align with their uses of SLFRF awards. Treasury established
interviewed officials in 18 states and 18 these indicators to understand and aggregate program outcomes across
localities (one per state) selected SLFRF recipients. However, some selected state and local officials said they
based on SLFRF funding amount, needed clarity from Treasury on how to report on required performance
population size, and geographic
indicators when they do not align with their uses of SLFRF awards and
region. Combined, these states
spending categories. Based on GAO’s analysis, Treasury updated its
represent nearly 60 percent of the U.S.
population and were allocated 60 guidance on November 30, 2023, to clarify reporting on these indicators.
percent of SLFRF funds. GAO also • Treasury assistance. Officials in most selected states and some selected
reviewed Treasury’s policies and localities told GAO that the assistance Treasury provided by telephone or
procedures for monitoring recipients’ email through its Contact Center was not timely and did not meet their needs.
award uses and reviewing spending Treasury established the center to field and respond to recipients’ inquiries
reports and single audit findings.
about programs administered by Treasury, but these officials said limited
What GAO Recommends resources affected Treasury’s assistance. Treasury has assessed some, but
not all, of its staffing needs, limiting its ability to provide timely and useful
GAO is making four recommendations assistance going forward.
to Treasury, including assessing future
Contact Center staffing needs and Treasury has established monitoring procedures for reviewing states’ and
improving the documentation and localities’ spending reports and annual single audit findings. Treasury modified its
timeliness of award monitoring procedures for reviewing spending reports, adapting to lessons it learned.
processes. Treasury generally agreed However, it did not document those changes in key internal program guidance,
with the four recommendations. creating a risk that the new procedures will not be implemented consistently.
Additionally, Treasury did not issue timely management decisions pertaining to
SLFRF findings in recipients’ single audit reports. As a result, Treasury does not
View GAO-24-106027. For more information,
contact Jeff Arkin at (202) 512-6806 or have reasonable assurance that unallowable uses of funds are identified or
ArkinJ@gao.gov or M. Hannah Padilla at (202) remediated.
512-5683 or PadillaH@gao.gov.
United States Government Accountability Office
Contents
Letter 1
Background 7
Officials in All Selected States and Localities Reported Taking a
Range of Steps to Administer Their SLFRF Awards 15
Officials in Selected States and Localities Identified Benefits and
Challenges in Administering Their SLFRF Awards 20
Treasury Has Not Fully Implemented Its Plan to Monitor
Recipients’ Use of SLFRF Funds 35
Conclusions 46
Recommendations for Executive Action 47
Agency Comments and Our Evaluation 47
Appendix I Comments from the Department of the Treasury 53
Appendix II GAO Contacts and Staff Acknowledgments 56
Figures
Figure 1: Coronavirus State and Local Fiscal Recovery Fund
(SLFRF) Allocation Amounts for Selected States 3
Figure 2: Coronavirus State and Local Fiscal Recovery Fund
(SLFRF) Allocation Amounts and Jurisdiction Type in
Selected Localities 5
Figure 3: Coronavirus State and Local Fiscal Recovery Funds
Allocations by Recipient Type 8
Figure 4: Coronavirus State and Local Fiscal Recovery Funds
Spending Categories in Treasury Project and
Expenditure Reports, as of Mar. 31, 2023 12
Figure 5: Structural Overview of Treasury’s Office of Recovery
Program’s (ORP) Single Audit Dashboard 42
Figure 6: Timeline for Management Decisions for Single Audit
Findings Reported for Fiscal Years Ending June 30, 2021 45
Page i GAO-24-106027 COVID-19 Relief
Abbreviations
ARPA American Rescue Plan Act of 2021
FAC Federal Audit Clearinghouse
FY fiscal year
IFR interim final rule
NEU non-entitlement unit of local government
OCA Office of Capital Access
OMB Office of Management and Budget
ORP Office of Recovery Programs
Q2 second quarter
SAM.gov System for Award Management
SLFRF Coronavirus State and Local Fiscal Recovery Funds
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Page ii GAO-24-106027 COVID-19 Relief
Letter
441 G St. N.W.
Washington, DC 20548
December 14, 2023
Congressional Addressees
The COVID-19 pandemic caused a serious public health crisis and had a
rapid and severe effect on the U.S. economy, including state and local
governments. In March 2021, the American Rescue Plan Act of 2021
(ARPA) appropriated $350 billion for the Coronavirus State and Local
Fiscal Recovery Funds (SLFRF) to help tribal governments, states,
localities, the District of Columbia, and U.S. territories cover costs
stemming from the negative health and economic effects of the
pandemic. 1 Nearly all of those funds—$325.5 billion—were allocated to
state and local governments. The Department of the Treasury (Treasury)
is responsible for distributing SLFRF awards to recipients and overseeing
their use of the funds.
The CARES Act includes a provision for us to report on our ongoing
monitoring and oversight efforts related to the COVID-19 pandemic. 2 We
were also asked to review Treasury’s administration of the SLFRF
program. This report examines selected states’ and localities’ (1) actions
to administer their SLFRF awards, and (2) benefits and challenges
encountered in administering their SLFRF awards, as well as (3)
1Pub. L. No. 117-2, tit. IX, subtit. M, § 9901, 135 Stat. 4, 223 (2021), codified at 42 U.S.C.
§§ 802-803 (ARPA). Sections 602 and 603 of the Social Security Act, as added by section
9901 of ARPA, appropriated $350 billion in total funding for two funds—the Coronavirus
State Fiscal Recovery Fund and the Coronavirus Local Fiscal Recovery Fund. For
purposes of this report, we discuss these two funds as one—the SLFRF. See 42 U.S.C.
§§ 802-803. For purposes of the SLFRF, ARPA establishes that the District of Columbia is
considered to be a state. 42 U.S.C. §§ 802(g)(5), 803(g)(9).
2Pub. L. No. 116-136, § 19010(b), 134 Stat. 281, 580 (2020), which is reprinted in 31
U.S.C. § 712 note. We regularly issue government-wide reports on the federal response to
the COVID-19 pandemic. For the latest report, see GAO, COVID-19: GAO
Recommendations Can Help Federal Agencies Better Prepare for Future Public Health
Emergencies, GAO-23-106554 (Washington, D.C.: July 11, 2023). As part of our work, we
have also issued reports on recipients’ (including tribal governments, states, localities, and
U.S. territories) uses of COVID-19 funds. All of our reports related to the COVID-19
pandemic are available at https://www.gao.gov/coronavirus.
Page 1 GAO-24-106027 COVID-19 Relief
Treasury’s plan to monitor states’ and localities’ use of SLFRF awards
and the extent to which it has been implemented. 3
To address our first two objectives, we interviewed officials responsible
for administering SLFRF awards in selected states and localities.
Specifically, we interviewed officials in budget offices in 18 states:
Arizona, Arkansas, California, Connecticut, Florida, Illinois, Maine,
Maryland, Michigan, Minnesota, Nebraska, Nevada, New York, North
Carolina, Pennsylvania, Texas, Washington, and Wyoming. 4 We based
our selection on a range of factors, including
• range in the amount of SLFRF allocations states received (based on
Treasury data); 5
• range in the percentage of the U.S. population represented (based on
Census Bureau data); 6
• range in unemployment rates (based on Bureau of Labor Statistics
data); 7 and
• geographic region (based on Census Bureau data).
Combined, the 18 states were allocated 60 percent of SLFRF funds and
represent about 60 percent of the U.S. population. Figure 1 provides a
3We excluded tribal governments, U.S. territories, and local governments in the territories
from our review. We reported on federal agencies’ distribution of COVID-19 relief funds,
including the SLFRF, to tribal recipients in GAO, COVID-19 Relief Funds: Lessons
Learned Could Improve Future Distribution of Federal Emergency Relief to Tribal
Recipients, GAO-23-105473 (Washington, D.C.: Dec. 15, 2022). We also recently
reported on the U.S. territories’ use of COVID-19 relief funds, including the SLFRF. See
GAO, COVID-19: U.S. Territory Experiences Could Inform Future Federal Relief,
GAO-23-106050 (Washington, D.C.: Sept. 19, 2023).
4We also recently issued a report on the experiences of eight of these states in managing
and using funds across COVID-19 relief programs: California, Florida, Illinois, Minnesota,
New York, Pennsylvania, Texas, and Washington. For additional information, see GAO,
COVID-19 Relief Funds: State Experiences Could Inform Future Federal Relief Funding,
GAO-24-106152 (Washington, D.C.: Nov. 15, 2023).
5We grouped the states according to low, medium, and high SLFRF awards, based on our
calculation of the percentage of total state SLFRF allocations that each state received.
6We grouped the states according to low, medium, and high populations, based on the
state’s percentage of the national population estimate.
7We grouped the states according to low, medium, and high unemployment rates, based
on the Bureau of Labor Statistics reported average unemployment rates for 2021.
Page 2 GAO-24-106027 COVID-19 Relief
breakdown of the selected states in our review and their SLFRF allocation
amounts.
Figure 1: Coronavirus State and Local Fiscal Recovery Fund (SLFRF) Allocation Amounts for Selected States
Note: States’ SLFRF allocation amounts are rounded to the nearest $100 million.
Page 3 GAO-24-106027 COVID-19 Relief
We also interviewed local officials in one randomly selected locality in
each of the 18 selected states. Using Treasury data, we based our
selection on (1) type of jurisdiction—metropolitan city (which we refer to
as a city throughout this report), county, and smaller unit of government,
referred to as non-entitlement unit of local government (NEU)—and (2)
range in the amounts of SLFRF awards each jurisdiction received—large,
medium, small. 8 We selected six localities within each of the three types
of jurisdictions, which resulted in: two large, medium, and small cities; two
large, medium, and small counties; and two large, medium and small
NEUs. 9 Figure 2 provides a breakdown of these localities by their
jurisdiction types and SLFRF allocation amounts.
8A metropolitan city is defined as the central city within a metropolitan area (i.e., a
standard metropolitan statistical area as established by the Office of Management and
Budget) or any other city within a metropolitan area that has a population of 50,000 or
more. 42 U.S.C. §§ 803(g)(4), 5302(a)(4). A metropolitan city includes cities that relinquish
or defer their status as a metropolitan city for purposes of receiving allocations under 42
U.S.C. § 5306, for fiscal year 2021. NEUs are local governments typically serving
populations of less than 50,000. 42 U.S.C. §§ 803(g)(5), 5302(a)(5). NEUs include cities,
villages, towns, townships, or other types of local governments.
9For the purposes of our selection, we considered small to be within the bottom 25th
percentile of SLFRF allocation amounts received; medium to be between the 40th and 60th
percentiles of SLFRF allocation amounts received; and large to be within the top fifth
percentile of SLFRF allocation amounts received.
Page 4 GAO-24-106027 COVID-19 Relief
Figure 2: Coronavirus State and Local Fiscal Recovery Fund (SLFRF) Allocation Amounts and Jurisdiction Type in Selected
Localities
a
A non-entitlement unit refers to a non-entitlement unit of local government as defined in 42 U.S.C. §
803(g)(5).
b
For the purposes of this report, city refers to a metropolitan city as defined in 42 U.S.C. § 803(g)(4).
Page 5 GAO-24-106027 COVID-19 Relief
For the purposes of our state and locality sample selections, we
determined that the Census Bureau, Treasury, and Bureau of Labor
Statistics data we used were sufficiently reliable for the purposes of this
report. Our data reliability assessments included reviewing relevant
documentation, interviewing relevant agency officials, and reviewing the
data for obvious errors or outliers.
We developed and administered a semi structured interview to budget
and related officials responsible for administering SLFRF awards in each
of the 18 selected states and 18 selected localities. Specifically, we asked
about steps they took to administer their SLFRF awards and any benefits
and challenges they encountered in administering their awards. 10 We also
analyzed related documents from these selected states and localities.
Throughout this report, we use the terms “some” and “most” to
characterize the number of states or localities that were similarly situated
for a particular issue. Unless otherwise noted, we defined “some” to
characterize between two and nine states or localities and “most” to
characterize 10 or more states or localities. The results of these
interviews are not generalizable to all states and localities.
To address our third objective, we reviewed Treasury’s processes for
reviewing SLFRF recipients’ reporting to Treasury and their single audit
reports; policies and procedures outlining the steps to be performed for
those processes; and summary documentation of those reviews as
implemented. 11 We compared Treasury’s processes to criteria outlined in
federal law, Office of Management and Budget (OMB) and Treasury
guidance, and Standards for Internal Control in the Federal
Government. 12
10To provide context for and supplement our understanding of states’ and localities’
administration of their SLFRF awards, we met with a number of associations that
represent state and local governments, which included the National Association of
Counties; Government Finance Officers Association; National League of Cities; National
Association of State Auditors, Comptrollers, and Treasurers; International City/County
Management Association; National Governors Association; and the Association of Local
Government Auditors.
11The Single Audit Act establishes requirements for nonfederal entities that receive federal
awards to undergo single audits (or, in limited circumstances, program-specific audits) of
those awards annually (unless a specific exception applies) when they spend at least
$750,000 in federal awards in their fiscal year. 31 U.S.C. §§ 7501-06.
12GAO, Standards for Internal Control in the Federal Government, GAO-14-704G
(Washington, D.C.: Sept. 10, 2014).
Page 6 GAO-24-106027 COVID-19 Relief
To address all objectives, we interviewed officials from Treasury’s Office
of Recovery Programs and Office of Inspector General.
We conducted this performance audit from May 2022 to December 2023
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
Background
SLFRF Allocations and Under ARPA, $325.5 billion of the $350 billion appropriated for the
Distributions SLFRF was allocated to the 50 states and the District of Columbia and
30,678 localities. 13 Localities consist of metropolitan cities (which we refer
to as cities throughout this report), counties, and smaller local
governments—those typically serving populations of less than 50,000—
referred to as non-entitlement units of local government (NEU), as figure
3 shows.
13The remaining $24.5 billion was allocated to tribal governments and U.S. territories.
Page 7 GAO-24-106027 COVID-19 Relief
Figure 3: Coronavirus State and Local Fiscal Recovery Funds Allocations by
Recipient Type
a
A metropolitan city is defined as the central city within a metropolitan area (i.e., a standard
metropolitan statistical area as established by the Office of Management and Budget) or any other
city within a metropolitan area that has a population of 50,000 or more. 42 U.S.C. §§ 803(g)(4),
5302(a)(4). A metropolitan city includes cities that relinquish or defer their status as a metropolitan
city for purposes of receiving allocations under 42 U.S.C. § 5306 for fiscal year 2021.
b
NEUs are local governments typically serving populations of less than 50,000. 42 U.S.C. §§
803(g)(5), 5302(a)(5). NEUs include cities, villages, towns, townships, or other types of local
governments.
As part of its responsibility to administer the SLFRF, Treasury employed a
number of methodologies to determine the size of each state’s and
locality’s SLFRF award based on specific factors, such as population size
and unemployment rates. Most states and all localities were required
under ARPA to receive their SLFRF awards in two equal tranches
Page 8 GAO-24-106027 COVID-19 Relief
approximately one year apart. 14 Treasury sent direct payments to all
SLFRF recipients except NEUs. ARPA required that states receive NEU
funds from Treasury and then distribute payments to each NEU within
their respective states, based on the states’ verification of the NEU’s
eligibility. 15 Under ARPA, states have 30 days to distribute funds to NEUs,
once they receive the funds from Treasury. States can receive a 30-day
extension if the distribution causes an “excessive administrative burden.”
States can receive subsequent extensions if the state provides a written
plan for distributing funds and Treasury determines that the plan is
“reasonably designed” to distribute such funds. 16
Treasury began distributing SLFRF awards to recipients in May 2021.
Recipients have until December 31, 2024, to obligate their SLFRF
awards, in accordance with ARPA. 17 Recipients also have until December
31, 2026, to liquidate those obligations (spend their awards). 18 In its 2022
14According to Treasury, states that had experienced a net increase of more than 2
percentage points in their unemployment rate from February 2020 to the date of the latest
available data at the time the state certified for their payment received their full award in a
single payment. Under ARPA, to the extent practicable, states receive award funds not
later than 60 days after certifying that the state requires the payment to carry out the
activities specified in statute and will use the funds in compliance with the eligible uses. 42
U.S.C. § 802(b)(6), (d)(1). Metropolitan cities, states (for distribution to NEUs), and
counties received award funds in two equal tranches, providing the first payment 60 days
after March 11, 2021, to the extent practicable, and the second payment no earlier than 12
months after the first. 42 U.S.C. § 803(b)(7). After receiving award funds for distribution to
NEUs, states had 30 days to make those distributions, unless Treasury granted an
extension. 42 U.S.C. § 803(b)(2)(C).
15ARPA requires states to allocate and distribute to NEUs an amount that is the same
proportion to the amount of the payment as the population in the NEU is to the share of
the total population of all NEUs in the state, subject to a cap. 42 U.S.C. § 803(b)(2)(C).
1642 U.S.C. § 803(b)(2)(C).
17Treasury defines obligation as an order placed for property and services and entering
into contracts, subawards, and similar transactions that require payment. It also means a
requirement under federal law or regulation or provision of the award terms and conditions
to which a recipient becomes subject as a result of receiving or expending funds. 31
C.F.R. § 35.3.
1887 Fed. Reg. 4338, 4340 (Jan. 27, 2022). The Consolidated Appropriations Act, 2023,
authorized SLFRF funding for certain infrastructure and community development projects
that meet existing eligibility criteria. Pub. L. No. 117-328, div. LL, § 102, 136 Stat. 4459,
6097 (2022). Funds for certain infrastructure and community development projects must
be obligated by December 31, 2024, and liquidated by September 30, 2026. For example,
this includes funds for the Bridge Investment Program, National Highway Performance
Program, and Surface Transportation Block Grant Program, among other programs, and
activities under section 105(a) of the Housing and Community Development Act of 1974.
42 U.S.C. § 802(c)(5)(A)-(E).
Page 9 GAO-24-106027 COVID-19 Relief
Final Rule implementing the SLFRF, Treasury explained that it set the
obligation deadline based on its interpretation of the statutory requirement
that eligible costs must be “incurred” by December 31, 2024. 19
SLFRF Reporting As authorized under ARPA, the SLFRF allows for a broad range of
eligible uses to respond to the COVID-19 pandemic and its economic
effects, as discussed below. 20 Recipients of SLFRF awards are required
to meet reporting requirements established by Treasury—and authorized
under ARPA—to detail their uses of funds. Specifically, SLFRF recipients
are required to submit “project and expenditure reports” to provide
information on how they used their awards, including obligation and
expenditure amounts and descriptions of projects they have undertaken. 21
1987 Fed. Reg. 4338, 4433 (Jan. 27, 2022). Treasury also stated that it interprets
“incurred” to be equivalent to the definition of “obligation.”
20ARPA established that recipients can use their SLFRF awards to cover costs incurred
by December 31, 2024, to (1) respond to the COVID-19 public health emergency or its
negative economic impacts; (2) provide premium pay to essential workers, or grants to
employers with essential workers; (3) provide government services up to the amount of
the reduction in revenue; and (4) make necessary investments in water, sewer, or
broadband infrastructure. 42 U.S.C. §§ 802(c), 803(c). Subsequently, the Consolidated
Appropriations Act, 2023, established that recipients may also use their awards to provide
emergency relief from natural disasters or the negative impacts of natural disasters. Pub.
L. No. 117-328, div. LL, § 102, 136 Stat. 4459, 6098 (2022), which is classified at 42
U.S.C. §§ 802(c)(1)(E), 803(c)(1)(E). Based on Treasury guidance, recipients may not
provide premium pay for work performed after April 10, 2023, when the COVID-19
National Emergency ended but may award premium pay for work performed prior to that
date. There are several restrictions on recipients’ uses of SLFRF awards. Recipients other
than tribal governments may not deposit SLFRF awards into a pension fund. 42 U.S.C. §§
802(c)(2)(A), 803(c)(2). Also, recipients that are states or territories may not use SLFRF
awards to offset a reduction in net tax revenue resulting from the recipient’s change in law,
regulation, or administrative interpretation. 42 U.S.C. § 802(c)(2)(A). The constitutionality
of the offset provision is currently being litigated in several courts. In addition, recipients
may not use SLFRF awards directly to service debt, satisfy a judgment or settlement, or
contribute to a “rainy day” fund. 87 Fed. Reg. 4338, 4394 (Jan. 27, 2022).
21In addition to the project and expenditure report, Treasury requires an interim report and
a recovery plan performance report from certain recipients. The interim report was a one-
time requirement due in 2021 that provided an initial overview of recipients’ status and
uses of funding. The recovery plan performance report is an annual report that provides
information on the projects large recipients are undertaking, including how they plan to
ensure program outcomes are achieved effectively, efficiently, and equitably. NEUs were
not required to submit an interim report. Only states, the District of Columbia, U.S.
territories, and metropolitan cities and counties with a population that exceeds 250,000
residents are required to submit recovery plan performance reports.
Page 10 GAO-24-106027 COVID-19 Relief
States and localities are to submit these reports through Treasury’s online
reporting portal quarterly or annually, depending on the type of recipient
and the award size.
• Quarterly reporting is required of (1) states, metropolitan cities, and
counties with more than 250,000 residents or those that were
allocated more than $10 million in SLFRF funds; and (2) NEUs that
were allocated more than $10 million in SLFRF funds.
• Annual reporting is required of (1) metropolitan cities and counties
with fewer than 250,000 residents that were allocated less than $10
million in SLFRF funds, and (2) NEUs that were allocated less than
$10 million in SLFRF funds.
In completing project and expenditure reports, SLFRF recipients are
required to report on their uses of award funds across seven spending
categories (see fig. 4). 22
22Treasury published an interim final rule implementing amendments to the SLFRF
program in the Consolidated Appropriations Act, 2023. 88 Fed. Reg. 64986 (Sept. 20,
2023); see also Pub. L. No. 117-328, 136 Stat. 4459 (2022). Treasury officials told us they
expect to finalize changes to the reporting portal, reflecting the expanded eligible uses
available in the interim final rule, and issue relevant guidance before the October 2023
project and expenditure reports are due.
Page 11 GAO-24-106027 COVID-19 Relief
Figure 4: Coronavirus State and Local Fiscal Recovery Funds Spending Categories
in Treasury Project and Expenditure Reports, as of Mar. 31, 2023
a
Treasury guidance refers to this category as Public health-Negative economic impact: Public sector
capacity.
b
Based on Treasury guidance, recipients may not provide premium pay for work performed after April
10, 2023, when the National Emergency related to COVID-19 ended, but may award premium pay for
work performed prior to that date.
Of the seven spending categories, revenue replacement provides
recipients with the most flexibility in their use of SLFRF awards and
streamlined reporting requirements, according to Treasury guidance.
Under this category, recipients may use their funds to cover a broad
range of government services (i.e., generally any service traditionally
provided by a government) up to the amount of revenue loss experienced
during the pandemic. Recipients may use SLFRF awards for revenue
replacement for projects that also are eligible under the other spending
categories because those categories include services that governments
provide.
Page 12 GAO-24-106027 COVID-19 Relief
Recipients have two options for calculating revenue loss. They may
calculate revenue loss using a formula that Treasury established, or they
may elect a $10 million “standard allowance,” which allows them to spend
up to $10 million or the maximum of their SLFRF awards, whichever is
less, over the course of the SLFRF program. 23
In their project and expenditure reports, SLFRF recipients can report
funds used to replace lost revenue as a single project, even if the project
description notes that funds are used for more than one activity or
purpose. Furthermore, for projects under the revenue replacement
category, Treasury has issued guidance that portions of a project that a
SLFRF recipient passes through to other entities are not considered
subawards since the public purpose of the SLFRF award as authorized
by law is achieved once the recipient replaces lost revenue. 24
We recently reported that, as of March 31, 2023, states reported
obligating 60 percent ($118.3 billion) and spending 45 percent ($88.2
billion) of SLFRF funds they received. Localities reported obligating 54
percent ($67.5 billion) and spending 38 percent ($47.9 billion) of their
awards. States and localities each reported spending the largest amount
of their awards to replace lost revenue. States reported spending 45
percent of their awards ($39.5 billion) to replace lost revenue; localities
reported spending 68 percent ($32.4 billion) to replace lost revenue. 25
Treasury and Recipient Treasury’s Office of Capital Access (OCA)—previously known as the
SLFRF Administration Office of Recovery Programs—is responsible for administering the
SLFRF program and other COVID-19-related relief and recovery
23Treasury offered the “standard allowance” option in its 2022 final rule implementing the
SLFRF. 87 Fed. Reg. 4338, 4401-03 (Jan. 27, 2022). Subsequently, the “standard
allowance” was codified into law. Pub. L. No. 117-328, div. LL, § 102, 136 Stat. 4459,
6097 (2022), codified at 42 U.S.C. §§ 802(c)(1), 803(c)(1).
24Treasury has determined that there are no subawards under the revenue replacement
category, based on the definition of “subrecipient” in OMB’s Uniform Administrative
Requirements, Cost Principles and Audit Requirements for Federal Awards, which is
reprinted in 2 C.F.R. part 200 (Uniform Guidance). See 2 C.F.R. § 200.1. Specifically, the
definition of a subrecipient in the Uniform Guidance provides that a subaward is provided
to “carry out” a portion of a federal award. According to Treasury, recipients’ use of funds
for replacing revenue does not give rise to subrecipient relationships given that there is no
federal program or purpose to carry out in the case of the revenue replacement portion of
the award. See Department of the Treasury, Coronavirus State and Local Fiscal Recovery
Funds Final Rule: Frequently Asked Questions (as of July 2023), 13.14.
25For more information, see GAO, COVID-19 Relief: States’ and Localities’ Fiscal
Recovery Funds Spending as of March 31, 2023, GAO-24-106753 (Washington, D.C.:
Oct. 11, 2023).
Page 13 GAO-24-106027 COVID-19 Relief
programs. 26 Among other things, OCA staff are responsible for providing
information to recipients to help them manage their awards, reviewing
recipient reporting, and monitoring and overseeing recipients’ use of their
awards. For example, OCA has issued guidance to recipients on various
aspects of SLFRF administration, including using the funds, distributing
funds to NEUs, and meeting reporting requirements.
All states and localities—including NEUs—are direct recipients of SLFRF
awards. Thus, they are responsible for all programmatic, financial, and
administrative aspects of their awards, including determining eligible
uses, designing controls to deter the misuse of funds, meeting reporting
requirements, and monitoring subrecipients.
In addition, SLFRF recipients may be subject to single audits, as required
by the Single Audit Act and OMB’s implementation guidance. 27 The act
establishes requirements for nonfederal entities (including states and
local governments) that receive federal award funds to undergo single
audits (or, in limited circumstances, program-specific audits) of those
awards annually (unless a specific exception applies) when they spend
$750,000 or more in federal award funds during their respective fiscal
years. 28
26The Office of Recovery Programs was renamed the Office of Capital Access as of
November 2, 2023, according to Treasury officials.
27The Single Audit Act is codified, as amended, at 31 U.S.C. §§ 7501-06, and
implementing (OMB) guidance is reprinted in 2 C.F.R. part 200 subpart F.
28Some SLFRF recipients are eligible to undergo an Alternative Compliance Examination
Engagement instead of a single audit. Eligible recipients include entities that would not
otherwise be required to undergo an audit pursuant to 2 C.F.R. § 200 Subpart F, if it were
not for the expenditures of SLFRF funds directly awarded by Treasury. These
engagements are conducted in accordance with Government Auditing Standards and the
American Institute of Certified Public Accountants Statements on Standards for Attestation
Engagements. SLFRF recipients provide these reports to Treasury by uploading them to
Treasury’s reporting portal and the Federal Audit Clearinghouse, which is the repository of
record where nonfederal entities are required to transmit the information required by the
Single Audit Act and OMB’s implementing guidance. These engagements are described in
detail in OMB’s 2021 Compliance Supplement, Part 8, Appendix VII Technical Update.
The compliance supplement is a document that identifies existing, important compliance
requirements that the federal government expects to be considered as part of an audit
required by the Single Audit Act.
Page 14 GAO-24-106027 COVID-19 Relief
Officials in All
Selected States and
Localities Reported
Taking a Range of
Steps to Administer
Their SLFRF Awards
Officials in All Selected Officials in all of the 18 selected states and most of the larger selected
States and Most Larger localities (i.e., entities that received a range of between tens of millions
and tens of billions of dollars in SLFRF awards) told us they expanded
Selected Localities
their capacity to administer their SLFRF awards. These states and
Reported Expanding Their localities are using their awards to fund a range of projects across entities
Capacity to Administer within their jurisdictions. Officials from some of these states and localities
Their SLFRF Awards told us that managing and coordinating their SLFRF awards across
multiple entities—such as collecting information for required reporting—
has been a substantial effort and required additional resources as well as
developing and implementing new policies and procedures. Steps that
these states and localities reported taking to expand their capacity
included:
Reassigning existing or hiring new staff. Officials in all 18 selected
states and most of the larger selected localities told us they reassigned
existing staff or hired new staff—including consultants or contractors.
Officials from some of these states and localities said they did so to
manage their increased workload and to help ensure they possessed the
experience, knowledge, and skills needed to administer their awards. For
example:
• Maine reassigned its Director of Internal Audit (responsible for
reviewing state agencies’ internal controls) to manage multiple
SLFRF-related administrative tasks. In this reassigned role, the
Director is responsible for (1) reviewing state agencies’ proposed
SLFRF-funded projects to ensure their compliance with SLFRF
requirements and (2) managing the state’s required reporting to
Treasury.
• Washington created new staff positions to manage the state’s
SLFRF award within its Office of Financial Management. State
officials told us they hired new staff to fill those positions. For
example, the office created and hired a Federal Funds Reporting
Page 15 GAO-24-106027 COVID-19 Relief
Coordinator to respond to Treasury reporting requirements, among
other responsibilities.
• Dunedin, Florida retained a consultant with substantial experience in
helping cities manage federal awards. A Dunedin official told us that
the city had limited experience with receiving funds directly from the
federal government. As a result, the consultant was hired to advise
Dunedin on a range of issues, including allowable uses of SLFRF
funds, reporting requirements, and monitoring subrecipients to ensure
their appropriate uses of funds.
Developing new or adapting existing IT systems. Officials from most
selected states and some selected localities told us they developed new
or adapted existing IT systems to administer their SLFRF awards.
Officials in these states and localities told us that the new systems helped
them manage required documentation more effectively and efficiently to
meet Treasury reporting requirements. For example:
• Illinois officials told us that the state adapted an online portal,
managed by the state’s Department of Commerce and Economic
Opportunity, to collect the required documentation from NEUs before
distributing their awards. Illinois officials also told us that the portal
facilitated the process for distributing awards to NEUs efficiently.
• Pennsylvania developed and implemented a new financial system for
managing and reporting its SLFRF award. Pennsylvania officials said
that the state’s core financial system captured SLFRF financial data,
such as obligations and expenditures, but did not have the capability
to capture other related SLFRF programmatic data, such as
performance information. The new system allows the state to capture
all required data, facilitating easier reporting.
• Monroe County, New York developed an online portal to collect
documentation from applicants applying for SLFRF funds. County
officials told us that the portal enables the county to collect all required
documentation from grantees in a central location, which facilitates
the county’s administration of the funds.
Implementing new or modifying existing internal controls. Officials in
most selected states and some larger selected localities told us they
implemented new internal controls or modified their existing internal
controls. Officials in some of these states and localities told us they did so
to help ensure oversight of, and accountability for, their use of SLFRF
awards. For example:
Page 16 GAO-24-106027 COVID-19 Relief
• Nevada’s Governor’s Finance Office—responsible for administering
the state’s SLFRF award—developed new internal controls to support
its implementation of the program. These controls included
procedures for managing SLFRF-related contracts and subawards to
state agencies, nonprofit organizations, and businesses. Nevada
officials told us that this office generally does not manage grants and
lacked internal controls prior to receiving the state’s SLFRF award.
The new internal controls are intended to ensure the office’s
compliance with SLFRF rules and regulations.
• North Carolina modified its existing statewide internal controls to help
ensure the state’s compliance with SLFRF requirements. For
example, the state created a Pandemic Recovery Office to oversee,
coordinate, and ensure proper reporting and accounting for the state’s
use of COVID-19 recovery funds. The office is responsible for
reviewing state agencies’ documentation on planned SLFRF-funded
projects to ensure their compliance with Treasury requirements.
• Denton County, Texas added SLFRF-specific internal controls to its
existing processes for administering federal funds. For example, the
county developed a process for checking each expenditure made by
subrecipients, such as nonprofit organizations. County officials told us
that this new process allows the county to ensure that its award is
being used only for eligible expenses.
Establishing new or leveraging existing offices. Officials in most
selected states and one larger selected locality told us they established
new or leveraged existing offices to oversee the administration of their
SLFRF awards. Officials in some of these states and the one locality
noted that administering SLFRF awards through existing offices or
management structures was not feasible, given the size and scope of
their SLFRF awards. For example:
• Minnesota created a COVID-19 Response Accountability Office
earlier in the pandemic to track and monitor COVID-related funds,
including the SLFRF. Housed within the Minnesota Management and
Budget office, the newly created office is responsible for coordinating
with state agencies as well as with Minnesota Management and
Budget’s budgeting and accounting divisions over SLFRF funds. The
office is also responsible for ensuring that state recipients, including
subrecipients of SLFRF funds, meet Treasury reporting requirements.
• California established a Federal Funds Accountability and Cost
Tracking Unit within the state’s Department of Finance to monitor,
track, and report on its use of its SLFRF award. Earlier in the
pandemic, the state had tasked department staff with managing
Page 17 GAO-24-106027 COVID-19 Relief
COVID-19 relief funding, including awards from the Coronavirus Relief
Fund. 29 California determined that given the size of its SLFRF award
($27 billion) and anticipated projects across a wide range of state
agencies, the department’s existing staff levels would not be adequate
to administer the state’s SLFRF award. The state expects that the
new unit and its dedicated staff will be able to ensure consistency in
data gathering and reporting across the state. Once the SLFRF award
expires, California plans to operate its new unit through the state’s
general fund. Specifically, the state plans to use the unit to streamline
and improve tracking and reporting and oversee future federal funds,
such as those for economic stimulus and natural disaster response
and recovery.
• Philadelphia, Pennsylvania leveraged its COVID-19 Recovery
Office—established in the spring of 2020—to manage state and
federal COVID-19 relief funds, including the SLFRF. A steering
committee comprised of city leaders from the Mayor’s Office, the City
Council, and programmatic departments oversees the office’s
activities. According to Philadelphia officials, these activities include
(1) identifying the city’s SLFRF spending priorities, (2) ensuring
adherence to federal rules and requirements, and (3) reporting to
Treasury. Philadelphia officials told us that this management structure
has helped to ensure the city’s effectiveness in implementing federal
COVID-19 relief funds, including the SLFRF.
Officials in Most Smaller Officials in most of the smaller selected localities—those that received
Selected Localities between tens of thousands of dollars and $10 million in SLFRF
allocations—told us they generally administered their SLFRF awards with
Reported Administering
their existing staff and processes. Some local officials told us that their
Their SLFRF Awards with additional responsibilities for administering SLFRF awards increased their
Existing Staff and workloads, but not unreasonably so. For example:
Processes
• Glen Echo, Maryland’s town manager assumed responsibility for
managing the town’s approximately $266,000 SLFRF award as part of
the position’s normal duties, according to the town manager. At one
time, Glen Echo had considered pooling SLFRF funds with nearby
towns to hire a consultant for helping manage the funds. However, the
Glen Echo town council decided that the cost to hire a consultant was
not feasible. The town manager told us that, as the town’s only full-
29The CARES Act appropriated $150 billion to Treasury for the Coronavirus Relief Fund
for direct assistance to tribal governments, states, the District of Columbia, localities, and
U.S. territories for necessary expenses incurred due to the COVID-19 public health
emergency. 42 U.S.C. § 801.
Page 18 GAO-24-106027 COVID-19 Relief
time employee, being responsible for administering the SLFRF has
increased her workload.
• Hot Springs County, Wyoming’s clerk told us that the county did not
hire additional staff to assist with administering the county’s SLFRF
awards. As a result, the county clerk assumed primary responsibility
for administering the awards, including reviewing Treasury guidance
for allowable uses and managing the county’s required reporting. The
clerk’s experience working for a Certified Public Accountant firm,
including auditing financial statements and conducting single audits,
helped with effective management of the funds, according to the clerk.
The clerk added that there have not been any major challenges in
managing the SLFRF awards.
• An official in Murdock, Nebraska told us that two of the town’s part-
time volunteers, who regularly help to manage the town’s operations,
have assumed the management and administration of the town’s
SLFRF award into their day-to-day duties. The official said that prior to
receiving SLFRF funds, Murdock had never received funds directly
from the federal government. This town official told us that Treasury’s
reporting guidance is complex and the volunteers do not have a solid
understanding of the reporting requirements, given their limited
experience. As a result, the volunteers must rely heavily on Treasury
for assistance.
Page 19 GAO-24-106027 COVID-19 Relief
Officials in Selected
States and Localities
Identified Benefits
and Challenges in
Administering Their
SLFRF Awards
State and Local Officials Most of the 18 selected states and localities have spent all or a portion of
Reported Benefits from their SLFRF awards on replacing revenue. 30 Officials in some of these
Enhanced Spending states and localities said that using funds to replace revenue for
government services enhanced spending flexibilities and eased their
Flexibilities and Eased reporting burdens.
Reporting Burdens
Enhanced spending flexibilities. Officials in most selected states said
that spending funds under the revenue replacement category provided
additional spending flexibilities by broadening the allowable uses,
including the populations targeted by spending. Connecticut, Florida,
Illinois, Maine, Michigan, and New York officials told us that using
revenue replacement allowed them to fund programs, such as important
services and responses to changing pandemic response priorities, that
were not clearly identified as allowable in Treasury’s other spending
categories. For example, to address the impact of lost instructional time
during the pandemic, Connecticut used some of its SLFRF award to fund
services to students beginning in pre-kindergarten. Connecticut officials
explained that, based on their understanding of Treasury policy, funding
these services is allowable under Treasury’s Negative Economic Impacts
spending category, but only for students beginning kindergarten. Officials
said the state categorized its spending as revenue replacement to
allowably expand services to pre-kindergarten students, whom the state
identified as also being affected by lost instructional time during the
pandemic.
30We recently reported on states’ and localities’ spending of their SLFRF awards.
Specifically, as of March 2023, all 50 states (including the District of Columbia) reported to
Treasury that they spent 45 percent ($88.2 billion) of their total SLFRF awards toward
replacing revenue while more than 26,410 localities had reported spending 68 percent
($32.4 billion) of their total SLFRF awards for this purpose. For additional information, see
GAO, COVID-19 Relief: States’ and Localities’ Fiscal Recovery Funds Spending as of
March 31, 2023, GAO-24-106753 (Washington, D.C.: Oct. 11, 2023).
Page 20 GAO-24-106027 COVID-19 Relief
Officials in most selected localities said that spending funds to replace
revenue increased their flexibility to address the needs of their local
citizens. For example, officials in Sahuarita, Arizona; Dunedin, Florida;
and Belleville, Illinois, told us that revenue replacement enhanced
spending flexibilities because these entities are not responsible for
services—such as public health—that fall under Treasury’s other
spending categories. Belleville officials said that most of the allowable
uses in Treasury’s Public Health spending category are not activities
typically within the city’s purview; rather, the county in which the city is
situated is responsible for most public health activities. Therefore, the city
focused on other activities within its area of responsibility that were
allowable under the revenue replacement category, such as roadway
replacement.
Eased reporting burdens. Officials in some selected states told us that
using SLFRF awards to replace revenue also significantly eased their
reporting burdens, particularly because Treasury does not require that
recipients report data on subawards for projects categorized as revenue
replacement. As noted earlier, Treasury does not consider portions of a
project that a SLFRF recipient passes through to other entities to be
subawards, as the public purpose of the SLFRF award as authorized by
law is achieved once the recipient replaces lost revenue. Connecticut,
Maryland, North Carolina, Pennsylvania, and Texas officials told us that
revenue replacement also eased the reporting burdens for state agencies
that received SLFRF funds, which, for some of these states, have limited
experience meeting federal reporting requirements.
Additionally, officials in some selected localities said they planned to
report all SLFRF spending under the revenue replacement category to
accommodate the locality’s limited capacity. For example, officials in
Waco, North Carolina (a city of under 500 residents), told us they have
limited experience with federal financial assistance, having received only
one grant—passed through from the state—in 2016. Waco officials said
that using the standard allowance of up to $10 million for revenue loss
significantly simplified reporting to Treasury, compared to using
Treasury’s formula to calculate revenue loss. With the standard
allowance, officials said that the city was confident that it could meet
Treasury’s reporting requirements by funding all of its projects under
general government services within the revenue replacement category.
Page 21 GAO-24-106027 COVID-19 Relief
State and Local Officials Selected states and localities reported experiencing a range of challenges
Identified a Range of in administering their SLFRF awards, which included unclear and
changing Treasury guidance, technical issues with Treasury’s reporting
Challenges in
portal, difficulties in distributing awards to NEUs, and challenges in
Administering Their obtaining assistance from Treasury.
SLFRF Awards
Treasury Guidance State and local officials identified areas where they found Treasury’s
guidance to be unclear or where continuing changes to Treasury’s
guidance resulted in challenges that slowed spending or altered spending
plans and created administrative burdens.
Obligation deadlines. Officials in some selected states told us they
needed additional clarity from Treasury on how to obligate state
employee salaries and remain in compliance with the December 31,
2024, deadline for obligating funds. For example, officials in Connecticut,
Maine, Michigan, Nevada, and Wyoming told us that employee salaries
are authorized by the state legislature during the state’s annual (i.e.,
every year) or biennial (i.e., every 2 years) budget cycle and cannot be
legislatively authorized prior to that budget cycle. 31 That is, states cannot
obligate anticipated staff salaries for 2026—the year in which recipients
are required to liquidate their SLFRF obligations—prior to the obligation
deadline of December 31, 2024. Maine, for example, operates on a
biennial budget cycle covering 2024 and 2025. The state’s 2026 and
2027 budget will likely not be approved until after the obligation deadline
of December 31, 2024.
Treasury guidance directed SLFRF recipients, such as states, to follow
state or local law and each state’s practices and policies regarding when
they are considered to have incurred an obligation. However, according to
officials from associations representing state and local governments,
states typically cannot incur obligations outside of an approved budget,
and states may not be able to establish authority providing otherwise to
meet the SLFRF’s timeline.
Some state officials told us they have had to consider alternative
solutions to funding staff salaries to meet the December 31, 2024,
obligation deadline, such as creating multiyear contracts for state
31Michigan operates on an annual budget cycle, which means the budget provides for
appropriations for one year. Connecticut, Maine, Nevada, and Wyoming operate on a
biennial cycle, which means the budget provides for appropriations for 2 years.
Page 22 GAO-24-106027 COVID-19 Relief
employees. State officials said they are not sure whether those solutions
will comply with Treasury program requirements.
In addition, officials in Arizona, Connecticut, Illinois, Maine, Nebraska,
North Carolina, and Texas said that Treasury’s guidance is not clear on
the circumstances in which SLFRF recipients can reobligate SLFRF funds
after the December 31, 2024, deadline but before the December 31,
2026, expenditure deadline. 32 For example, Connecticut and Illinois
officials noted that if a state were to cancel a contract after the December
31, 2024, obligation deadline—due to a contractor’s failure to perform
remaining work—officials were not clear if they are allowed to reobligate
the funds or required to return them to Treasury. Illinois officials further
said that, in the absence of clear guidance, they have been hesitant to
obligate funds to larger, longer-term projects, which could involve
substantial work after the December 31, 2024, obligation deadline.
Further, in a letter to Treasury dated September 14, 2023, a number of
associations representing state and local governments expressed similar
concerns regarding a need for clarity on these issues. 33 For example,
associations raised concerns that some state and local governments may
not have the authority to establish a policy that would clarify their ability to
obligate payroll expenses on the necessary timeline for the SLFRF
program. They also noted that Treasury’s existing guidance is subject to
interpretation, while additional guidance would assist governments to
meet the intended purpose of the SLFRF.
In August 2023, Treasury officials told us they were aware of states’ and
localities’ concerns over obligating staff salaries and reobligating SLFRF
funds to meet the statutory deadlines. The officials further said they were
in the process of considering actions to address these concerns—such as
providing information on how recipients can remain in compliance with
obligation deadlines in these circumstances—but had not yet done so.
In a draft of our report we provided to Treasury officials on November 2,
2023, for their review and comment, we recommended that Treasury
32Reobligation is the obligation of deobligated funds for a different authorized use.
Deobligation is the cancellation or downward adjustment of previously incurred
obligations. Deobligated funds may be reobligated within the period of availability of an
appropriation.
33The associations included the Government Finance Officers Association; the National
Association of State Auditors, Comptrollers and Treasurers; the National Association of
State Budget Officers; and the National League of Cities.
Page 23 GAO-24-106027 COVID-19 Relief
clarify guidance to address actions that recipients may take on obligating
and reobligating SLFRF funds to remain in compliance with the deadlines
established for the SLFRF program.
Subsequently, on November 20, 2023, Treasury issued an interim final
rule (IFR) to amend the definition of “obligation” to provide flexibility and
guidance to recipients regarding the amendment and replacement of
contracts and subawards. 34
• Treasury revised the definition of obligation, such that recipients are
considered to have incurred an obligation by December 31, 2024, with
respect to a requirement under federal law or regulation or a provision
of the SLFRF award terms and conditions to which the recipient
becomes subject as a result of receiving or expending funds. 35
Recipients may use funds to cover costs, including personnel costs,
related to reporting and compliance requirements and single audit
costs, among others. For example, a recipient may consider SLFRF
funds obligated by December 31, 2024, if the recipient plans to use
the funds to pay the salaries of staff who manage the project and
expenditure reporting to Treasury. To take advantage of this flexibility,
recipients must meet certain additional reporting requirements,
including reporting to Treasury by April 30, 2024. 36
• Treasury clarified that recipients that reobligate funds to new
contractors or subrecipients after December 31, 2024, will be
considered to have used their funds to cover an obligation incurred
34Coronavirus State and Local Fiscal Recovery Funds, 88 Fed. Reg. 80584 (Nov. 20,
2023), to be codified at 31 C.F.R. pt 35. The interim final rule (IFR) was published in the
Federal Register and became effective on November 20, 2023. Treasury stated that
immediate implementation of the amendments to the obligation deadline will enable
recipients to complete their internal budgeting processes in time to meet the statutory
deadline to incur costs by December 31, 2024. Treasury is seeking public comment on the
IFR through December 20, 2023. Interim final rules are considered final rules that carry
the force and effect of law. Agencies may revise and replace an IFR with a non-interim
final rule after the agency considers post-promulgation public comments received. The
IFR also clarified that subrecipients are not subject to the December 31, 2024, obligation
deadline.
3588 Fed. Reg. at 80586.
36According to the IFR, recipients must (1) determine the amount of SLFRF funds the
recipient estimates it will use to cover such expenditures, (2) document a reasonable
justification for this estimate, (3) report that amount to Treasury by April 30, 2024, with an
explanation of how the amount was determined, and (4) report at award closeout the final
amount expended for these costs. 88 Fed. Reg. at 80586.
Page 24 GAO-24-106027 COVID-19 Relief
prior to December 31, 2024, under certain circumstances. 37 For
example, a recipient may replace a contract with previously obligated
funds if the recipient terminates the contract or subaward because the
contractor or subawardee went out of business. 38
Treasury is seeking public comment on the IFR through December 20,
2023.
Changes to reporting guidance. In early January 2022, Treasury
released a user guide that contained detailed instructions to help
recipients navigate the portal and adhere to reporting requirements. In
most selected states and in one locality, officials told us that the
information in the user guide continued to change across reporting cycles,
creating additional burdens. For example, Arkansas officials said that
Treasury’s reporting requirements for broadband projects changed across
multiple reporting cycles. Treasury’s user guide for the October 2022
reporting cycle included specific reporting requirements that were not
included in the April 2022 or July 2022 reporting cycles. Arkansas officials
told us that when they initiated these projects, Treasury had not
communicated the reporting requirements. Thus, the state was unable to
build those requirements into vendor contracts for each project. As
Treasury’s reporting requirements changed, the state had to return to
those vendors and attempt to collect the data retroactively. Ultimately,
officials said they collected the required data, but were unable to meet
Treasury’s reporting deadline. The state worked with Treasury to submit
the data after the deadline.
Treasury officials told us that they made periodic changes to the user
guide to comport with changes they made to Treasury’s SLFRF
compliance and reporting guidance. For example, Treasury made
3788 Fed. Reg. at 80587.
38Recipients are permitted to replace a contract or subaward entered into prior to
December 31, 2024, under the following circumstances: (1) the recipient terminates the
contract or subaward because of the contractor or subawardee’s default, because the
contractor or subawardee goes out of business, or because the recipient otherwise
determines that the contractor or subawardee will not be able to perform under the
contract or carry out the subaward; (2) the recipient and contractor or subrecipient
mutually agree to terminate the contract or subaward for convenience; or (3) the recipient
terminates the contract or subaward for convenience if the contract or subaward was not
properly awarded (such as if the contractor was not eligible to receive the contract), there
is clear evidence that the contract or subaward was improper, the recipient documents its
determination that the contract or subaward was not properly awarded, and the original
contract or subaward was entered into by the recipient in good faith. 88 Fed. Reg. at
80587.
Page 25 GAO-24-106027 COVID-19 Relief
periodic changes to its compliance and reporting guidance related to
broadband projects between June and September 2022. Treasury
subsequently updated its user guide for the quarterly reporting cycle to
reflect those changes. Since then, Treasury has begun highlighting
changes to its user guide to account for changes to its compliance and
reporting program requirements.
Short timelines to implement reporting guidance. Officials in most
selected states and some selected localities expressed concerns with the
timing of Treasury’s project and expenditure reporting guidance. For each
quarterly reporting cycle, Treasury issues a project and expenditure
reporting user guide when it opens the reporting portal, which is generally
one month prior to the reporting deadline, according to Treasury officials.
These user guides provide information to SLFRF recipients on submitting
project and expenditure reports, including specific requirements and
details for using the reporting portal. Arizona, California, Connecticut,
Maryland, Michigan, Pennsylvania, Texas, and Washington officials told
us that having to report all required information within a one-month period
is burdensome. Texas officials, for example, said that to meet the
reporting requirements, the state must collect and aggregate data from 40
different state agencies that received SLFRF awards. They added that, as
a result, the timing of the user guides can create challenges.
Local officials in Denton County, Texas, told us that they also struggled to
prepare the project and expenditure reports during the first quarterly
reporting cycle because they did not receive the guidance until the user
guide was issued, about one month prior to the submission deadline.
Denton County officials said that they only became aware of certain
reporting requirements upon receiving the user guide. Officials said they
had to “play catch-up” during nights and weekends to collect the required
information once they received Treasury’s guidance.
Treasury officials said that they issue the user guide at the same time
they open the reporting portal to allow recipients to review the portal and
user guide concurrently. Treasury officials told us that doing so helps to
facilitate states and localities reaching out to Treasury with questions
before project and expenditure reports are due. The officials added that
for those recipients that report quarterly, Treasury generally allows
Page 26 GAO-24-106027 COVID-19 Relief
recipients to submit late reports or make necessary revisions within a
designated period, such as 60 days following the reporting deadline. 39
Reporting on performance indicators. Under Treasury guidance, all
states, and counties and metropolitan cities with populations exceeding
250,000 residents are required to include performance indicators in their
project and expenditure reports to support Treasury’s oversight of
recipient spending of SLFRF. For each project that states and localities
fund under certain Treasury spending categories, these recipients are to
report metrics associated with a particular performance indicator that
Treasury has identified in its reporting guidance. Treasury established
these indicators to understand and aggregate program outcomes across
recipients.
However, officials in some states and one locality told us they
encountered instances when the project that they reported within a
certain expenditure category did not align with the required performance
indicator. These officials told us they needed additional clarity in
Treasury’s guidance to understand how to report on the required
performance indicators when they do not align with their uses of SLFRF
awards and Treasury spending categories.
For example, officials in Minneapolis, Minnesota, identified an instance in
which a project the city had undertaken did not align with Treasury’s
required performance indicator. The city is implementing a project to
address long-term housing security, which is focused on improving
conditions in the city’s encampments for individuals experiencing
homelessness. However, the city is required to report on a performance
indicator—in this instance, the number of housing units preserved or
developed. Local officials said that while Treasury’s indicator is not
relevant to the city’s project, the city must nevertheless include
information on the indicator to submit their report. Minneapolis officials
expressed concerns that not reporting a value for this indicator (i.e.,
reporting that zero housing units were preserved or developed) does not
adequately represent the city’s efforts because the performance indicator
is not aligned with the city’s efforts.
Similarly, Connecticut officials reported that the performance indicators
included in Treasury’s guidance do not always align with projects reported
39Treasury, Office of Recovery Programs, Awards Management Policy for Financial
Assistance Recovery Programs, Version 1.0 (July 15, 2022).
Page 27 GAO-24-106027 COVID-19 Relief
under certain spending categories. For example, Connecticut spent
SLFRF funds under Treasury’s spending category, “Community Violence
Interventions,” to fund educational and athletic programs to prevent illegal
drug use by children. Connecticut officials said that, for this spending
category, Treasury required that the state report on the number of people
participating in summer youth employment programs. However,
Connecticut officials told us that they did not expect the project to result in
youth employment. These officials also said they did not report a value for
the performance indicator and expressed concerns that not doing so
could result in their not meeting Treasury reporting requirements.
At the time of our review, Treasury officials told us they would expect
recipients to report a zero value for the required performance indicator if a
recipient’s project does not align with the indicator. These officials also
said they use other information that recipients report—including the
project narrative, completion status, and other performance indicators—
as well as information provided in recipients’ recovery plans, where
applicable, to determine if a project is making progress toward other
intended outcomes. 40 However, Treasury officials told us that Treasury
guidance did not specify how recipients are to report on performance
indicators that do not align with the SLFRF awards. They also said they
recognized a lack of clarity in the guidance for recipients who may not
have data to report for a particular performance indicator.
In a draft of our report we provided to Treasury officials on November 2,
2023, for their review and comment, we recommended that Treasury
clarify its guidance on the required performance indicators, including how
recipients are to report on the indicators when they do not align with their
uses of SLFRF awards and Treasury spending categories.
In response to our draft recommendation, Treasury updated its SLFRF
Compliance and Reporting guidance on November 30, 2023, to clarify
how recipients are to report on a project under a certain expenditure
category that is an allowable use of SLFRF awards but does not align
with the required performance indicator. Specifically, Treasury’s updated
guidance states that, in those instances, recipients may report a zero
40In addition to the project and expenditure report, Treasury requires a recovery plan
performance report from certain recipients. The recovery plan performance report is an
annual report that provides information on the projects large recipients are undertaking,
including how they plan to ensure program outcomes are achieved effectively, efficiently,
and equitably. Only states, the District of Columbia, U.S. territories, and metropolitan cities
and counties with a population that exceeds 250,000 residents are required to submit
recovery plan performance reports.
Page 28 GAO-24-106027 COVID-19 Relief
value for the performance indicator. The additional Treasury guidance
may help provide clarity to states and localities in instances when their
projects do not align with the required performance indicator. Treasury’s
actions may also help meet Treasury’s oversight and understanding of
SLFRF program outcomes across recipients.
Technical Issues with Officials in most selected states and localities cited a range of technical
Treasury’s Reporting Portal challenges with Treasury’s reporting portal, which in some cases
contributed to delays in meeting reporting requirements. Those
challenges related to:
Entering and uploading data. Officials in some selected states and
localities had trouble entering SLFRF project and expenditure data onto
Treasury’s reporting portal due to the portal’s limited functionality and
system errors. Officials in Arizona, Florida, Maine, Michigan, and
Nebraska told us that data entry issues prevented them from moving
forward in their reporting. For example, Florida officials told us that the
portal would not allow them to report basic details of an early-stage
broadband project without reporting additional project information that
was not relevant to the project at that time. Officials in Washington State
and Minneapolis, Minnesota described to us difficulties with uploading
bulk documents and receiving error messages that did not detail what
caused the error. For the officials in Minneapolis, this resulted in their
having to use considerable staff time to manually enter data for 50 to 60
projects.
Accessing and amending reports. Officials in some selected states
cited challenges accessing or amending project and expenditure report
submissions. For example, Connecticut, Pennsylvania, and Texas
officials told us that they attempted to download a PDF file of their
quarterly report from Treasury’s reporting portal, but the portal generated
a PDF file with incorrect data. Pennsylvania officials added that
Treasury’s reporting portal continued to create inaccurate reports for the
next reporting period, though officials were ultimately able to work with
Treasury to reconcile the differences. The inaccuracies delayed
Pennsylvania’s ability to share project and expenditure data on the state’s
public website.
Local officials in Sahuarita, Arizona; East Hartford, Connecticut; and
Minneapolis, Minnesota, told us that they could not amend prior reports
through the portal, once submitted. This posed a challenge because
expenditures for a certain quarter, such as infrastructure projects, may be
recorded or processed after that quarter’s reporting deadline. East
Page 29 GAO-24-106027 COVID-19 Relief
Hartford, Connecticut officials told us that, according to government
accounting standards, expenditures must be recorded in the fiscal year in
which services were performed or goods received. As a result,
expenditures reported for a prior quarter may be inaccurate and result in
over- or under-reporting in the following quarter.
Treasury has taken several actions to address some of the technical
issues that states and localities had experienced with the SLFRF
reporting process. For example, Treasury recorded webinars on various
aspects of SLFRF reporting, including on uploading bulk documents to
the portal. As noted earlier, Treasury also generally allows recipients to
submit late reports or make necessary revisions within a designated
period, such as a 60-day window following the reporting deadline. In
August 2023, Treasury officials told us that they were enhancing the
portal, including streamlining a reporting form and developing new tools to
help states upload bulk data.
Awards to NEUs Officials in most selected states described challenges distributing SLFRF
awards to NEUs as required by the American Rescue Plan Act of 2021
(ARPA). They cited challenges related to contacting NEUs to distribute
awards and redistributing SLFRF awards from nonresponsive NEUs (i.e.,
those the state was unable to contact).
Contacting NEUs and distributing awards. Officials in most states told
us that they struggled to contact NEUs in their state and distribute SLFRF
awards within the 30-day deadline established in ARPA. Arkansas,
Illinois, Maryland, Nebraska, and North Carolina officials told us that they
typically do not have reason to contact all NEUs in their state—which for
some states can include thousands of NEUs—and do not have an
established process for doing so. In these states, the limited
administrative capacity of some of the smaller NEUs, such as limited
internet access and lack of full-time staff, exacerbated the distribution
challenges. Officials in Nebraska described having to drive to some of the
NEUs within the state to hand-deliver required documents because the
NEU did not have internet access and could not communicate
electronically with state officials.
To help address these challenges, states requested and Treasury
granted one or more extensions of up to 30 days for distributing the NEU
Page 30 GAO-24-106027 COVID-19 Relief
awards. 41 Under ARPA, an initial extension may be granted if states
certify that the distribution requirement would constitute an “excessive
administrative burden.” 42 In addition, some states leveraged their
relationships with organizations representing state and local
governments, such as the state’s league of municipalities, to help identify
and contact NEUs.
Redistributing awards. In June 2021, Treasury issued guidance
indicating that states “may” redistribute SLFRF funds from non-
responsive NEUs to other NEUs in the state or must return excess funds
to Treasury. 43 Some selected states experienced challenges
understanding Treasury guidance for redistributing NEU awards,
including guidance for non-responsive NEUs (i.e., those the state was
unable to contact). For example, Florida, Nebraska, and North Carolina
officials said that the process outlined in the guidance created confusion
because it did not indicate whether the redistribution process was
required. Further, Treasury did not provide specific details on returning to
Treasury award funding for non-responsive NEUs at that time. State
officials told us that without additional information specified in the
guidance, they were not certain which actions were allowable.
State officials reported taking various actions with the unclaimed funds.
For example, Florida officials said they did not redistribute any unclaimed
41In January 2022, we reported that some states faced challenges that affected their
ability to distribute all SLFRF payments to NEUs. At that time, Treasury officials said some
states have thousands of NEUs and need more time to manage efforts, such as reaching
out to NEUs and processing NEU requests for funds. For example, they said some states
requested an extension so they could have additional time to establish a process for
distributing SLFRF payments. For additional details, see GAO, COVID-19: Significant
Improvements Are Needed for Overseeing Relief Funds and Leading Responses to Public
Health Emergencies, GAO-22-105291 (Washington, D.C.: Jan. 27, 2022).
42If the state was granted an extension to the distribution period but was still unable to
make all the distributions before the end of the extended period, the state may request an
additional extension. Treasury may only grant the additiional extension if (1) the state
provides a written plan specifying when the state expects to make the distribution and the
actions the state has taken and will take to make all distributions before the end of the
extended period; and (2) Treasury determines that the plan is reasonably designed to
distribute all funds to NEUs before the end of the extended period. 42 U.S.C. §
803(b)(2)(C).
43Other NEUs, referred to as residual NEUs in Treasury’s guidance, include NEUs whose
initial allocation was below the 75 percent budget cap and which either (1) requested
funding for itself or (2) declined funding for itself and requested a transfer to the state
under Section 603(c)(4). For Treasury’s guidance to states on distributing SLFRF awards
to NEUs, see Treasury, Coronavirus Local Fiscal Recovery Fund: Guidance on
Distribution of Funds to Non-Entitlement Units of Local Government. June 30, 2021.
Page 31 GAO-24-106027 COVID-19 Relief
funds to the NEUs in the state—which would have resulted in distributing
less than $3 each to more than 300 entities. North Carolina officials said
that, in the case of one NEU, they redistributed its unclaimed funds to the
county in which the NEU is located. North Carolina officials added that the
costs and burdens related to redistributing the funds to the more than 500
NEUs in the state outweighed the value of the award amounts (an
average of $66 per NEU). Treasury officials told us that in response to
issues raised in a draft of our report, Treasury notified North Carolina on
November 16, 2023, that the funds the state had provided to the county
would need to be returned to Treasury.
In April 2023, Treasury provided information regarding the process for
states to return any unclaimed funds to Treasury, rather than
redistributing those funds. 44
Obtaining Assistance from Officials in all 18 selected states and 16 of the 18 selected localities
Treasury sought assistance from Treasury’s Contact Center, either by phone or
email. Treasury created the center in April 2021 to field and respond to
recipients’ inquiries about COVID-19 relief programs that Treasury
administers, including the SLFRF. 45 The center draws on resources from
a number of offices within Treasury. Specifically, the center is staffed by
agents from Treasury’s Bureau of the Fiscal Service, who are to respond
to “basic operational questions” about the SLFRF program, according to
Treasury officials. These agents are to refer IT-related questions (for
example, logging onto Treasury’s reporting portal) to Treasury’s Office of
the Chief Information Officer. They are to refer SLFRF policy-related
questions (for example, questions related to allowable uses) to OCA staff
who manage and administer the SLFRF program.
State and local officials told us that they struggled to obtain timely and
helpful assistance from the Contact Center to address their questions and
concerns about the SLFRF program. Specifically, officials in most states
and some localities told us that Treasury’s assistance was not timely.
Officials in California, Connecticut, Florida, Pennsylvania, and
Washington told us that, in some instances, they received no response
from Treasury or received a response to a time-sensitive question after a
deadline had elapsed. Local officials in Esmeralda County, Nevada, told
44Treasury, Treasury Award Redirect Portal: Completing an Award Redirect Submission.
45Other federal programs included the Coronavirus Capital Projects Fund, the Emergency
Rental Assistance Program, the Homeowner Assistance Fund, and the Local Assistance
and Tribal Consistency Fund.
Page 32 GAO-24-106027 COVID-19 Relief
us they reached out to the Contact Center through multiple emails and
phone calls for help with project and expenditure reporting. However,
officials did not receive a response from Treasury until after the required
report was due.
In addition, officials in most states and some localities told us that, even
when they were able to reach the Contact Center, the assistance
Treasury provided did not meet their needs. For example, officials in
some states said that when they emailed the Contact Center for
clarification on guidance for allowable uses, Treasury responded with
excerpts from the same guidance on which officials were seeking
clarification. Similarly, officials in Washington County, Maine, said that the
assistance received from Treasury on registering for and accessing the
reporting portal was not helpful. The county eventually succeeded in
registering for the portal by working with town managers across
Washington County who were also seeking assistance on the portal
registration process.
Treasury officials told us that limited funding available to administer the
SLFRF had affected their ability to assist recipients through the Contact
Center. Because of this challenge, the Contact Center stopped providing
phone support in June 2022. In September 2022, Treasury notified
SLFRF recipients of the funding constraints affecting its ability to provide
ongoing support to SLFRF and other COVID-19 relief program recipients
served by the Contact Center. 46 In October 2022, Treasury curtailed its
email support and reduced its Contact Center staff by more than 80
percent. Treasury subsequently reopened its phone support and
increased the number of Contact Center staff after receiving authority in
the Consolidated Appropriations Act, 2023, to use certain unobligated
funds to cover administrative expenses necessary to respond to COVID-
19. 47
To improve its operations, Treasury assessed the number of agents
needed in the Contact Center to manage recipients’ phone calls and
emails, especially during expected periods of increased demand.
46The September 23, 2022, letter from Treasury noted that “Congress appropriated
funding to Treasury to administer recovery programs, and some programs were given
more than enough funding to cover their operations. But in the case of several other
programs, the available funding is insufficient to allow Treasury to maintain the current
levels of administrative support.” SLFRF was one of the “several other programs” the letter
cited.
47Pub. L. No. 117-328, div. LL, § 102(d), 136 Stat. 4459, 6103 (2022).
Page 33 GAO-24-106027 COVID-19 Relief
Treasury officials said they also (1) trained Contact Center staff on
common SLFRF program challenges recipients faced; and (2) organized
internal weekly meetings to highlight any new challenges, coordinate
answers to common questions, and agree on standardized solutions.
Treasury officials told us that responding to IT- or SLFRF policy-related
questions can result in longer response times because the questions are
more complex and the staff responsible for responding to these questions
are not dedicated Contact Center staff and assume other job
responsibilities. However, Treasury’s efforts to improve the Contact
Center’s ability to provide timely and useful information have not been
comprehensive. In particular, Treasury has not assessed staffing needs
within the units responsible for responding to IT- or SLFRF policy-related
questions with timely and useful answers.
According to leading human capital practices, agencies need to take
steps to sustain a workforce with the skills and competencies critical to
achieving the agency’s strategic goals. 48 Achieving such a workforce
depends on having effective human capital management through
developing human capital strategies. Such strategic workforce planning
includes the agency assessing current and future critical skill needs by,
for example, analyzing the gaps between current skills and future needs,
and developing strategies for filling the gaps identified in workforce skills
or competencies.
Without a comprehensive assessment to determine adequate staffing for
addressing questions received through the Contact Center, assistance
from Treasury may not be fully effective for states and localities seeking
assistance. Therefore, states and localities may be unable to obtain the
information they need to effectively manage their awards, such as
ensuring their proposed uses will be allowable under Treasury reporting
requirements.
48GAO, Human Capital: Key Principles for Effective Strategic Workforce Planning,
GAO-04-39 (Washington, D.C.: Dec. 11, 2003).
Page 34 GAO-24-106027 COVID-19 Relief
Treasury has made progress in developing and implementing internal
Treasury Has Not controls for monitoring recipients’ use of SLFRF awards, as we previously
Fully Implemented Its recommended. 49 However, the agency did not implement all key control
activities as documented in its policies and procedures. For example,
Plan to Monitor Treasury did not update its key guidance for reviewing project and
Recipients’ Use of expenditure reports for potential noncompliance to reflect changes to
review procedures. It also did not issue timely management decisions
SLFRF Funds pertaining to SLFRF findings in recipients’ single audit reports.
Treasury Assessed Treasury conducted a risk assessment of the SLFRF and designed
Program Risk in control activities to mitigate program risks. These risk assessment
procedures were designed to address federal internal control standards,
Developing SLFRF
which state that agencies should identify, analyze, and respond to risks
Recipient Monitoring related to achieving defined objectives, and OMB’s guidance on
Procedures effectively implementing ARPA programs. 50
Treasury’s risk assessment addressed award issuance and payments,
including validation of recipients’ eligibility to receive payments. Treasury
officials also reviewed overall program risk areas to determine (1) the
strategy for testing recipient reporting data (including the sampling
methodology), and (2) the resources Treasury would require to analyze
risk data in detail.
Following the risk assessment process, Treasury officials told us that they
designed control activities to mitigate identified risks. For example, they
took actions such as:
• Checking government-wide databases so that recipients could not
receive payments without having an active System for Award
49GAO-22-105051.
50OMB Memorandum M-21-20, Promoting Public Trust in the Federal Government
through Effective Implementation of the American Rescue Plan Act and Stewardship of
the Taxpayer Resources (Mar. 19, 2021), states that federal agencies administering
programs authorized by ARPA are to comply with the requirements of the Payment
Integrity Information Act of 2019 and implementing OMB guidance for assessing payment
integrity risks and designing controls for new programs to mitigate payment integrity risks.
Further, the memorandum notes that agencies must apply the requirements of title 2 of
the Code of Federal Regulations, Grants and Agreements (2 C.F.R.) to federal financial
assistance funded through ARPA to the maximum extent authorized by law. Key risk
evaluation provisions in section 200.206 of 2 C.F.R. include a variety of considerations
that agencies may apply when evaluating the risks posed by applicants of federal awards,
such as financial stability, management systems and standards, history of performance,
audit reports and findings, and ability to effectively implement requirements. 2 C.F.R. §
200.206.
Page 35 GAO-24-106027 COVID-19 Relief
Management (SAM.gov) registration. 51 According to Treasury officials,
this control identified instances where recipients had no existing
SAM.gov account or had an expired SAM.gov account. For those
recipients, Treasury officials stated that they did not make payment
until the recipients had either created or renewed their SAM.gov
registration.
• Developing controls such as the project and expenditure report
compliance matrix, which systematically maps risks to specific
program requirements, catalogs each identified risk, and identifies one
or more proposed internal controls designed to address the assessed
risk. Officials stated that Treasury includes risks identified through the
compliance matrix in an inventory of business rules and analytics
scenarios that Treasury applies to recipient data when reviewing
project and expenditure reports.
Treasury focused its development of monitoring controls on higher-level
risks, such as the allowable use of funds; quantitative considerations,
such as which recipients received the largest amount of funds; and re-
evaluation of risk levels of noncompliant recipients over time. Treasury
relied on the overall results of its risk assessment process to develop
internal control activities for monitoring of SLFRF recipients, including
reviews of recipients’ project and expenditure reporting data and single
audit reports.
Treasury Did Not Update Treasury’s postaward monitoring process includes reviews of SLFRF
Its Key Internal Guidance recipient data captured in the periodic project and expenditure reports
that recipients are required to submit electronically through Treasury’s
for Reviewing Project and
reporting portal.
Expenditure Reports to
Reflect Changes to Treasury’s policies and procedures for award management of SLFRF and
Review Procedures other federal financial assistance programs administered by OCA is
captured in two documents.
• Award Management Policy for Financial Assistance Recovery
Programs, issued in July 2022 and updated in May 2023. This
document provides an overview of the award management process
for various Treasury programs including the SLFRF. It includes topics
51SAM.gov is the official U.S. government system where contractors, organizations, or
individuals applying for assistance awards; those receiving loans; sole proprietors;
corporations; and partnerships register to do business with the U.S. government.
Page 36 GAO-24-106027 COVID-19 Relief
such as program design, awards, postaward management,
remediation, award closeout, and post-closeout activities. 52
• Data Validation, Compliance Testing, and Noncompliance
Remediation Procedures, Version 2.0, issued in January 2023 and
updated in Version 2.1 in April 2023. This document outlines the
activities and requirements for compliance testing of various Treasury
programs, including the SLFRF. Specifically, it documents standard
procedures for compliance testing, processes for identifying and
remediating instances of noncompliance, and step-by-step
instructions for staff to execute compliance testing.
Treasury staff are to use the procedures in these two key documents, in
combination with other policies addressing various aspects of SLFRF
program administration, to complete the reviews of SLFRF recipients’
project and expenditure report data.
Based on our review of documentation for the reporting cycle covering
expenditures and activity from April 1, 2022, through June 30, 2022 (the
second quarter of fiscal year 2022, or Q2 2022), and interviews with
Treasury officials, we found that Treasury did not perform all monitoring
processes that the agency had developed and documented for reviewing
recipients’ quarterly project and expenditure reports. Specifically, we
found that Treasury (1) did not investigate all potential instances of
noncompliance identified during the automated first level of reviews, and
(2) conducted a modified sampling approach in its manual second level of
reviews. Also, Treasury’s second level of reviews did not incorporate two
of the four risk parameters designed for selecting second level sample
items.
• In the first level of reviews, Treasury evaluated 2,090 recipients that
submitted project and expenditure reports and the automated first
level review identified 920 of the reviewed recipients as potentially
noncompliant. However, Treasury did not further investigate through a
second level review all 920 potentially noncompliant recipients.
Treasury’s selection process for its second level review was
inconsistent with the Award Management Policy for Financial
Assistance Recovery Programs, which states that second level testing
52The federal award closeout process refers to the process by which the agency
determines that a nonfederal entity has completed all applicable administrative actions
and performed all the required work of the award. These recipient actions include
submission of all financial, performance, and other reports as required by the terms and
conditions of the award, and liquidation of all financial obligations incurred under the
award following the end of the period of performance. 2 C.F.R. § 200.344.
Page 37 GAO-24-106027 COVID-19 Relief
is required for recipients with instances of noncompliance identified by
first level testing. Instead, Treasury selected a smaller sample of 349
recipients for second level testing.
• Treasury did not test for Mode A “Revenue Replacement” and “Burn
Rate” analytics or Mode B “Significant Projects” in its second level
testing. Treasury officials stated that their compliance testing
approach initially envisioned second level testing based on four
modes: A, B, C, and D. 53 Instead, Treasury performed second level
testing using sampling only from Modes C and D.
Treasury officials stated that multiple factors led to their decision to depart
from conducting reviews as documented in their policies, including (1) the
large number of recipients in the SLFRF program; (2) reporting system
and process improvements implemented based on lessons learned in
early reporting; (3) hiring and onboarding of personnel; (4) false positive
results in certain testing procedures; (5) limited administrative funding that
ARPA provided for the SLFRF program; (6) staffing levels consisting of
only two compliance analysts for the review of Q2 2022 project and
expenditure reports; and (7) a lack of analytic data needed to conduct
some second level testing procedures.
Treasury documented its rationale for departing from the policies
documented in its Award Management Policy for Financial Assistance
Recovery Programs in internal memorandums issued in October and
November 2022. Specifically, Treasury cited the need to minimize
backlogs in quarterly testing and decrease the overall level of effort while
also maintaining an appropriate degree of consistency with the originally
proposed project and expenditure report testing approach. In addition,
Treasury issued Recipient Risk Scoring and Analysis Procedures in May
2023. Under these procedures, recipients are given a risk score based on
multiple factors, including the results of initial testing. In July 2023,
Treasury officials stated they were developing a new methodology that
would place a greater emphasis on systematic reviews of certain
recipients and incorporate the recipients’ risk score. Treasury officials
stated they anticipated implementing the new methodology for the review
of reports in a future quarter.
53Per Treasury, Mode A is a test of high-risk uses of funds, targeting prohibited uses and
more sensitive project types such as revenue replacement. Mode B is a test of
concentration risk used to analyze recipients with a large portion of their award dedicated
to a specific project category. Mode C is a test of financial risk centering on recipients by
size of allocation. Mode D addresses Treasury’s portfolio risk by focusing on continued
testing and review of the recipient portfolio to achieve maximum coverage over time.
Page 38 GAO-24-106027 COVID-19 Relief
While Treasury officials have issued updated supplemental
memorandums for performing project and expenditure report reviews
based on lessons learned in the quarters for which reviews were
completed, Treasury has not explicitly incorporated those updated
procedures into key top-level documents, such as the Awards
Management Policy for Financial Assistance Recovery Programs.
Standards for Internal Control in the Federal Government calls for entity
management to document policies in the appropriate level of detail to
allow management to effectively monitor the control activity, and
periodically review policies, procedures, and related control activities for
continued relevance and effectiveness in achieving the entity’s objectives.
By not updating the policies in its top-level guidance, Treasury increases
the risk that its staff may not conduct future reviews of quarterly project
and expenditure reports consistently over time, and in compliance with
documented policies and procedures.
Treasury Has Made Federal awarding agencies have oversight responsibilities for the funds
Progress in Implementing that they award to nonfederal entities. A single audit is an entity-wide
audit of the award recipient’s expenditure of federal awards and of its
Single Audit Report
financial statements. For major programs, this audit can help identify
Reviews but Deficiencies deficiencies in the award recipient’s compliance with the provisions of
Remain laws, regulations, contracts, or grant agreements, and in its financial
management and internal control systems relating to compliance
requirements. 54 Correcting such deficiencies can help provide reasonable
assurance about the effective use of federal funds and reduce the
likelihood of federal improper payments.
Treasury’s responsibilities in administering the SLFRF include ensuring
that (1) single audits are completed and submitted in a timely manner,
and (2) SLFRF award recipients take appropriate and timely corrective
action in response to single audit findings. 55
Treasury has made progress in developing this component of the SLFRF
recipient monitoring process by (1) issuing policies and procedures for
reviews of recipients’ single audit reports, and (2) developing and
54Single audits are entity-wide financial and compliance audits that focus on accounting
and administrative controls. The single audit serves to advise federal oversight officials
and program managers on whether an entity’s financial statements are fairly presented,
and provide reasonable assurance that federal financial assistance programs are
managed in accordance with applicable laws and regulations.
552 C.F.R. § 200.513(c)(1) and (c)(3).
Page 39 GAO-24-106027 COVID-19 Relief
implementing an electronic dashboard tool to summarize key information
from single audit reports that the agency is responsible for monitoring.
Single audit reports issued for SLFRF recipients identified through
Treasury’s single audit report monitoring process have identified a range
of findings of noncompliance with program requirements. For example:
• Whittier, California. For the fiscal year ending June 30, 2022, the
city’s auditor found that the city incorrectly reported approximately
$2.5 million in SLFRF expenditures on its project and expenditure
report to Treasury.
• Utah. For the fiscal year ending June 30, 2022, the state’s auditor
found that the state overestimated its revenue loss calculation by
approximately $727 million, potentially causing material
noncompliance with program requirements.
Treasury Developed Policies Treasury has issued policies and procedures for reviews of single audit
for Single Audit Report reports of recipients and issuance of management decisions as part of its
Reviews SLFRF award monitoring process. These policies, which are documented
in procedures as (1) an appendix to the Award Management Policy for
Financial Assistance Recovery Programs, titled “ORP Single Audit
Responsibilities Policy,” which provides high-level information on the
various Treasury operational units that contribute to the single audit report
review process, and (2) additional procedures issued in June 2023, for
executing its single audit responsibilities as a federal awarding agency,
including descriptions of its single audit portfolio management process
and the management decision preparation, review, approval, and
issuance process. 56
Treasury Developed and To implement its single audit report review policies, Treasury developed
Implemented a Single Audit an electronic single audit dashboard. The dashboard is a recipient
Dashboard but Did Not Meet monitoring tool that summarizes important metrics of underlying program
Requirements for Reviewing data and audit findings, including compliance findings. The dashboard
Single Audit Reports and collects, stores, and displays single audit and program-specific audit data
Following up on Findings for programs as reported in the Federal Audit Clearinghouse (FAC),
56Standard Operating Procedure: Single Audit Prioritization, Resolution and Management
Decision Letter Issuance, Version 1.0, and Single Audit Procedures, Version 1.1.
Page 40 GAO-24-106027 COVID-19 Relief
which operates on behalf of OMB. 57 The Single Audit Act and OMB’s
single audit guidance requires each award recipient to submit an audit
reporting package to the FAC, which must maintain a database of
completed audits and provide appropriate information to federal agencies.
Treasury staff are responsible for accessing the FAC monthly to update
the data in the dashboard, prioritizing all single audit findings from the
dashboard into three categories (high, medium, and low priority) and
performing single audit resolution activities. Figure 5 below provides a
structural overview of Treasury’s single audit dashboard.
57The FAC states that its primary purposes are to: (1) distribute single audit reporting
packages to federal agencies; (2) support OMB oversight and assessment of federal
award audit requirements; (3) maintain a public database of completed audits; and (4)
help auditors and auditees minimize the reporting burden of complying with single audit
requirements. The reporting package includes (1) the award recipient’s financial
statements and schedule of expenditures of federal awards; (2) a summary schedule of
prior audit findings, including the status of all single audit findings included in the prior
audit’s schedule of findings and questioned costs for federal awards; (3) the auditor’s
report (including an opinion on the award recipient’s financial statements and schedule of
expenditures of federal awards, reports on internal control and compliance with laws,
regulations, and provisions of contracts or grant agreements for each major program, and
a schedule of findings and questioned costs); and (4) a corrective action plan. 2 C.F.R. §
200.512(c).
Page 41 GAO-24-106027 COVID-19 Relief
Figure 5: Structural Overview of Treasury’s Office of Recovery Program’s (ORP) Single Audit Dashboarda
a
ORP was renamed the Office of Capital Access as of November 2, 2023. The entity was known as
the Office of Recovery Programs at the time we reviewed the Single Audit Dashboard.
Note: Step 2 states that the “FAC accepts and publishes all audit submissions.” However, there is a
limited exception to this general practice. An auditee that is an Indian Tribe or a tribal organization
may opt not to authorize the FAC to make the reporting package publicly available on a website. 2
C.F.R. § 200.512(b)(2).
As of July 2023, Treasury officials stated that they had completed the
initial development of the single audit dashboard and had actively utilized
it; held trainings and demonstrations of the dashboard for staff; and
updated the dashboard monthly with new data from the FAC. Treasury’s
monthly review of dashboard data in July 2023 identified 427 reports for
SLFRF recipients with single audit findings related to the program.
Treasury officials told us in July 2023 that single audit review forms—
which document the results of the single audit report review performed by
Treasury staff for each recipient—had not been completed for all reports
because the reviews were ongoing at that time. Treasury officials also
told us in September 2023 that Treasury reviews single audit findings by
recipient across all COVID-19 relief programs that it administers, rather
than by program. Treasury resolves findings for all COVID-19 relief
Page 42 GAO-24-106027 COVID-19 Relief
programs for a particular recipient as part of that review. Treasury
prioritizes reviews of recipients based on various factors, including
whether a recipient has a finding in a program that is undergoing closeout
procedures.
During our review, Treasury continued to face technical challenges that
limited its ability to monitor relevant single audit report findings
comprehensively. For example, in August 2023, Treasury officials stated
that the dashboard may not capture all required reports. Officials stated
that they had identified 1,907 SLFRF recipients that (1) had received
more than $750,000 in funds for programs that the agency administers;
(2) had not submitted a single audit report since 2019; and (3) reported
spending more than $750,000 in SLFRF funds. They noted that this
population may be over inclusive or under inclusive due to a variety of
factors, such as the recipients’ fiscal year end dates and the dates when
all expenditures occurred, both of which affect the requirement to submit
an audit report to the FAC. 58 Until Treasury enhances its process for
identifying which SLFRF recipient reports are missing from the FAC, there
is a risk that the agency’s monitoring process will not capture all single
audit reports that Treasury is required to review as a federal awarding
agency. 59
As a result of such limitations, Treasury’s initial reviews of SLFRF
recipients’ single audit reports could not provide reasonable assurance
that the single audit report review process systematically addressed the
full scope of the agency’s oversight responsibilities, including identifying
and following up with all SLFRF recipients who had relevant single audit
report findings.
Treasury Missed Following the review of a single audit report with audit findings, federal
Deadlines to Issue agencies issue management decisions to provide award recipients with
written notification of the agency’s position on single audit findings.
Management Decisions
Management decisions must disclose information including a clear
for SLFRF Findings statement about whether the audit finding is sustained, the reasons for
the decision, and the expected auditee action to repay disallowed costs (if
any), make financial adjustments, or take other action. In addition, the
58In comparison to the 1,907 recipients who may not have submitted single audit reports
as of August 2023, Treasury officials noted that as of September 30, 2023, 7,399 Treasury
recipients had submitted single audit reports including 483 SLFRF recipients with a total of
1,097 SLFRF findings.
592 C.F.R. § 200.513(c).
Page 43 GAO-24-106027 COVID-19 Relief
management decision should describe any appeal process available to
the auditee. OMB’s single audit guidance states that the federal awarding
agency must issue such management decisions within 6 months of
acceptance of the audit report by the FAC. 60 Without a timely notification
that contains all of the OMB requirements for written management
decisions, award recipients may be unclear about the agency’s position
on the single audit findings and what corrective actions, if any, they need
to take to address the single audit findings.
Per OMB Memorandum M-21-20, federal awarding agencies were
directed to allow program recipients and subrecipients with fiscal year-
end dates through June 30, 2021, to delay completing and submitting
their single audit reporting packages to the FAC to 6 months beyond the
normal due date. As a result of this extension, entities that received and
spent SLFRF awards during a fiscal year ending on June 30, 2021, would
have been required to submit their single audit reports to the FAC by
September 30, 2022. 61 This extension had the effect of pushing out the
deadline for awarding agencies to issue management decisions related to
single audit report findings. Specifically, for recipients that submitted
single audit reports to the FAC by September 30, 2022, the awarding
agency was required to issue management decisions by March 31, 2023.
In October 2022, Treasury officials stated they had identified 90 single
audit reports that included a total of 194 findings related to the SLFRF
program. However, in July 2023, Treasury officials stated that Treasury
had not yet issued any management decisions related to single audit
report findings pertaining to SLFRF, including findings identified in single
audit reports submitted to the FAC as of September 30, 2022, within the
required 6-month timeframe. As of September 2023, Treasury had issued
management decisions for nine recipients, two of which were SLFRF
recipients with findings, and planned to issue additional management
decisions in the future. Treasury officials stated that as of September 30,
2023, an additional 35 management decisions for 33 recipients were in
process using the agency’s recently established automated management
decision process and would be issued in the coming weeks. Twenty-six of
the 33 recipients had SLFRF findings. Treasury officials further stated that
602 C.F.R. § 200.521(d).
61Pursuant to OMB guidance, the normal due date for submitting the single audit report is
within the earlier of 30 calendar days after receipt of the auditor’s report, or 9 months after
the end of the audit period (or the next business day if the due date falls on a federal
holiday or a weekend). 2 C.F.R. § 200.512(a)(1).
Page 44 GAO-24-106027 COVID-19 Relief
as of November 30, 2023, Treasury had issued 45 management
decisions. See figure 6 for a timeline of required single audit report
deadlines and management decision deadlines.
Figure 6: Timeline for Management Decisions for Single Audit Findings Reported
for Fiscal Years Ending June 30, 2021
a
According to 2 C.F.R. 200.512(a)(1), the single audit reporting package must be submitted within the
earlier of 30 calendar days after receipt of the auditor’s report(s), or 9 months after the end of the
audit period (or the next business day if the due date falls on a federal holiday or a weekend). We
used the 9-month time period for simplicity purposes and because it generally represents the
maximum amount of time award recipients would have to submit single audit reports.
According to Treasury officials, the agency faced challenges in the
implementation of a systematic review of SLFRF recipients’ single audit
reports and issuing management decisions occurred because Treasury
did not have existing single audit processes or staff to administer these
processes when the program was established. The agency built its single
audit capabilities through: (1) hiring additional staff with single audit
expertise, (2) developing policies and procedures for review of single
audit findings and issuance of management decisions, and (3) creating
the dashboard. Treasury officials also stated in September 2023 that they
continue to assess the backlog of single audit report reviews and
anticipated workload in developing a plan to continue to resolve single
audit findings. They further noted in October 2023 that Treasury had
increased staffing levels for audit and compliance resolution functions
from two to four analysts to address the backlog of reviews.
Page 45 GAO-24-106027 COVID-19 Relief
Until Treasury issues timely management decisions to SLFRF recipients
with relevant single audit findings, there is an increased risk that potential
findings related to unallowable uses of program funds may remain
unidentified and uncorrected for significant periods of time, which in turn
increases the risk of losses to the government in the form of federal
improper payments.
The SLFRF program provided an unprecedented amount of funds to
Conclusions states and localities to help them respond to and recover from the
COVID-19 pandemic. Faced with the challenge of standing up the
program for states and tens of thousands of local governments, Treasury
quickly disbursed SLFRF funds and took a range of important steps to
administer the program. Among other things, Treasury created additional
flexibilities for using SLFRF funds, issued guidance and developed
reporting requirements, and disseminated information in multiple forms.
State and local officials with whom we met acknowledged the benefits of
the SLFRF program and their ability to fund projects that otherwise may
not have been possible, due to the scale and flexibility of the program.
However, opportunities remain for Treasury to help ensure that states and
localities are equipped with assistance to administer their SLFRF funds. A
comprehensive assessment of its staffing needs to address recipient
requests is necessary to help Treasury provide timely and useful
assistance to states and localities going forward.
Further, Treasury has taken steps to provide oversight and accountability
of the SLFRF by requiring recipients to provide an accounting of their
spending through project and expenditure reports, and establishing and
conducting monitoring procedures for reviewing these reports on an
ongoing basis. Treasury modified those procedures, adapting to lessons it
learned. While Treasury took steps to document the reasons for
conducting alternative review procedures and has indicated plans to
modify its existing policies and procedures, Treasury has yet to fully
incorporate policy modifications into the key top-level documents or
implement those modified policies and procedures consistently in
quarterly reviews following the second quarter of 2022. In addition,
Treasury has neither completed a systematic review of all SLFRF
program recipients’ single audit reports nor issued all related
management decisions within required timeframes. Given the delays in its
single audit review process and outstanding management decisions, it is
important that Treasury eliminate the backlog of single audit report
reviews and issue timely management decisions to address the risk that
potential findings related to unallowable uses of program funds may
remain unknown to Treasury officials and uncorrected.
Page 46 GAO-24-106027 COVID-19 Relief
We are making four recommendations to the Department of the Treasury:
Recommendations for
Executive Action The Secretary of the Treasury should comprehensively assess staffing
needs for the Contact Center to ensure that it is able to respond timely to
SLFRF recipient requests for assistance and with information that meets
their needs. (Recommendation 1)
The Secretary of the Treasury should update and implement the agency’s
documented policies and procedures for monitoring recipients’ use of
SLFRF awards to reflect lessons learned from reviewing recipients’
project and expenditure reports. (Recommendation 2)
The Secretary of the Treasury should conduct timely systematic reviews
of SLFRF recipients’ single audit reports and document the results of
those reviews. (Recommendation 3)
The Secretary of the Treasury should issue timely management decisions
related to SLFRF findings in accordance with OMB’s single audit
guidance. (Recommendation 4)
We provided a draft of this report to Treasury for review and comment.
Agency Comments Treasury provided written comments, which we summarize below and
and Our Evaluation reproduce in appendix I. Treasury also provided technical comments,
which we incorporated as appropriate. In addition, we provided excerpts
of a draft of this report to officials in the 18 states and 18 localities we
included in our review. We incorporated their technical comments as
appropriate.
In its written comments, Treasury generally agreed with all four of our
recommendations and described actions it had taken or planned to take
to address two of those recommendations.
Regarding our first recommendation that Treasury should
comprehensively assess its staffing needs for its Contact Center,
Treasury agreed and stated that it has begun this assessment and will
update us once it is complete.
Regarding our second recommendation that Treasury should update
and implement the agency’s documented policies and procedures for
monitoring recipients’ use of SLFRF awards to reflect lessons learned
from reviewing recipients’ project and expenditure reports, Treasury
agreed and stated that it is taking steps through organizational changes
to increase monitoring capacity. Treasury also stated that it is assessing
Page 47 GAO-24-106027 COVID-19 Relief
its policies and procedures for monitoring use of SLFRF funds and will
update us with revised procedures when complete.
Regarding our third and fourth recommendations that Treasury should
conduct timely, systematic reviews of SLFRF recipients’ single audit
reports, document the results of those reviews, and issue timely
management decisions related to SLFRF findings in accordance with
OMB’s single audit guidance, Treasury generally agreed. Treasury stated
that it agrees that reviewing and resolving single audit findings is an
important piece of effective federal award administration and
monitoring. Treasury also stated that it made progress in implementing
single audit review processes despite facing unique challenges, such
as a lack of single audit infrastructure at the outset of the pandemic.
We recognize the progress Treasury has made toward implementing
single audit review processes and will monitor Treasury’s further
efforts in this area.
In a draft of this report, we had recommended that Treasury should clarify
its guidance on actions SLFRF recipients may take on obligating and
reobligating their awards to comply with statutory deadlines.
Subsequently, on November 20, 2023, Treasury issued an interim final
rule (IFR) to amend the definition of “obligation” to provide flexibility and
guidance to recipients regarding the amendment and replacement of
contracts and subawards. The IFR clarifies that (1) under certain
circumstances, recipients are considered to have incurred an obligation
by the statutory deadline of December 31, 2024, with respect to a
requirement under federal law or regulation or a provision of SLFRF
award terms and conditions that they become subject to as a result of
receiving or expending funds; and (2) recipients reobligating funds to new
contractors or subrecipients after December 31, 2024, will be considered
to have used their funds to cover an obligation incurred prior to December
31, 2024, under certain circumstances, such as when a contractor or
subrecipient goes out of business. Because the IFR was issued during
the review and comment period and addressed the issues raised in our
draft report, we removed the recommendation from this report and
modified the report accordingly.
We had also recommended in a draft of this report that Treasury should
clarify its guidance on required performance indicators, including how
SLFRF recipients are to report on required performance indicators when
those indicators do not align with recipients’ uses of SLFRF awards and
Treasury spending categories. Subsequently, Treasury updated its
Page 48 GAO-24-106027 COVID-19 Relief
SLFRF Compliance and Reporting guidance on November 30, 2023, to
clarify how recipients are to report on a project under a certain
expenditure category that is an allowable use of SLFRF awards but does
not align with the required performance indicator. Because the guidance
was issued during the review and comment period and addressed the
issues we raised in our draft report, we removed the recommendation
from this report and modified the report accordingly.
We are sending a copy of this report to the appropriate congressional
addressees; the Secretary of the Treasury; state and local officials in the
18 states and 18 localities we interviewed; and other interested parties. In
addition, the report is available at no charge on the GAO website at
https://www.gao.gov.
If you or your staff have any questions about this report, please contact
Jeff Arkin at (202) 512-6806 or arkinj@gao.gov, or M. Hannah Padilla at
(202) 512-5683 or padillah@gao.gov. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last page
of this report. GAO staff who made key contributions to this report are
listed in appendix II.
Jeff Arkin
Director
Strategic Issues
M. Hannah Padilla
Director
Financial Management and Assurance
Page 49 GAO-24-106027 COVID-19 Relief
List of Addressees
The Honorable Patty Murray
Chair
The Honorable Susan Collins
Vice Chair
Committee on Appropriations
United States Senate
The Honorable Ron Wyden
Chairman
The Honorable Mike Crapo
Ranking Member
Committee on Finance
United States Senate
The Honorable Bernard Sanders
Chair
The Honorable Bill Cassidy, M.D.
Ranking Member
Committee on Health, Education, Labor, and Pensions
United States Senate
The Honorable Gary C. Peters
Chairman
The Honorable Rand Paul, M.D.
Ranking Member
Committee on Homeland Security and Governmental Affairs
United States Senate
The Honorable Kay Granger
Chairwoman
The Honorable Rosa L. DeLauro
Ranking Member
Committee on Appropriations
House of Representatives
The Honorable Cathy McMorris Rodgers
Chair
The Honorable Frank Pallone, Jr.
Ranking Member
Committee on Energy and Commerce
House of Representatives
Page 50 GAO-24-106027 COVID-19 Relief
The Honorable Mark E. Green, M.D.
Chairman
The Honorable Bennie G. Thompson
Ranking Member
Committee on Homeland Security
House of Representatives
The Honorable James Comer
Chairman
The Honorable Jamie Raskin
Ranking Member
Committee on Oversight and Accountability
House of Representatives
The Honorable Jason Smith
Chairman
The Honorable Richard Neal
Ranking Member
Committee on Ways and Means
House of Representatives
The Honorable John Barrasso, M.D.
United States Senate
The Honorable John Cornyn
United States Senate
The Honorable Steve Daines
United States Senate
The Honorable Charles E. Grassley
United States Senate
The Honorable James Lankford
United States Senate
The Honorable Tim Scott
United States Senate
The Honorable John Thune
United States Senate
Page 51 GAO-24-106027 COVID-19 Relief
The Honorable Todd Young
United States Senate
Page 52 GAO-24-106027 COVID-19 Relief
Appendix I: Comments from the Department
Appendix I: Comments from the Department of
the Treasury
of the Treasury
Page 53 GAO-24-106027 COVID-19 Relief
Appendix I: Comments from the Department of
the Treasury
Page 54 GAO-24-106027 COVID-19 Relief
Appendix I: Comments from the Department of
the Treasury
Page 55 GAO-24-106027 COVID-19 Relief
Appendix II: GAO Contacts and Staff
Appendix II: GAO Contacts and Staff
Acknowledgments
Acknowledgments
Jeff Arkin, (202) 512-6806 or arkinj@gao.gov.
GAO Contacts
M. Hannah Padilla, (202) 512-5683 or padillah@gao.gov.
In addition to the above contacts, Brenda Rabinowitz (Assistant Director),
Staff Shirley Abel (Assistant Director), Dan Webb (Analyst-in-Charge), Colleen
Acknowledgments Corcoran (Analyst-in-Charge), Mary Ann Hardy (Analyst-in-Charge),
Ralanda Sasser, Andony Payne, James Toscano, Samantha Sloate,
Madeline Kasik, Gary Wiggins, and Megan Jones made key contributions
to this report. Steven Putansu, Dylan Stagner, Samantha Lalisan,
Madeline Barch, and Michael Bechetti also provided support.
Page 56 GAO-24-106027 COVID-19 Relief
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