2023 Compliance Supplement: Emergency Rental Assistance Program, Assistance Listing 21.023 (Treasury)
Summary
2023 Compliance Supplement section for the Treasury Emergency Rental Assistance Program, Assistance Listing 21.023, which notes the program is considered higher risk for 2023 under 2 CFR section 200.519(c)(2). It explains that ERA 1 was authorized by the Consolidated Appropriations Act, 2021 and ERA 2 by the American Rescue Plan Act, and describes program objectives as direct payments to eligible entities to assist eligible households with financial assistance and housing stability services. It states ERA 1 provided $25 billion and ERA 2 provided $21.55 billion, with Treasury making initial ERA 2 payments of 40 percent of an eligible grantee's total award. The text is Treasury's own compliance guidance for auditors and no date beyond 2023 is printed.
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“2023 Compliance Supplement: Emergency Rental Assistance Program, Assistance Listing 21.023 (Treasury).”
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2023 Emergency Rental Assistance Program Treasury
DEPARTMENT OF THE TREASURY
ASSISTANCE LISTING 21.023 EMERGENCY RENTAL ASSISTANCE PROGRAM
I. PROGRAM OBJECTIVES
Note: This program is considered a “higher risk” program for 2023, pursuant to 2 CFR section
200.519(c)(2). Refer to the “Programs with Higher Risk Designation” section of Part 8,
Appendix IV, Internal Reference Tables, for a discussion of the impact of the “higher risk”
designation on the major program determination process.
Two pieces of legislation authorized funding for Emergency Rental Assistance. The
authorizations include some different legal requirements. Therefore, this Compliance
Supplement addresses the requirements as “ERA 1” and “ERA 2.” ERA 1 was authorized by
Division N, Title V, Section 501 of the Consolidated Appropriations Act, 2021 (the Act), Pub. L.
No. 116-260 (December 27, 2020), codified at 15 USC 9058a. ERA 2 was authorized by Title
III, Subtitle B, Section 3201 of the American Rescue Plan Act (ARPA), 2021, Pub. L. No. 117-2
(March 11, 2021), codified at 15 USC 9058c. Both ERA 1 and ERA 2 funding is defined as
“other financial assistance” per 2 CFR Part 200.1 and both ERA 1 and ERA 2 are administered
by Treasury as direct payments for specified use.
The purpose of ERA is to provide direct payments to eligible entities to assist eligible
households with financial assistance and to provide housing stability services and, in the case of
ERA 2 as applicable, to cover the costs for other affordable rental housing and eviction
prevention activities. ERA grantees may provide assistance directly to eligible landlords and
utility providers on behalf of an eligible household or directly to an eligible household (See 15
USC 9058a(c)(2)(C)(i) and FAQ 12 for more detail on landlords and utility provider
participation in the program). Financial assistance for eligible households may include payment
of rent, rental arrears, utilities and home energy costs, utilities and home energy costs arrears,
and other expenses related to housing. ERA grantees may also use funds to provide housing
stability services as authorized by the respective statutes.
II. PROGRAM PROCEDURES
A. Overview
ERA 1 provided $25 billion for the US Department of the Treasury (Treasury) to make
payments to States (defined to include the District of Columbia), US territories (Puerto
Rico, US Virgin Islands, Guam, Northern Mariana Islands, and American Samoa), Indian
tribes or their tribally designated housing entities, as applicable, the Department of
Hawaiian Home Lands, and certain local governments with more than 200,000 residents.
These entities are collectively referred to as “eligible grantees” or “ERA 1 grantees.”
ERA 1 award funds may be used to provide financial assistance and housing stability
services to eligible households. All ERA 1 grantees that submitted the requested
documentation to Treasury and executed a financial assistance agreement received their
total ERA 1 award funds in one payment.
Compliance Supplement 2023 4-21.023-1
2023 Emergency Rental Assistance Program Treasury
ERA 2 provided $21.55 billion for Treasury to make payments to States (defined to
include the District of Columbia), US Territories (Puerto Rico, US Virgin Islands, Guam,
Northern Mariana Islands, and American Samoa), and local governments with more than
200,000 residents. These entities are collectively referred to as “eligible grantees” or
“ERA 2 grantees.” ERA 2 award funds may be used to assist eligible households with
financial assistance and to provide housing stability services and, as applicable, to cover
the costs for other affordable rental housing and eviction prevention activities.
Pursuant to 15 USC 9058c (c)(1), Treasury made initial payments of 40 percent of an
eligible grantee’s total award amount to each grantee under ERA 2 that submitted the
required documentation and executed the financial assistance agreement. Through
February 2022, Treasury made payments of the remaining 60 percent of ERA 2 grantees’
award funds after they certified that at least 75 percent of the initial ERA 2 payment had
been obligated pursuant to 15 USC 9058c(c)(2). Beginning in February 2022, Treasury
altered its ERA 2 payment tranche policy to allow grantees to receive the remainder of
their ERA 2 award funds in two payments (half of the remaining balance, followed by the
remaining balance), subject to potential reductions resulting from the implementation of a
statutory reallocation requirement with each tranche payment only made after grantees
certified that they have obligated at least 75 percent of the funds already disbursed
pursuant to 15 USC 9058c(c)(2).
Additional information on statutory differences between ERA 1 and ERA 2 are described
in the Emergency Rental Assistance Frequently Asked Questions (FAQs) posted at:
https://home.treasury.gov/policy-issues/coronavirus/assistance-for-state-local-and-tribal-
governments/emergency-rental-assistance-program/faqs.
15 USC 9058a(b)(1)(A) directs Treasury to use US Census Bureau data for the most
recent year for which data is available for population calculations for determining the
populations of state and local governments. Funds are distributed via a per capita formula
allocation detailed on Treasury.gov that considers the minimum allocation of $200
million for states and the District of Columbia. Allocation amounts can be found via the
following link: https://home.treasury.gov/policy-issues/coronavirus/assistance-for-state-
local-and-tribal-governments/emergency-rental-assistance-program/allocations-and-
payments.
Source of Governing Requirements
Emergency Rental Assistance (“ERA 1”), Division N, Title V, Section 501 of the Consolidated
appropriations Act, 2021, Pub. L. No. 116-260 (December 27, 2020) and codified as 15 USC
9058a.
Emergency Rental Assistance (“ERA 2”), Title III, Subtitle B, Section 3201 of the American
Rescue Plan Act, 2021, Pub. L. No. 117-2 (March 11, 2021) codified as 15 USC 9058c.
Section 15011 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act (Pub. L.
No. 116-136), codified by 15 USC 9058a, as amended by Title VIII, Section 801(b) of
Compliance Supplement 2023 4-21.023-2
2023 Emergency Rental Assistance Program Treasury
the Consolidated Appropriations Act, 2021 (Pub. L. No. 116-260), codified at 15 USC 9058c, on
December 27, 2020.
Treasury’s Frequently Asked Questions (FAQs) and related guidance available on Treasury.gov,
including important version changes over time that can be found on the ERA website.
Availability of Other Program Information
1. General information for ERA is available on Treasury’s website at
www.treasury.gov/ERA. Information includes the following documents:
a. ERA 1 authorizing statute: https://www.govinfo.gov/content/pkg/PLAW-
116publ260/pdf/PLAW-116publ260.pdf (See pages 889 - 899)
This document details information that is contained in the authorizing
statute including funds appropriated for ERA 1.
b. ERA 2 authorizing statute: https://www.govinfo.gov/content/pkg/PLAW-
117publ2/pdf/PLAW-117publ2.pdf (See pages 52 - 56)
This document details information that is contained in the authorizing
statute including funds appropriated for ERA 2.
c. 15 USC 9058a(g)(1) regarding ERA 1 reporting:
https://www.govinfo.gov/content/pkg/PLAW-116publ136/pdf/PLAW-
116publ136.pdf (See pages 260 - 262)
This document provides information on grantee reporting the use of funds.
d. ERA 1 Award Terms template:
https://home.treasury.gov/system/files/136/Emergency-rental-assistance-
terms-FINAL.pdf (See pages 1 - 5)
This document provides award terms as a condition to the receipt of
payment from Treasury for ERA 1.
e. ERA 2 Award Terms template:
https://home.treasury.gov/system/files/136/ERA2_Grantee_Award_Terms_
572021.pdf (See pages 1 - 5)
This document provides award terms as a condition to the receipt of
payment from Treasury for ERA 2.
f. Treasury’s ERA Frequently Asked Questions (FAQs) and guidance are
available at: https://home.treasury.gov/system/files?file=136/ERA-FAQ-
7.27.22.pdf (See pages 1-18)
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2023 Emergency Rental Assistance Program Treasury
Treasury released FAQs as guidance regarding ERA 1 and ERA 2 except
where differences are specifically noted.
g. Treasury’s ERA 1 Reallocation guidance:
https://home.treasury.gov/system/files/136/UpdatedERA1ReallocationGui
danceSep6.pdf (See pages 1 - 8)
The ERA 1 statute requires Treasury to identify “excess funds” for
reallocation from amounts Grantees have “not obligated” from their initial
ERA 1 allocations.
h. Treasury’s ERA 2 Reallocation guidance:
https://home.treasury.gov/system/files/136/ERA2-Reallocation-Guidance-
March-30-2022.pdf (See pages 1 - 6)
The ERA 2 statute requires Treasury to identify funds for reallocation
from amounts allocated to eligible Grantees, but not yet paid out to them.
i. ERA Compliance and Reporting guidance:
https://home.treasury.gov/policy-issues/coronavirus/assistance-for-state-
local-and-tribal-governments/emergency-rental-assistance-
program/reporting (See web page)
Treasury instituted a webpage that provides information and guidance on
quarterly reporting and compliance.
j. Guidance from the Treasury Office of Inspector General (OIG) related to
the reporting of ERA fraud, waste, and abuse and any future monitoring of
funds requirements (where applicable): https://home.treasury.gov/policy-
issues/coronavirus/assistance-for-state-local-and-tribal-
governments/emergency-rental-assistance-program/fraud (See web page)
Treasury OIG provided guidance to grantees on what to do if they suspect
fraud, waste, and abuse.
a. ERA Promising Practices guidance: https://home.treasury.gov/policy-
issues/coronavirus/assistance-for-state-local-and-tribal-
governments/emergency-rental-assistance-program/promising-practices
(See web page)
2. Treasury has engaged with ERA grantees across the country to identify program
strategies that promise to speed up program implementation, more efficiently
deliver program benefits, enhance program integrity, and improve tenant and
landlord access to programs.
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2023 Emergency Rental Assistance Program Treasury
a. ERA Program and Service Design guidance:
https://home.treasury.gov/policy-issues/coronavirus/assistance-for-state-
local-and-tribal-governments/emergency-rental-assistance-
program/service-design (See web page)
Treasury provided guidance on consideration for good program design and
delivery.
III. COMPLIANCE REQUIREMENTS
In developing the audit procedures to test compliance with the requirements for this federal
program, the auditor must determine, from the following summary (also included in Part 2,
“Matrix of Compliance Requirements”), which of the 12 types of compliance requirements have
been identified as subject to the audit (noted with a “Y” in the summary matrix below), and then
determine which of the compliance requirements that are subject to the audit are likely to have a
direct and material effect on the federal program at the auditee. For each such compliance
requirement subject to the audit, the auditor must use Part 3 (which includes generic details about
each compliance requirement other than Special Tests and Provisions) and this program
supplement (which includes any program-specific requirements) to perform the audit. When a
compliance requirement is shown in the summary below as “N,” it has been identified as not
being subject to the audit. Auditors are not expected to test requirements that have been noted
with an “N.” See the Safe Harbor Status discussion in Part 1 for additional information.
A B C E F G H I J L M N
Matching, Procurement and
Equipment and
Cash
Period
Activities Allowable
Level of Effort, Suspension and Subrecipient Special
Real Property
Eligibility Reporting
Allowed or Costs/Cost Of Program Tests and
Unallowed Principles Management Management Earmarking Performance Debarment Income Monitoring Provisions
Y Y N Y N N Y N N Y Y Y
A. Activities Allowed or Unallowed
1. Activities Allowed
a. ERA 1 and ERA 2 funds may be used for administrative expenses,
housing stability services, and financial assistance on behalf of an eligible
household, as defined in the Treasury guidance. In the case of ERA 2,
after October 2022, grantees that have obligated 75 percent of their
allocations may choose to use up to 25 percent of their allocation for,
“other affordable rental housing and eviction prevention purposes, as
defined by the Secretary, serving very low-income families.” Treasury
released guidance for these additional uses as FAQ 46 in July 2022.
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2023 Emergency Rental Assistance Program Treasury
Where applicable, the final ERA 1 payment amount distributed by
Treasury to the ERA 1 grantee through an ERA 1 “redirect” and/or
“reallocation” process, pursuant to Treasury’s Reallocation Guidance, is
described on Treasury.gov. If a grantee receives redirected or reallocated
funds, the funds are subject to the same requirements under the ERA 1
Award Terms previously accepted by the grantee in connection with their
ERA 1 award with the addition that grantees receiving reallocated ERA 1
funds may request from Treasury an extension of their final obligation
date from September 30, 2022, to December 29, 2022. Please see the ERA
page at Treasury.gov and ERA FAQs for the latest guidance regarding
eligible uses under ERA 1 and ERA 2. (See FAQs 1, 4-7, 16-20, 26-28, 35
and 39-42)
b. Administrative Expenses: The revised Award Terms for ERA 1 and ERA
2 awards issued by Treasury permits ERA grantees to use award funds
provided to cover both direct and indirect administrative costs. The cost of
a grantee contacting a landlord to encourage their participation and
acceptance of ERA assistance is one of many examples of an eligible
administrative cost. Under ERA 1, a grantee may use up to 10 percent of
the total award amount for direct and indirect administrative costs and
may use up to 10 percent of the total award amount for housing stability
services. Under ERA 2, a grantee may use up to 15 percent of the total
award amount for direct and indirect administrative costs and may use up
to 10 percent of the total award amount for housing stability services as
described below (See also FAQ 29).
c. Housing Stability Services: Under ERA 1, housing stability services
includes case management and other services related to the COVID-19
outbreak intended to help keep households stably housed. Under ERA 2,
housing stability services do not have to be related to the COVID-19
outbreak. For ERA 1 and ERA 2, housing stability services include those
that enable households to maintain or obtain housing. Such services may
include, among other things, eviction prevention and eviction diversion
programs; mediation between landlords and tenants; housing counseling;
fair housing counseling; housing navigators or promotors that help
households access programs or find housing; case management related to
housing stability; housing-related services for survivors of domestic abuse
or human trafficking; legal services or attorney’s fees related to eviction
proceedings and maintaining housing stability; and specialized services for
individuals with disabilities or seniors that support their ability to access
or maintain housing (See FAQ 23).
d. Financial Assistance: Financial assistance to households includes payment
of rent, rental arrears, utilities and home energy costs, utility and home
energy costs arrears, and other expenses related to housing pursuant to 15
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2023 Emergency Rental Assistance Program Treasury
USC 9058a(c)(2)(A). Please note that under the ERA 1 program, award
funds used for “other expenses” must be related to housing and “incurred
due, directly or indirectly, to the novel coronavirus disease (COVID-19)
outbreak” (See 15 USC 9058a(c)(2)(A)(v). However, the ERA 2 statute
requires that “other expenses” be “related to housing” but does not require
that they be incurred due to the COVID-19 outbreak (See 15 USC
9058a(d)(1)(A)(V)). The amount of financial assistance for prospective
rent cannot exceed three months under a single household application (See
FAQ 10). There is no maximum dollar amount for the cumulative
financial assistance that may be provided on behalf of an eligible
household beyond the requirements set forth in the ERA FAQs. These
requirements include that amounts paid be based on documentation of
household income, leases, and equivalent forms (or for applicants unable
to present adequate documentation, a written attestation from the applicant
up to a monthly maximum of 100 percent of the greater of the Fair Market
Rent or the Small Area Fair Market Rent for the area in which the
applicant resides) and that the amount of assistance provided to any
household under ERA 1 and ERA 2, including assistance provided by
other ERA 1 and ERA 2 grantees cannot exceed 18 months (See FAQ 10).
Financial assistance arrears may only cover household expenses accrued
on or after March 13, 2020, up to a maximum of 15 months for ERA 1 and
a maximum of 18 months, under ERA 1 and ERA 2 combined. For
prospective rent assistance greater than three months up to the statutory
maximum of 18 months under ERA 1 and ERA 2, the household must
apply to the program again and the grantee must have sufficient funds.
Households may receive up to 12 months of assistance under ERA 1 and
an additional three months if necessary to ensure housing stability for the
household for a total of three months. This means that for ERA 1, the
maximum rental arrears monthly coverage period, where applicable, is 15
months where necessary for housing stability and households may only
receive up to three months of prospective rent, where applicable and
qualifying (See FAQ 10).
Examples of other costs for both ERA 1 and ERA 2 include relocation
expenses (including prospective relocation expenses), rental security
deposits, rental fees including application and screening fees, reasonable
accrued late fees, Internet service to a given rental unit, and rental bonds
where necessary to avoid an eviction order, as provided in the Treasury
guidance and subject to certain conditions (for example, that Internet
service expenses are eligible only if grantees establish policies governing
the appropriate of use for this purpose).
e. Other Affordable Rental Housing and Eviction Prevention Purposes:
Treasury released FAQ 46 on July 2022 to define these uses.
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2023 Emergency Rental Assistance Program Treasury
B. Allowable Costs / Cost Principles
The cost principles in 2 CFR Part 200, Subpart E (Cost Principles) except the 2 CFR
200.418 and 2 CFR 200.419 apply to ERA 1 and ERA 2. Under ERA 1, a grantee may
use up to 10 percent of the total award amount for direct and indirect administrative costs.
Under ERA 2, a grantee may use up to 15 percent of the total award amount for direct
and indirect administrative costs (See FAQ 29).
E. Eligibility
1. Eligibility for Individuals
To ensure eligibility requirements are met, household eligibility should be tested
to focus on whether grantees established and adhered to reasonable policies for
evaluating household applications within Treasury’s framework providing for the
use of self-attestation, categorical eligibility, and fact-specific proxies in
qualifying circumstances. Specific eligibility requirement can be found in FAQ 1
at https://home.treasury.gov/system/files?file=136/ERA-FAQ-7.27.22.pdf.
This approach to eligibility was implemented in accordance with 15 USC 9058a,
for ERA 1 in 15 USC 9058a(c)(2)(C)(ii) concerning documentation of payments
to households, 15 USC 9058a(f)(2)(A) and (B) of the Act concerning signature
requirements for applications and documentation required for tenants, 15 USC
9058a (k)(1) concerning area median income determinations, and 15 USC 9058a
(k)(3)(A)(I) and (II) concerning eligible household determinations and attestation
requirements. This treatment is further explained in the ERA FAQs; 15 USC
9058a; and the Treasury, Department of Justice and Department of Housing and
Urban Development joint letter issued August 27, 2021
(https://home.treasury.gov/system/files/136/Eviction-Moratorium-Joint-
Letter.pdf).
To the extent that a grantee has established and consistently followed its own
reasonable procedures for implementing an eligibility determination process,
consistent with Treasury’s guidance, it is not Treasury’s expectation that grantees
should seek additional documentation from a beneficiary after the initial
determination of eligibility has been completed, including for those determined to
be eligible using self-attestation, categorical eligibility, or fact-specific proxies in
qualifying circumstances. Testing of individual household eligibility-related
documentation should be limited to material already collected by the grantee
during application as much as possible to avoid imposing undue burden on
households that remain at risk of housing instability.
Treasury guidance related to determining where an applicant lives and the amount
that they owe can be found in FAQ 5
https://home.treasury.gov/system/files?file=136/ERA-FAQ-7.27.22.pdf. Grantees
must obtain, if available, a current lease, signed by the applicant and the landlord
Compliance Supplement 2023 4-21.023-8
2023 Emergency Rental Assistance Program Treasury
or sublessor, that identifies the unit where the applicant resides and establishes the
rental payment amount. If a household does not have a signed lease,
documentation of residence may include evidence of paying utilities for the
residential unit, an attestation by a landlord who can be identified as the verified
owner or management agent of the unit, or other reasonable documentation as
determined by the grantee. In the absence of a signed lease, evidence of the
amount of a rental payment may include bank statements, check stubs, or other
documentation that reasonably establishes a pattern of paying rent, a written
attestation by a landlord who can be verified as the legitimate owner or
management agent of the unit, or other reasonable documentation as defined by
the grantee in its policies and procedures.
Additional Treasury guidance related to income determination can be found in
FAQ 4 and related guidance (
https://home.treasury.gov/system/files?file=136/ERA-FAQ-7.27.22.pdf). ERA 2
builds on the eligibility criteria in ERA 1 and permits additional flexibilities.
The ERA FAQs document the full eligibility considerations for grantees to extend
emergency assistance to vulnerable populations without imposing undue
documentation burdens. As described, given the challenges presented by the
COVID-19 pandemic, grantees may be flexible as to the particular form of
documentation they require, including by permitting photocopies or digital
photographs of documents, e-mails, or attestations from employers, landlords,
caseworkers, or others with knowledge of the household’s circumstances.
Grantees must require all applications for assistance to include an attestation from
the applicant household that all information included is correct and complete. In
all cases, grantees must document their policies and procedures for determining
household eligibility to include policies and procedures for determining the
prioritization of households in compliance with the statute and maintain records
of their determinations.
Grantees may rely on a written attestation without further documentation of
household income from the applicant under three approaches:
a. Self-attestation Alone – In order to provide assistance rapidly during the
public health emergency related to COVID-19, the grantee may rely on a
self-attestation of household income, financial hardship, and/or risk of
homelessness and housing instability without further verification if the
applicant confirms in their application or other document that they are
unable to provide documentation, provided the other requirements detailed
in Treasury guidance are satisfied. If an applicant is able to provide
satisfactory evidence of residence but is unable to present adequate
documentation of the amount of the rental obligation, grantees may accept
a written attestation from the applicant to support the payment of
assistance up to a monthly maximum of 100 percent of the greater of the
Fair Market Rent or the Small Area Fair Market Rent for the area in which
Compliance Supplement 2023 4-21.023-9
2023 Emergency Rental Assistance Program Treasury
the applicant resides, as most recently determined by HUD and made
available at https://www.huduser.gov/portal/datasets/fmr.html;
b. Categorical Eligibility – If an applicant household income has been
verified to be at or below 80 percent of the area median income (for ERA
1) or if an applicant household has been verified as a low-income family
as defined in Section 3(b) of the United States Housing Act of 1937 (42
USC 1437a(b)) (for ERA 2) in connection with another local, state, or
federal government assistance program, grantees are permitted to rely on a
determination letter from the government agency that verified the
applicant’s household income or status as a low-income family, provided
that the determination for such program was made on or after January 1,
2020; and/or
c. Fact-specific proxy – A grantee may rely on a written attestation from the
applicant household as to household income if the grantee also uses any
reasonable fact-specific proxy for household income, such as reliance on
data regarding average incomes in the household’s geographic area.
Grantees also have discretion to provide waivers or exceptions to this
documentation requirement to accommodate disabilities, extenuating
circumstances related to the pandemic, or a lack of technological access.
In these cases, the grantee is still responsible for making the required
determination regarding the applicant’s household income and
documenting that determination.
Grantees have discretion to provide waivers or exceptions to certain
documentation requirements to accommodate disabilities, extenuating
circumstances related to the pandemic, or a lack of technological access. In these
cases, the grantee is still responsible for making the required determination
regarding the applicant’s household income and documenting that determination.
Pursuant to 15 USC 9058a(k)(3)(B), and 2 CFR 200.403, when providing ERA 1
assistance, the grantee must review the household’s income and sources of
assistance to confirm that the ERA 1 assistance does not duplicate any other
assistance, including federal, state, or local assistance provided for the same costs.
Grantees may rely on an attestation from the applicant regarding non-duplication
with other government assistance, and the duplication requirement does not apply
to ERA 2; however, to maximize program efficacy, Treasury encourages grantees
to minimize the provision of duplicative assistance.
Treasury strongly encourages grantees to rely on the self-certification of
applicants with regard to whether their financial hardship meet statutory eligibility
requirements. Similarly, with respect to determining whether one or more
individuals within the household can demonstrate a risk of experiencing
homelessness or housing instability, Treasury indicates that a grantee may rely on
a past due utility or rent notice or eviction notice, evidence of unsafe or unhealthy
living conditions (which may include overcrowding) or any other evidence of
Compliance Supplement 2023 4-21.023-10
2023 Emergency Rental Assistance Program Treasury
risk, as determined by the grantee. Treasury clearly indicates that a grantee may
rely on an applicant’s self-certification identifying the applicable risk factor or
factors, without further documentation, if other documentation is not immediately
available.
After October 2022, grantees that have obligated 75 percent of their allocations
may choose to use up to 25 percent of their allocation for, “other affordable rental
housing and eviction prevention purposes, as defined by the Secretary, serving
very low-income families.” Treasury released guidance for these additional uses
as FAQ 46 in July 2022 -
Seehttps://home.treasury.gov/system/files?file=136/ERA-FAQ-7.27.22.pdf. In
summary, eviction prevention purposes are those previously defined as housing
stability uses. For affordable housing, the eligible uses include operation or
development of affordable housing that utilizes another federal grant program for
affordable housing development and has a 20 year affordability covenant.
2. Eligibility for Groups of Individuals or Area of Service Delivery
Not Applicable
3. Eligibility for Subrecipients
Not Applicable
H. Period of Performance
Under 15 USC 9058a(e)(1), the period of performance for ERA 1 awards began on the date that
the grantee executed the ERA 1 Award Terms and ended on December 31, 2021. 15 USC
9058a(h) extended the award period of performance from December 31, 2021, to September 30,
2022. Pursuant to 15 USC 9058a(e)(2), Treasury extended the award period of performance to
end on December 29, 2022 for ERA 1 grantees that receive reallocated funds.
Under 15 USC 9058c(g), the period of performance for ERA 2 awards begins on the date that
Treasury and the grantee executed the ERA 2 Award Terms and ends on September 30, 2025.
All award funds not obligated or expended by the end of the period of performance date for ERA
1 and ERA 2 awards must be returned to Treasury as part of the award closeout process pursuant
to 2 CFR 200.344(d), including amounts distributed through redirection and reallocation. See
also the ERA 1 Closeout Resource at
https://home.treasury.gov/system/files/136/ERACloseoutResource_Final_9.16.22.pdf.
L. Reporting
1. Financial Reporting
a. SF-270, Request for Advance or Reimbursement – Not Applicable
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2023 Emergency Rental Assistance Program Treasury
b. SF-271, Outlay Report and Request for Reimbursement for Construction
Programs – Not Applicable
c. SF-425, Federal Financial Report – Applicable
2. Performance Reporting
Title of Report: ERA Compliance Report
PRA Number: 1505-0266 (ERA 1) and 1505-0270 (ERA 2)
Reporting Cycle: Quarterly
Authoritative Requirement: 15 USC 9058c; 2 CFR 200.328 (Financial report);
and 2 CFR 200.329 (Performance report)
Blank Copy of the Report: https://home.treasury.gov/system/files/136/ERA-
Treasury-Portal-User-Guide-v2.pdf (see figures 3-7 for screenshots of user guide)
Report Instructions: https://home.treasury.gov/policy-
issues/coronavirus/assistance-for-state-local-and-tribal-governments/emergency-
rental-assistance-program/reporting
Report Corrections: The Office of Recovery Program’s (ORP) reporting portal
has built-in functionality to reopen a report and allow recipients to make edits
after the reporting deadline. However, it is ORP’s policy that recipients may only
make revisions if authorized by Treasury staff for a period of up to 60 days after
the reporting deadline. After the revision period ends, the report is final. A
resubmitted report becomes a recipient’s final report within ORP’s reporting
portal. Recipients can generate PDFs of these reports at any time.
Key Line Items-
1. Administrative Costs Ratio- Quantifiable Objective Criteria: Total
obligations and/or expenditures for administrative costs does not exceed
the relevant threshold of total allocation (10% across the prime and all
subrecipients for ERA 1, not to exceed 15% for ERA 2 across the prime
and all subrecipients)
(See ERA Reporting Guidance, Appendix 7, Applicable Limitations on
Administrative Expenses, page 52)
2. Housing Stability Services Ratio- Quantifiable Objective Criteria: Total
obligations and/or expenditures for housing stability services is not greater
than 10% of the total amount allocated (See ERA Reporting Guidance,
Appendix 7, Applicable Limitations on Administrative Expenses, page
52). Examples of these services can be found as item 23 on ages 12 and
13 of the July 27, 2022 FAQs located at
https://home.treasury.gov/system/files?file=136/ERA-FAQ-7.27.22.pdf.
3. System for Prioritizing Assistance- Quantifiable Objective Criteria: The
number of households with less than 50% Area Median Income (AMI)
receiving financial assistance is greater than the number of households
Compliance Supplement 2023 4-21.023-12
2023 Emergency Rental Assistance Program Treasury
with greater than 50% AMI receiving assistance (See ERA Reporting
Guidance, Section E, Number of Unique Participant Households at Certain
Income Levels, page 27)
4. Participant Households at Certain Income Levels Eligibility- Quantifiable
Objective Criteria: The total households receiving assistance is not greater
than the sum of Area Median Income (AMI) banded eligible households
with a 5 to 10% margin of error to avoid false positives for medium to
large recipients. Treasury is aware of some limited temporary income data
availability and reporting lag due to waterfall distribution models required
within the statutory design framework and related administrative
processing delays, as well as the use of fact-based proxies or assistance
based on participation in other programs. Does not apply to tribal
recipients exempt from income reporting according to Treasury guidance
and policy (See ERA Reporting Guidance, Section E, Number of Unique
Participant Households at Certain Income Levels, page 27)
3. Special Reporting
Not applicable
4. Special Reporting for Federal Funding Accountability and Transparency Act
Although reporting on subaward information is applicable to ERA grantees
pursuant to the award term set forth in Appendix A to 2 CFR Part 170, which is
incorporated by reference in the ERA 1 and ERA 2 Award Terms, ERA grantees’
compliance with these reporting requirements is not subject to audit.
M. Subrecipient Monitoring
See Part 3, Section M, “Subrecipient Monitoring” for a general description of the
compliance requirements, the related audit objectives, and suggested audit procedures.
N. Special Tests and Provisions
1. ERA 1 Funds Redirection
Compliance Requirements
Pursuant to 15 USC 9058a(b)(1)(A) and Treasury’s implementing instructions to
requesting grantees, grantees are permitted to redirect ERA 1 funds when a locality
receives an ERA 1 award and subsequently transfers 100 percent of the ERA 1 award
funds received from Treasury to its eligible state and Treasury approves the transaction.
The redirection of award funds is finalized when the locality has submitted the relevant
redirection documentation to Treasury and Treasury has provided confirmation of
acceptance. At that time, the locality’s ERA 1 award is cancelled, and the locality has no
further legal obligation to Treasury under the ERA 1 award.
Compliance Supplement 2023 4-21.023-13
2023 Emergency Rental Assistance Program Treasury
Audit Objectives
The state’s ERA 1 award is modified by the amount of the funds transferred from the
local government to the state and the state is responsible as the grantee for reporting on
the use of the transferred award funds that become subject to the requirements set forth in
the Award Terms previously accepted by the state in connection with its ERA 1 award. A
local government that has redirected 100 percent of its ERA 1 award funds to its state but
has not submitted the relevant redirection documentation to Treasury or is still awaiting
confirmation of acceptance of submitted documentation by Treasury, is still responsible
for complying with the ERA 1 Award Terms, including submitting Monthly and
Quarterly reports until their redirection forms were submitted and accepted by Treasury.
Suggested Audit Procedures
(1) All voluntarily redirected ERA 1 award funds were approved by the
grantee’s authorizing official in accordance with Treasury guidance;
(2) All redirected ERA 1 award funds were deposited to the official,
authorized bank account of the receiving grantee, as approved by
Treasury; and
(3) All ERA 1 award funds received through the redirection process are used
in accordance with the ERA 1 Award Terms.
2. ERA Funds Reallocation
Compliance Requirements
Pursuant to 15 USC 9058a(d), Treasury is required to reallocate “excess” ERA 1 award
funds. Treasury’s objective in reallocations is to ensure ERA 1 award funds remain
available to grantees in accordance with their jurisdictional needs and demonstrated
capacity to deliver assistance while the ERA appropriations remain available. Treasury’s
ERA 1 reallocation guidance on Treasury.gov and previewed here describes how grantees
that have expenditure ratios below designated thresholds as of September 30, 2021, were
subject to involuntary recapture, in the absence of mitigating actions, requiring the
grantee to return funds to Treasury within the provided timeframes. Treasury continues to
periodically assess expenditures using escalating expenditure benchmarks to identify
excess funds. For the first assessment using data as of September 30, 2021, grantees
could mitigate the impact of recapture by submitting a certification that the grantee’s
financial assistance activity had since increased to a level beyond the minimum threshold,
committing to a voluntary reallocation, or by providing a Performance Improvement
Plan. Treasury’s reallocation guidance on Treasury.gov will continue to detail specific
ERA reallocation timelines. The guidance also describes the voluntary reallocation
process through which a grantee may request that Treasury reallocate its ERA 1 award
funds to other ERA 1 grantees in the same state. Treasury is not recapturing funds from
Compliance Supplement 2023 4-21.023-14
2023 Emergency Rental Assistance Program Treasury
Indian Tribes or Tribally Designated Housing Entities (TDHEs) prior to the end of the
second quarter of 2022, except where a Tribal grantee, its TDHE, or housing authority
voluntarily return funds to Treasury. Auditors should refer to the ERA 1 reallocation
guidance at www.treasury.gov/era. Guidance for ERA 2 reallocation can also be found on
this site.
Updated information regarding ERA 2 reallocation was posted as an update to
Reallocation Guidance in March 2022.
Audit Objectives
The reallocation expenditure ratio determines whether the grantee is subject to
involuntary reallocation due to an insufficient ratio and the amount of excess funds
subject to recapture by Treasury. Auditors should confirm the amounts reported as
expended and obligated accurately capture the grantee’s housing activity at the time of
submission, as reflected in a grantee’s award and/or financial systems, and that grantees
receiving reallocated funds met the Treasury criteria.
Suggested Audit Procedures
a. Confirm that financial information certified by grantees used by Treasury to make
reallocation determinations is accurate and that excess funds that are subject to
involuntary recapture are returned to Treasury in accordance with Treasury’s
confirmation letter.
b. Financial information certified as part of reallocation includes monthly
expenditure and cumulative obligations levels, as described in the Treasury
reallocation guidance.
c. ERA 1 expenditures reported monthly by the grantee are inputs to Treasury’s
reallocation expenditure ratio.
d. ERA 1 obligations certified in the Request for Reallocated Funds form (1505-
0266), including in the Request for Voluntarily Reallocated Funds, are inputs into
determining eligibility to receive reallocated funds.
e. ERA 2 expenditures and obligations reported in quarterly reports by the grantee
are inputs to Treasury’s ERA 2 reallocation expenditure and obligation ratios.
Compliance Supplement 2023 4-21.023-15
May 2023 Federal Agency Single Audit, Key Management Liaison, and Program Contacts
APPENDIX III
FEDERAL AGENCY SINGLE AUDIT, KEY MANAGEMENT LIAISON, AND
PROGRAM CONTACTS
This appendix provides federal agency single audit contacts (starts on page 8-III-2), key
management liaisons (starts on page 8-III-10), and program contacts (starts on page 8-III-11) for
each program/cluster included in the Supplement. For the single audit contacts a table is provided
for each federal agency identifying who can answer technical audit questions. The table includes
contact information and the geographical area each federal contact is responsible for overseeing.
A list of key management liaisons, who are the contacts for questions related to the administrative
requirements applicable to an agency program(s), and their e-mail addresses follows the single
audit contact information. Last, program contacts, who can answer programmatic questions, and
their contact information, are listed by agency and Assistance Listing number.
Agency Page
United States Department of Agriculture 8-3-2
Department of Commerce 8-3-2
Department of Defense 8-3-2
Department of Education 8-3-2
Department of Energy 8-3-3
Department of Health and Human Services 8-3-3
Department of Homeland Security 8-3-3
Department of Housing and Urban Development 8-3-3
Department of the Interior 8-3-4
Department of Justice 8-3-4
Department of Labor 8-3-4
Department of State 8-3-4
Department of Transportation 8-3-5
Department of the Treasury 8-3-5
Department of Veterans Affairs 8-3-5
Agency for International Development 8-3-5
Appalachian Regional Commission 8-3-6
Corporation for National and Community Service 8-3-6
Environmental Protection Agency 8-3-6
Federal Communications Commission 8-3-6
General Services Administration 8-3-7
Gulf Coast Ecosystem Restoration Council 8-3-7
National Aeronautics and Space Administration 8-3-7
National Archives and Records Administration 8-3-7
National Endowment for the Arts 8-3-8
National Endowment for the Humanities 8-3-8
National Science Foundation 8-3-8
Nuclear Regulatory Commission 8-3-8
Social Security Administration 8-3-8
Tennessee Valley Authority 8-3-9
US Small Business Administration 8-3-9
Federal Agency Key Management Liaisons 8-3-10
Federal Agency Program Contacts 8-3-11
Compliance Supplement 2023 8-III-1 Appendix III
May 2023 Federal Agency Single Audit, Key Management Liaison, and Program Contacts
Federal Agency Single Audit Contacts
Agency Type of Audit
Department of Transportation
US Department of Transportation
Office of Inspector General
Attn: National Single Audit Coordinator
101 W. Lombard Street, Suite 2516
Baltimore, MD 21201
Phone: Voice (443) 825-1510
Additional Contact: Matthew Straw
singleauditrequest@oig.dot.gov
Department of the Treasury
Department of the Treasury All audits
Office of Inspector General
Deputy Assistant Inspector General for Audit
875 15th Street NW, Suite 300
Washington, DC 20050
Phone: Voice 202-927-5784
Fax: 202-927-5379
Department of Veterans Affairs
Director All audits
Office of Inspector General
Financial Statement Audit Division (52CF)
Department of Veterans Affairs
810 Vermont Ave. NW
Washington, DC 20420
Phone: Voice 202-565-7013
Fax: 202-565-7771
Agency for International Development
USAID For audits of all US based
Attn: OIG/A/FA not-for-profit organizations
Room 8.10-10
1300 Pennsylvania Avenue, NW
Washington, DC 20523-7802
Phone: Voice 202-712-4902
Fax: 202-216-3598
E-Mail: faudit@usaid.gov
Web site:
U.S. Agency for International Development (usaid.gov)
Compliance Supplement 2023 8-III-5 Appendix III
May 2023 Federal Agency Single Audit, Key Management Liaison, and Program Contacts
Federal Agency Key
Agency Name E-Mail Address
Department of Agriculture Samantha Coles Samantha.cole@usda.gov
Seanne Weekes Seanne.weekes@usda.gov
Department of Commerce John P. Geisen JGeisen@doc.gov
Department of Defense Jason Day jason.o.day.civ@mail.mil
Department of Education Lihong Guo Lihong.Guo@ed.gov
Department of Energy Joel Gonzalez Joel.Gonzalez@hq.doe.gov
Department of Health and Human Robin Aldridge Robin.Aldridge@hhs.gov
Services Leticia Adu Leticia.Adu@hhs.gov
Department of Homeland Security Michael Pellegrino Michael.Pellegrino@HQ.DHS.GOV
Department of Housing and Urban Shannon E. Steinbauer Shannon.E.Steinbauer@hud.gov
Development
Department of the Interior Eunice Pierre eunice_pierre@ios.doi.gov
Department of Justice Linda Taylor Linda.Taylor2@usdoj.gov
Jeff A. Haley Jeff.Haley@usdoj.gov
Department of Labor Anita Robinson Robinson.Anita@dol.gov
Latonya Torrence Torrence.Latonya@dol.gov
Department of State Thomas Kodiak Kodiakt@state.gov
Department of the Treasury Siporah Jackson Siporah.Jackson@treasury.gov
Department of Transportation Willie Smith willie.smith@dot.gov
Department of Veterans Affairs Kevin Cone Kevin.Cone@va.gov
Corporation for National and Edris Shah eshah@cns.gov
Community Service
Denali Commission Beth Flowers bflowers@denali.gov
Environmental Protection Agency Kysha Holliday Holliday.Kysha@epa.gov
Federal Communications Commission Sheela Kailasanath Sheela.Kailasanath@fcc.gov
Gulf Coast Ecosystem Restoration Steve Sigler Steve.sigler@restorethegulf.gov
Council
Institute for Museum and Library Connie Cox Bodner CBodner@imls.gov
Services
National Aeronautics and Space Antanese Crank antanese.n.crank@nasa.gov
Administration
National Archives and Records Christopher Eck Christopher.Eck@nara.gov
Administration
National Endowment for the Arts Breanna Berger bergerb@arts.gov
National Endowment for the Laura Davis ldavis@neh.gov
Humanities
National Science Foundation Rochelle D. Ray rray@nsf.gov
Office of National Drug Control Policy Lisa Newton Lisa_E_Newton@ondcp.eop.gov
Social Security Administration Trae Sommer Audit.Correspondence@ssa.gov
DCO.AUDIT@ssa.gov
DCO.ODD.AUDIT@ssa.gov
OIG.audit.kansascity@ssa.gov
Frank.Biro@ssa.gov
US Agency for International David McNeil dmcneil@usaid.gov
Development
US Small Business Administration Kimberly Butler Kimberly.Butler@sba.gov
Compliance Supplement 2023 8-III-10 Appendix III
May 2023 Federal Agency Single Audit, Key Management Liaison, and Program Contacts
Federal Agency Program
Contacts
Assistance Agency Contact(s) E-Mail Address Telephone
Listing Number
Maritime Administration
(MARAD)
John Desch John.Desch@dot.gov
Senior Contract Specialist, 202-366-4356
(MARAD)
21 Department of the Treasury
(TREAS)
21.015 Troyling Harris troyling.harris@treasury.gov 202-927-8096
21.020 Chief Compliance Officer
21.016 Siporah Jackson Siporah.Jackson@treasury.gov 202-374-1813
21.019 Nasr Fahmy, Single Audit Nasr.Fahmy@treasury.gov (202) 527-4036
Advisor
21.023 Nasr Fahmy, Single Audit Nasr.Fahmy@treasury.gov (202) 527-4036
Advisor
21.026 Nasr Fahmy, Single Audit Nasr.Fahmy@treasury.gov (202) 527-4036
Advisor
21.027 Nasr Fahmy, Single Audit Nasr.Fahmy@treasury.gov (202) 527-4036
Advisor
21.029 Nasr Fahmy, Single Audit Nasr.Fahmy@treasury.gov (202) 527-4036
Advisor
21.032 Nasr Fahmy, Single Audit Nasr.Fahmy@treasury.gov (202) 527-4036
Advisor
32 Federal Communications
Commission
32.006 Sheela Kailasanath Sheela.Kailasanath@fcc.gov 202-418-0938
32.009
45 National Endowment for the
Humanities (NEH)
45.129 Karen Kenton kkenton@neh.gov 202-606-8307
Director
Compliance Supplement 2023 8-III-19 Appendix III
May 2023 Internal Reference Tables
APPENDIX IV
INTERNAL REFERENCE TABLES
INTRODUCTION
This Appendix includes a listing of programs with a “higher risk” designation and describes how
that designation impacts the major program determination process. It also includes a list of
programs in Part 4, which have requirements defined in IV, Other Information.
PROGRAMS WITH “HIGHER RISK” DESIGNATION
Uniform Guidance section 200.519(c)(2) states that “Federal agencies, with the concurrence of
OMB, may identify Federal programs that are higher risk. It also states that OMB will provide
this identification in the Compliance Supplement.”
As a result of the COVID-19 pandemic, many new federal programs were established and
funding was added to existing federal programs from the following Acts:
• Coronavirus Preparedness and Response Supplemental Appropriations Act
• Families First Coronavirus Response Act
• Coronavirus Aid, Relief, and Economic Security Act (CARES Act)
• Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA)
• American Rescue Plan Act (ARP)
Funding arising from these sources is referred to as “COVID-19 funding,” or “COVID-19
programs”.
On November 15, 2021, the Infrastructure Investment and Jobs Act (IIJA) was signed into law.
It established new programs and provided additional funding for existing programs. Funding
arising from the IIJA is referred to as “IIJA funding” or “IIJA program”. The 2023 higher risk
list includes one program that includes IIJA funding.
The following table includes a complete list of programs that have been identified as “higher
risk” for audits subject to the 2023 Compliance Supplement either because of COVID-19
funding, IIJA funding, or because a Federal agency has identified the program to be higher risk.
Agency Assistance Listing (CFDA) Title
Number
Education* 84.425 Education Stabilization Fund
HHS* 93.498 Provider Relief Fund and American Rescue
Plan (ARP) Rural Distribution
HHS** 93.778/93.777/93.775 Medicaid Cluster
Treasury* 21.023 Emergency Rental Assistance
Compliance Supplement 2023 8-IV-1 Appendix IV
May 2023 Internal Reference Tables
Treasury* 21.026 Homeowner Assistance Fund
Treasury* 21.027 Coronavirus State and Local Fiscal
Recovery Funds
Treasury* 21.029 Coronavirus Capital Projects Fund
Interior ** 15.252 Abandoned Mine Land Reclamation
(AMLR)
Social Security 96.001/96.006 Disability Insurance/Supplemental Security
Income
Note:
* These programs were created by one of the laws cited at the beginning of this section and are
thus considered 100% COVID-19 funding.
** These programs were existing programs that received additional COVID-19 funding from one
or more of the laws cited at the beginning of this section or IIJA funding.
Impact of “Higher Risk” Status on Major Program Determination
Type A Program Considerations
A “higher risk” designation will often result in a Type A program or other cluster being audited
as a major program. However, an auditor is not precluded from determining that a “higher risk”
Type A program or other cluster qualifies as a low risk Type A program if both of the following
criteria are met:
1. the program otherwise meets the criteria for a low risk Type A program in section
200.518 of the Uniform Guidance; and
2. the percentage of COVID-19 funding or IIJA funding in the program or other cluster
during the non-federal entity’s fiscal year is not material to the program or other cluster
as a whole. For example, a recipient’s schedule of expenditures of federal awards may
include the Medicaid Cluster but the expenditures relevant to COVID-19 funding
included in the program during the June 30, 2023, fiscal year end is not material.
Alternatively, a recipient’s schedule of expenditures of federal awards may include
Education Stabilization Fund expenditures for the June 30, 2023, fiscal year end, which
would be considered material because COVID-19 funding comprises the entire program.
Note that the inclusion of COVID-19 funding or IIJA funding within the Research &
Development (R&D) cluster does not create a “higher risk” designation for the R&D cluster.
Auditors should prepare audit documentation supporting the risk considerations and conclusions
for “higher risk” programs.
Type B Program Considerations
Under section 200.518 of the Uniform Guidance, in certain circumstances the auditor must
identify Type B programs that are high risk using professional judgment and the criteria in
section 200.519 of the Uniform Guidance, which includes consideration of whether a program
has been identified as “higher risk” by a Federal agency with the concurrence of OMB. Thus,
Compliance Supplement 2023 8-IV-2 Appendix IV
May 2023 Internal Reference Tables
there are no changes to the normal risk assessment process for Type B programs identified as
“higher risk.” That is, the “higher risk” identification must be considered with the other factors in
section 200.519.
Further, the auditor is not required to prioritize the assessment of risk for “higher risk” Type B
programs over other Type B programs.
PROGRAMS WITH “OTHER INFORMATION” IN PART 4
The following is a list of programs in Part 4 that have requirements defined in IV, “Other
Information.” Other Information sections are included to communicate additional information
concerning the program. For example, when a program allows funds to be transferred to another
program, the “Other Information” section provides guidance on how those funds are to be treated
on the Schedule of Expenditures of Federal Awards and in major program determinations. Note
that if the listing is a cluster, all program numbers are shown, but only the primary program
name is presented.
10.551/10.561 Supplemental Nutrition Assistance Program (SNAP)
10.553/10.555/10.556/10.559 School Breakfast Program (SBP)
10.557 Special Supplemental Nutrition Program for Women, Infants,
and Children (WIC)
10.558 Child and Adult Care Food Program (CACFP)
10.760 Water and Waste Disposal Systems for Rural Communities
10.766/10.780 Community Facilities Loans and Grants
11.300/11.307 Investments for Public Works and Economic Development
14.157 Supportive Housing for the Elderly (Section 202)
14.181 Supportive Housing for Persons with Disabilities (Section 811)
14.218/14.225 Community Development Block Grants/Entitlement Grants and
Non-Entitlement Counties in Hawaii
14.228 Community Development Block Grants/State’s Program and
Non-Entitlement Grants in Hawaii
14.239 Home Investment Partnerships Program
14.256 Neighborhood Stabilization Program (Recovery Act Funded)
14.850 Public and Indian Housing
14.862 Indian Community Development Block Grant Program
14.867 Indian Housing Block Grants
14.871/14.879 Section 8 Housing Choice Vouchers
14.872 Public Housing Capital Fund (CFP)
14.873 Native Hawaiian Housing Block Grant
14.881 Moving to Work Demonstration Program
14.888 Lead-based Paint Capital Fund Program and Housing-Related
Hazards Capital Fund
15.022 Tribal Self-Governance
15.025/15.026/15.113/
15.114/15.130 Services to Indian Children, Elderly and Families (477 Cluster)
16.710 Public Safety Partnership and Community Policing Grants
Compliance Supplement 2023 8-IV-3 Appendix IV
May 2023 Internal Reference Tables
17.225 Unemployment Insurance (UI)
17.265 Native American Employment and Training
20.106 Airport Improvement Program
20.223 Transportation Infrastructure Finance and Innovation Act
(TIFIA) Program
21.012 Native Initiatives (New)
21.016 Equitable Sharing Program
21.020 Community Development Financial Institutions Program
21.027 Coronavirus State and Local Fiscal Recovery Funds
66.458/66.482 Capitalization Grants for Clean Water State Revolving Funds
66.468/66.483 Capitalization Grants for Drinking Water State Revolving Funds
81.041 State Energy Program
84.000 Cross-Cutting Section
84.002 Adult Education-Basic Grants to States
84.010 Title I Grants to Local Educational Agencies
84.011 Migrant Education -State Grant Program (Title I, Part C of
ESEA)
84.027/84.173 Special Education-Grants to States (IDEA, Part B)
84.032-G Federal Family Education Loans-(Guaranty Agencies)
84.032-L Federal Family Education Loans-(Lenders)
84.041 Impact Aid (Title VII of ESEA)
84.042/84.044/84.047/
84.066/84.217 Student Support Services
84.048 Career and Technical Education-Basic Grants to States (Perkins
IV)
84.181 Special Education-Grants for Infants and Families
84.282 Charter Schools
84.287 Twenty-First Century Community Learning Centers
84.367 Supporting Effective Instruction State Grants (formerly
Improving Teacher Quality State Grants)
84.424 Student Support and Academic Enrichment Program
84.938 Hurricane Education Recovery
93.044/93.045/93.053 Special Programs for the Aging-Title III, Part B-Grants for
Supportive Services and Senior Centers and CARES Act for
Supportive Services Under Title III-B of the Older Americans
Act
93.095/93.096 HHS Programs for Disaster Relief Appropriations Act-Non-
Construction
93.268 Immunization Cooperative Agreements
93.461 HRSA COVID-19 Uninsured Program
93.498 Provider Relief Fund
93.499 Low-Income Household Water Assistance Program
93.545 Consumer Operated and Oriented Plan (CO-OP) Program
93.558 Temporary Assistance for Needy Families (TANF)
93.566 Refugee and Entrant Assistance—State-Administered Programs
93.569 Community Services Block Grant
Compliance Supplement 2023 8-IV-4 Appendix IV
May 2023 Internal Reference Tables
93.575/93.596/93.489 Child Care and Development Block Grant
93.600/93.356 Head Start
93.667 Social Services Block Grant
93.778/775/777 Medical Assistance Program (Medicaid; Title XIX)
93.959 Block Grants for Prevention and Treatment of Substance Abuse
93.994 Maternal and Child Health Services Block Grant to the States
97.036 Disaster Grants-Public Assistance (Presidentially Declared
Disasters)
97.039 Hazard Mitigation Grant Program (HMGP)
97.067 Homeland Security Grant Program (HSGP)
Part 5.3 also has requirements defined in IV, “Other Information.”
Compliance Supplement 2023 8-IV-5 Appendix IV
May 2023 List of Changes for the 2022 Compliance Supplement
APPENDIX V
LIST OF CHANGES FOR THE 2023 COMPLIANCE SUPPLEMENT
This appendix provides a list of changes from the 2023 Supplement dated May 2023. Please note
that changes in the Matrix of Compliance Requirements are reflected in Part 2 of this supplement
and are not reflected in this appendix.
Table of Contents
The Table of Contents has been updated to show additions and deletions.
Part 1 – Background, Purpose, and Applicability
• Updated for the effective date of Supplement, streamlined language in
Background, Purpose, Applicability and How to Obtain Additional Guidance
sections, included information on the FAC transition and Single Audit Extensions
within the Other Audit Advisories section.
Part 2 – Matrix of Compliance Requirements
• Matrix of Compliance changes and corrections were made for 2023. Changes are
shown in yellow highlights.
Part 3 – Compliance Requirements
• Updated Introduction for the effective date of the Supplement, updated Cash
Management, and included BABAA requirement to Procurement and Suspension
and Debarment.
Part 4 – Agency Program Requirements
Changes were made to the following programs and clusters:
• 10.512-Agriculture Extension at 1890 Land-Grant Institutions Program
• 10.515-Renewable Resources Extension Act (RREA) and National Focus Funds
(RREA-NFF)
• 10.551/10.561-Supplemental Nutrition Assistance Program (SNAP) Cluster
• 10.553/10.555/10.566/10.559/10.582-Child Nutrition Cluster
• 10.606-Food for Progress Program
• 10.607-Section 416(b) Program
• 10.766/10.780-Community Facilities Loans and Grants Cluster
Compliance Supplement 2023 8-V-1 Appendix V
May 2023 List of Changes for the 2022 Compliance Supplement
• 11.300/11.307- Economic Development Cluster
• 11.611-Hollings Manufacturing Extension Partnership (NIST)
• 14.157-Supportive Housing for the Elderly (Section 202)
• 14.182/14.195/14.249/14.856-Section 8 Project-Based Cluster
• 14.269/14.272- Community Development Block Grant-Disaster Recovery Grant
(CDBG-DR) Cluster
• 14.866/14.889- HOPE VI Cluster
• 14.867-Indian Housing Block Grants
• 14.871/14.879- Housing Voucher Cluster
• 14.872-Public Housing Capital Fund (CFP)
• 14.873-Native Hawaiian Housing Block Grant
• 14.881-Moving to Work Demonstration Program
• 14.888-Lead-Based Paint & Housing-Related Hazards
• 15.252-Abandoned Mine Land Reclamation
• 15.605/15.611/15.626-Fish and Wildlife Cluster
• 16.034-Coronavirus Emergency Supplemental Funding
• 16.710-Public Safety Partnership and Community Policing Grants
• 16.738-Edward Byrne Memorial Justice Assistance Grant Program
• 16.922-Equitable Sharing Program
• 17.207/17.801-Employment Service Cluster
• 17.225-Unemployment Insurance (UI)
• 17.235-Senior Community Service Employment Program
• 17.245-Trade Adjustment Assistance
• 17.258/17.259/17.278-WIOA Cluster
• 17.264-National Farmworker Jobs Program
Compliance Supplement 2023 8-V-2 Appendix V
May 2023 List of Changes for the 2022 Compliance Supplement
• 17.265-Native American Employment and Training
• 20.001-Wage Rate Requirements Cross-Cutting Section
• 20.205-Highway Planning and Construction (Federal-Aid Highway Program)
(decoupled program)
• 20.218-Motor Carrier Safety Assistance Program
• 20.219-Recreational Trails Program (decoupled program)
• 20.223-Transportation Infrastructure Finance and Innovation Act (TIFIA)
Program
• 20.224-Federal Lands Access Program (decoupled program)
• 20.315 – National Railroad Passenger Corporation Grants
• 20.327-Railroad Crossing Elimination (new)
• 20.500/20.507/20.525/20.526-Federal Transit Cluster
• 20.509-Formula Grants for Rural Areas
• 20.532-Passenger Ferry Grant Program, Electric or Low Emitting Ferry Pilot
Program, and Ferry Service for Rural Communities Program (new)
• 20.533-All Stations Accessibility Program (new)
• 20.534-Community Project Funding Congressionally Directed Spending (new)
• 20.600/20.611/20.616- Highway Safety Cluster
• 20.708-Natural Gas Distribution Infrastructure Safety and Modernization Grant
Program(new)
• 20.816-Maritime Administration Marine Highway Grant Program
• 20.823-Maritime Administration – Port Infrastructure Development Program
• 21.011 – Capital Magnet Fund (new)
• 21.012 – Native Initiatives (new)
• 21.015-Resources and Ecosystems Sustainability, Tourist Opportunities, and
Revived Economies of the Gulf Coast States (Gulf RESTORE)
• 21.019-Coronavirus Relief Fund
Compliance Supplement 2023 8-V-3 Appendix V
May 2023 List of Changes for the 2022 Compliance Supplement
• 21.020-Community Development Financial Institutions Program
• 21.023 - Emergency Rental Assistance Program
• 21.024 – Rapid Response Program (new)
• 21.025 -Small Dollar Loan Program (new)
• 21.026 - Homeowner Assistance Fund
• 21.027 - Coronavirus State and Local Fiscal Recovery Funds
• 21.029 - Coronavirus Capital Projects Fund Program
• 21.032- Local Assistance and Tribal Consistency Fund (new)
• 23.003-Appalachian Development Highway System (decoupled)
• 32.006-COVID-19 Telehealth Program
• 32.009- Emergency Connectivity Fund Program
• 45.129-Promotion of the Humanities-Federal/State Partnership
• 81.041-State Energy Program
• 81.042-Weatherization Assistance for Low-Income Persons
• 84.000-Cross-Cutting Section
• 84.010-Title I Grants to Local Educational Agencies (Title I, Part A of the ESEA)
• 84.011-Migrant Education-State Grant Program (Title I, Part C of ESEA)
• 84.027/84.173- Special Education Cluster (IDEA)
• 84.041-Impact Aid (Title VII of ESEA)
• 84.048-Career and Technical Education-Basic Grants to States (Perkins V)
• 84.181-Special Education-Grants for Infants and Families
• 84.282-Charter Schools
• 84.365-English Language Acquisition State Grants
• 84.367-Supporting Effective Instruction State Grants (formerly Improving
Teacher Quality State Grants)
Compliance Supplement 2023 8-V-4 Appendix V
May 2023 List of Changes for the 2022 Compliance Supplement
• 84.425-Education Stabilization Fund (ESF)
• 93.044/93.045/93.053-Aging Cluster
• 93.090-Guardianship Assistance
• 93.153-Coordinated Services and Access to Research for Women, Infants,
Children, and Youth (Ryan White HIV/AIDS Program Part D Women, Infants,
Children and Youth WICY Program)
• 93.210-Tribal Self-Governance Program-IHS Compacts/Funding Agreements
• 93.217-Family Planning-Services
• 93.224/93.527-Health Center Program Cluster
• 93.423-Waivers for State Innovation for Section 1332 of the Patient Protection
and Affordable Care Act (PPACA)
• 93.461-HRSA COVID-19 Uninsured Program
• 93.498-Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution
• 93.499 – Low Income Household Water Assistance Program
• 93.545-Consumer Operated and Oriented Plan (CO-OP) Program
• 93.556-Promoting Safe and Stable Families
• 93.558-Temporary Assistance for Needy Families (TANF)
• 93.563-Child Support Enforcement
• 93.566-Refugee and Entrant Assistance-State-Administered Programs
• 93.568-Low-Income Home Energy Assistance
• 93.575/93.596/93.489- Child Care and Development Fund Cluster
• 93.600/93.356-Head Start Cluster
• 93.645-Stephanie Tubbs Jones Child Welfare Services Program
• 93.658-Foster Care-Title IV-E
• 93.659-Adoption Assistance-Title IV-E
• 93.667-Social Services Block Grant
Compliance Supplement 2023 8-V-5 Appendix V
May 2023 List of Changes for the 2022 Compliance Supplement
• 93.671-Family Violence Prevention and Services Act
• 93.686-Ending the HIV Epidemic: A Plan for America
• 93.767-Children’s Health Insurance Program (CHIP)
• 93.778/93.777/93.775-Medical Cluster
• 93.914-HIV Emergency Relief Project Grants (Ryan White HIV/AIDS Program
Part A)
• 93.917-HIV Care Formula Grants (Ryan White HIV/AIDS Program Part B)
• 93.918-Grants to Provide Outpatient Early Intervention Services with Respect to
HIV Disease (Ryan White HIV/AIDS Program Part C)
• 93.958-Block Grants for Community Mental Health Services
• 93.994-Maternal and Child Health Services Block Grant to the States
• 96.001/96.006-Disability Insurance/SSI Cluster
• 97.036-Disaster Grants-Public Assistance (Presidentially Declared Disasters)
• 97.067-Homeland Security Grant Program (HSGP)
Part 5 – Clusters of Programs
• Part 5.1 - No Change.
• Part 5.2 – No Change.
• Part 5.3 – Updated for the effective date of Supplement, changes within Activities
Allowable/Unallowed, Cash Management, Eligibility, Reporting and Special
Tests.
• Part 5.4 – Removed the Highway Planning and Construction Cluster.
Part 6 – Internal Control
• No Change.
Part 7 – Guidance for Auditing Programs Not Included in This Compliance Supplement
• No Change.
Compliance Supplement 2023 8-V-6 Appendix V
May 2023 List of Changes for the 2022 Compliance Supplement
Part 8 – Appendixes
Appendix I – Federal Programs Excluded from the A-102 Common Rule and Portions of
2 CFR Part 200
• No Change.
Appendix II – Federal Agency Codification of Governmentwide Requirements and
Guidance for Grants and Cooperative Agreements
• No Change.
Appendix III – Federal Agency Single Audit, Key Management Liaison, and Program
Contacts
• Updated for this year’s program contacts.
Appendix IV – Internal Reference Tables
• Updated the list of programs currently designated as high risk.
• Updated the list of programs with requirements defined in IV, “Other Information.”
Appendix V – List of Changes for the 2022 Compliance Supplement
• List updated with changes to the programs and appendixes for 2023.
Appendix VI – Program-Specific Audit Guides
• No Changes.
Appendix VII – Other Audit Advisories
• Updated for the effective date of the Supplement, included FAC transition information
and Single Audit Extensions.
Appendix VIII – Examinations of EBT Service Organizations
• No Change.
Appendix IX – Compliance Supplement Core Team
• Updated the list of team members for 2023.
Compliance Supplement 2023 8-V-7 Appendix V
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