Emergency Rental Assistance Program — Compliance Supplement, Assistance Listing 21.023
Summary
This is the Compliance Supplement section for the Department of the Treasury Emergency Rental Assistance Program, Assistance Listing 21.023. The program objectives say two laws authorized funding, so the 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, Pub. L. No. 116-260 (December 27, 2020), and ERA 2 by Section 3201 of the American Rescue Plan Act, Pub. L. No. 117-2 (March 11, 2021). The overview says ERA 1 provided $25 billion for Treasury to make payments to States, US territories, Indian tribes or their tribally designated housing entities, and certain local governments.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
- Issuer
- Congressional materials
- Document type
- Department Of The Treasury Era Compliance Supplement Home Treasury Gov 999201Bfb8
- Case
- Department Of The Treasury Era Compliance Supplement Home Treasury Gov 999201Bfb8
Cite this document
“Emergency Rental Assistance Program — Compliance Supplement, Assistance Listing 21.023.”
Original at home.treasury.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/department-of-the-treasury-era-compliance-supplement-home-treasury-gov-999201bfb8/
, SHA-256 6782e42a52d52e1c485ce0718fe759c91ecdcfa084091647d6cd04a50a3db3ac.Full text
Emergency Rental Assistance Program Treasury
DEPARTMENT OF THE TREASURY
ASSISTANCE LISTING 21.023 EMERGENCY RENTAL ASSISTANCE PROGRAM
I. PROGRAM OBJECTIVES
Two laws 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” in the
Uniform Guidance and both ERA 1 and ERA 2 are administered by the Department of the
Treasury (Treasury) as direct payments for specified use.
The purpose of ERA is to provide direct payments to eligible grantees 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 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. The period of performance for the initial allocation of ERA1 awards and
reallocated funds expired on September 30, 2022, and December 29, 2022, respectively.
Therefore, grantees’ fiscal year 2025 financial reporting should not include any
expenditures for audit for their ERA 1 award.
Compliance Supplement 2025 4-21.023-1
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). [The period of performance for ERA2 awards ends on
September 30, 2025.]
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 codified as 15 USC9058a.
Emergency Rental Assistance (“ERA 2”), Title III, Subtitle B, Section 3201 of the American
Rescue Plan Act, 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 2025 4-21.023-2
Emergency Rental Assistance Program Treasury
the Consolidated Appropriations Act, 2021 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
General information for ERA is available on Treasury’s website at
https://www.treasury.gov/ERA. Information includes the following documents:
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.
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.
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.
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.
Treasury’s ERA Frequently Asked Questions (FAQs) and guidance are available at:
https://home.treasury.gov/system/files/136/ERA-FAQs03052024.pdf (See pages 1-23)
Treasury released FAQs as guidance regarding ERA 1 and ERA 2 except where differences are
specifically noted.
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.
Compliance Supplement 2025 4-21.023-3
Emergency Rental Assistance Program Treasury
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.
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.
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)
This webpage describes examples of promising practices for ERA that 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.
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
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.
Compliance Supplement 2025 4-21.023-4
Emergency Rental Assistance Program Treasury
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 Y Y N N Y Y N
A. Activities Allowed or Unallowed
1. Activities Allowed
B. Allowable Costs / Cost Principles
The cost principles in 2 CFR Part 200, Subpart E (Cost Principles) except for 2 CFR
200.418 and 2 CFR 200.419 apply to ERA 2. Thus, if a grantee made ineligible payments
with ERA1 funds, the grantee may remove the ineligible payment from ERA1 and may
pursue allowable recharacterization for eligible payments made from ERA2 funds during
the ERA1 period of performance. Repayment to Treasury may not be required. See
ERA1 Closeout Resource Footnote 3.
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 ERA
FAQ 1.at: https://home.treasury.gov/system/files/136/ERA-FAQs03052024.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) 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 Treasury, Department of Justice, and Department of Housing and
Urban Development’s joint letter issued August 27, 2021 that can be accessed at:
https://home.treasury.gov/system/files/136/Eviction-Moratorium-Joint-Letter.pdf.
Compliance Supplement 2025 4-21.023-5
Emergency Rental Assistance Program Treasury
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 at:
https://home.treasury.gov/system/files/136/ERA-FAQs03052024.pdf. Grantees
must obtain, if available, a current lease, signed by the applicant and the landlord
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 at: https://home.treasury.gov/system/files/136/ERA-
FAQs03052024.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.
Compliance Supplement 2025 4-21.023-6
Emergency Rental Assistance Program Treasury
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
the applicant resides, as most recently determined by HUD and made
available at: https://www.huduser.gov/portal/datasets/fmr.html. In
accordance with FAQ# 1, grantees must specify in their policies and
procedures under what circumstances they will accept written attestations
from the applicant without further documentation to determine any aspect
of eligibility or the amount of assistance, and in such cases, grantees must
have in place reasonable validation or fraud-prevention procedures to
prevent abuse;
b. Categorical Eligibility – 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
Compliance Supplement 2025 4-21.023-7
Emergency Rental Assistance Program Treasury
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 the factors regarding the allowability of
costs in the Uniform Guidance, 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
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.
Beginning October 1, 2022, grantees that have obligated 75 percent of their ERA2
awards, including funds received through reallocation, may choose to use up to 25
percent of their ERA2 award 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 at FAQ 46 in July
2022. See page 20 of https://home.treasury.gov/system/files/136/ERA-
FAQs03052024.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
Compliance Supplement 2025 4-21.023-8
Emergency Rental Assistance Program Treasury
G. Matching, Level of Effort, Earmarking
1. Matching
Not Applicable
2. Level of Effort
Not Applicable
3. Earmarking
Under ERA 2, a grantee may use up to 15 percent of the total award amount for
direct and indirect administrative costs and 10 percent of the total award amount
for housing stability services. See FAQ 29 at:
https://home.treasury.gov/system/files/136/ERA-FAQs03052024.pdf.
ERA Funds Reallocation
Pursuant to 15 USC 9058c(e), Treasury has the authority to reallocate ERA 2
award funds that have not yet been disbursed to a grantee. Treasury’s ERA 2
reallocation guidance on Treasury.gov and previewed here describes the voluntary
reallocation process through which a grantee may request that Treasury reallocate
its ERA 2 award funds to other ERA 2 grantees in the same state or to Treasury’s
general pool of reallocated funds. Grantees’ eligibility for reallocated funds can
be verified by their expenditure reports demonstrating they have met the statutory
requirement that at least 50 percent of the total funds allocated to a grantee have
been obligated to be eligible for reallocated funds. The grantees are also required
to certify that they meet this obligation requirement on the form they submit to
Treasury to request the reallocated funds. Unlike with ERA1, Treasury did not
recapture any ERA2 funds paid out to a grantee; only undisbursed ERA2 funds
were subject to reallocation. Guidance for ERA 2 reallocation can be found on
this site at https://home.treasury.gov/system/files/136/ERA2-Reallocation-
Guidance-March-30-2022.pdf (See pages 1 - 6).
Updated information regarding ERA 2 reallocation was posted as an update to
Reallocation Guidance in March 2022. Treasury does not plan on conducting any
additional “involuntary” reallocations for ERA2.
H. Period of Performance
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 2 awards must be returned to Treasury as part of the award
closeout process pursuant to the Uniform Guidance closeout requirements, including
amounts distributed through redirection and reallocation.
Compliance Supplement 2025 4-21.023-9
Emergency Rental Assistance Program Treasury
L. Reporting
1. Financial Reporting
a. SF-270, Request for Advance or Reimbursement – Not Applicable
b. SF-271, Outlay Report and Request for Reimbursement for Construction
Programs – Not Applicable
c. SF-425, Federal Financial Report – Not Applicable
Note: ERA recipients do not submit SF-425 Reports. They provide a
subset of the data collected via the SF-425 in the ERA2 Compliance
Report in the Federal Financial Reporting section of the report via
Treasury’s portal.
2. Performance Reporting
a. Title of Report: ERA Compliance Report
PRA Number: 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/ERA2-Portal-Users-Guide.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: ERA2 recipients that submit a report prior to the due date
may recall a previously submitted report, make any edits, and resubmit the report
by the due date. In addition, when authorized by Treasury staff, ERA2 recipients
may revise submitted reports for the current quarter to address issues identified by
Treasury’s initial data quality/consistency validations. After the revision period
ends, the submitted report is final within Treasury’s reporting portal. Where the
ERA2 recipient identifies an issue for revision after the revision period, recipients
are required to ensure the revised information is incorporated into the next
quarterly report.
Key Line Items-
Administrative Costs Ratio- Quantifiable Objective Criteria: Total
obligations and/or expenditures for administrative costs does not exceed
the relevant threshold of total allocation (15% for ERA 2 across the prime
and all subrecipients), and the amounts reported for administrative costs
are accurate. (See ERA Reporting Guidance, Appendix 7, Applicable
Compliance Supplement 2025 4-21.023-10
Emergency Rental Assistance Program Treasury
Limitations on Administrative Expenses, page 54 and for ERA2 see ERA
2 Reporting Guidance, Appendix 7, Applicable Limitations on
Administrative Expenses, page 43)
1. 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 ERA2 Reporting Guidance,
Appendix 7, Applicable Limitations on Administrative Expenses, page
43). Examples of these services can be found in FAQ 23 on page 12 of the
March 5, 2024 FAQs located at:
https://home.treasury.gov/system/files/136/ERA-FAQs03052024.pdf.
2. 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
with greater than 50% AMI receiving assistance (For ERA1 see ERA
Reporting Guidance, Section E, Number of Unique Participant
Households at Certain Income Levels, page 29 and for ERA2 see ERA2
Reporting Guidance, Section E, Cumulative Number of Unique
Participant Households at Certain Income Levels, page 23)
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 (For ERA1 see ERA Reporting Guidance, Section E, Number
of Unique Participant Households at Certain Income Levels, page 29 and
for ERA2 see ERA2 Reporting Guidance, Section E, Cumulative Number
of Unique Participant Households at Certain Income Levels, page 23)
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 ERA2 Award Terms, ERA grantees’ compliance
with these reporting requirements is not subject to audit.
Compliance Supplement 2025 4-21.023-11
Emergency Rental Assistance Program Treasury
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.
Compliance Supplement 2025 4-21.023-12
File and source
- File
- department-of-the-treasury-era-compliance-supplement-home-treasury-gov-999201bfb8.pdf
- Size
- 361,545 bytes
- SHA-256
- 6782e42a52d52e1c485ce0718fe759c91ecdcfa084091647d6cd04a50a3db3ac
- Original
- home.treasury.gov