Desk Review of the OIG-27-011 State of Maine's Use of Coronavirus Relief Funds Proceeds
Summary
A Department of the Treasury Office of Inspector General memorandum, OIG-27-011, dated October 5, 2026, from Pauletta P. Battle, Assistant Inspector General for Audit, to Jeffrey Stout, Acting Chief Program Officer, Office of Capital Access. It reports on a desk review, initiated March 29, 2022, of the State of Maine's use of Coronavirus Relief Fund (CRF) proceeds authorized under Title VI of the Social Security Act as amended by the CARES Act. The review's objective was to evaluate Maine's documentation supporting its uses of CRF proceeds reported in the GrantSolutions portal and to assess the risk of unallowable use of funds.
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DEP A RTMENT OF THE TRE A SUR Y
WASH INGTON , D.C. 20220
OFFICE OF
INSPECTOR GENERAL
October 5, 2026
OIG-27-011
MEMORANDUM FOR JEFFREY STOUT, ACTING CHIEF PROGRAM OFFICER,
OFFICE OF CAPITAL ACCESS , DEPARTMENT OF THE
TREASURY
FROM: Pauletta P. Battle Isl
Assistant Inspector General for Audit
SUBJECT: Desk Review of the State of Maine's Use of Coronavirus
Re lief Fund Proceeds
On March 29, 2022, we initiated a desk review of the State of Maine's (Maine) use
of Coronavi rus Relief Fund (CRF) proceeds, authorized under Title VI of the Social
Security Act, as amended by Title V, Division A of the Coronavirus Aid , Re lief, and
Economic Security Act (CARES Act). 1 The objective of our desk review was to
evaluate Maine' s documentation supporting its uses of CRF proceeds as reported in
the GrantSolutions 2 porta l and to assess the risk of unall owable use of funds. The
scope of our desk review cove red Maine' s obligation and expenditure data for the
period March 1, 2020, t hrough December 3 1, 2022 (cycles 1-11 ), as reported in
GrantSolutions .
As part of the desk review, we performed the following :
1) reviewed Maine' s quarterly Financial Progress Reports (FPRs) submitted in
GrantSolutions through December 31 , 2022;
2) reviewed the Treasu ry ' s Coronavirus Relief Fund Guidance (Guidance) as
published in the Federal Register on January 15, 202 1 ; 3
3) reviewed Treas ury OIG' s Coronavirus Relief Fund Frequently Asked
Questions Related to Reporting and Recordkeeping; 4
1
P.L. 116-136 (March 27, 2020)
2
Grant Solut ions, a grant and program management Federal shared service prov ider under the
U.S. Department of Health and Human Services, dev eloped a customized and user-friendl y
reporting solut ion to capt ure t he use of CRF payments from recipient s.
3
Coronav irus Relief Fund Guidance as published in t he Federal Regist er (January 15 , 202 1)
https://home.treasury .gov/system/files/ 1 36/ CRF-Guidance-Federal-Register 2021-00827. pdf
4
Treasury OIG Coronavirus Relief Fund Frequently Asked Questions Related to Reporting and
Recordkeeping (OIG-20-028R; March 2, 2021 ).
1
4) reviewed Treasury OIG’s Coronavirus Relief Fund Reporting and Record
Retention Requirements;
5) reviewed Treasury OIG’s monitoring checklists 5 of Maine’s quarterly FPR
submissions for reporting deficiencies;
6) reviewed other audit reports issued, such as Single Audit Act reports, and
those issued by the Government Accountability Office and other applicable
Federal agency OIGs for internal control or other deficiencies that may
pose a risk or impact Maine’s use of CRF proceeds;
7) reviewed Treasury OIG Office of Investigations, the Council of the
Inspectors General on Integrity and Efficiency (CIGIE) Pandemic Response
Accountability Committee (PRAC), 6 and Treasury OIG Office of Counsel input
on issues that may pose risks or impact to Maine’s use of CRF proceeds;
8) interviewed key personnel responsible for preparing and certifying
Maine’s quarterly FPR submissions, as well as officials responsible for
obligating and expending CRF proceeds;
9) made a non-statistical selection of Contracts greater than or equal to
$50,000, Grants greater than or equal to $50,000, Direct Payments greater
than or equal to $50,000, Aggregate Reporting less than $50,000, 7 and
Aggregate Payments to Individuals 8 data identified through GrantSolutions
reporting; and
10) evaluated documentation and records used to support Maine’s quarterly
FPRs.
Based on the results of our desk review, Maine’s documentation supporting the
uses of CRF proceeds complied with the CARES Act and Treasury’s Guidance. We
determined that Maine’s risk of unallowable use of funds is low. Accordingly, we
will not be conducting an audit of Maine.
5
The checklists were used by Treasury OIG personnel to monitor the progress of prime recipient
reporting in the GrantSolutions portal. GrantSolutions quarterly submission reviews were
designed to identify material omissions and significant errors, and where necessary, included
procedures for notifying prime recipients of misreported data for timely correction. Treasury OIG
followed the CRF Prime Recipient Quarterly GrantSolutions Submissions Monitoring and Review
Procedures Guide, OIG-CA-20-029R to monitor the prime recipients on a quarterly basis.
6
Section 15010 of P.L. 116-136 established the PRAC within the CIGIE to promote transparency
and conduct and support oversight of covered funds and the coronavirus response to (1) prevent
and detect fraud, waste, abuse, and mismanagement; and (2) mitigate major risks that cut across
program and agency boundaries.
7
Prime recipients were required to report CRF transactions greater than or equal to $50,000 in
detail in the GrantSolutions portal. Transactions less than $50,000 could be reported as an
aggregate lump-sum amount by type (contracts, grants, loans, direct payments, and transfers to
other government entities).
8
Obligations and expenditures for payments made to individuals, regardless of amount, were
required to report in the aggregate in the GrantSolutions portal to prevent inappropriate disclosure
of personally identifiable information.
2
Non-Statistical Transaction Selection Methodology
Treasury issued a total of $1,250,000,000 in CRF payment to Maine. As of
December 31, 2022, Maine expended all its CRF funds. We made a non-statistical
selection of 58 transactions from Contracts greater than or equal to $50,000,
Grants greater than or equal to $50,000, Direct Payments greater than or equal to
$50,000, Aggregate Reporting less than $50,000, and Aggregate Payments to
Individuals.
We made selections using auditor judgment based on the total CRF award amount,
amounts claimed within each payment type, and our overall risk assessment of
Maine. Because the transactions tested were non-statistically selected, results
could not be extrapolated to the total universe of transactions.
Background
The CARES Act appropriated $150 billion to establish the CRF. Under the CRF,
Treasury made payments for specified uses to States and certain local
governments; the District of Columbia and U.S. Territories, including the
Commonwealth of Puerto Rico, the U.S. Virgin Islands, Guam, American Samoa,
and the Commonwealth of the Northern Mariana Islands; and Tribal governments
(collectively referred to as “prime recipients”). Treasury issued a total of
$1,250,000,000 CRF payments to Maine. The CARES Act stated that a prime
recipient may only use the funds to cover costs that were—
1) necessary expenditures incurred due to the public health emergency with
respect to the Coronavirus Disease 2019 (COVID-19);
2) not accounted for in the budget most recently approved as of March 27,
2020; and
3) incurred during the period between March 1, 2020, and ended on December
31, 2021, for states, local governments, and territories. In the case of tribal
governments, were incurred during the period that began on March 1, 2020,
and ended on December 31, 2022 (covered period).
Section 15011 of the CARES Act required each covered recipient 9 to submit to
Treasury and the PRAC, no later than 10 days after the end of each calendar
9
Section 15011 of P.L. 116-136 defined a covered recipient as any entity that received large
covered funds and included any State, the District of Columbia, and any territory or possession
of the United States.
3
quarter, a report that contained (1) the total amount of large covered funds 10,11
received from Treasury; (2) the amount of large covered funds received that were
expended or obligated for each project or activity; (3) a detailed list of all projects
or activities for which large covered funds were expended or obligated; and (4)
detailed information on any level of sub-contracts or sub-grants awarded by the
covered recipient or its sub-recipients.
The CARES Act assigned Treasury OIG the responsibility for compliance monitoring
and oversight of the receipt, disbursement, and use of CRF proceeds.
Desk Review Results
We reviewed the GrantSolutions portal and found that Maine timely filed quarterly
FPRs for the period March 1, 2020, through December 31, 2022 (cycles 1 – 11),
as required under Treasury OIG’s Guidance, Coronavirus Relief Fund Reporting and
Record Retention Requirements.
We found that the transactions tested in Contracts greater than or equal to
$50,000, Aggregate Reporting Less Than $50,000 and Aggregate Payments to
Individuals payment types were: (1) necessary expenditures incurred due to the
public health emergency with respect to COVID-19, (2) not accounted for in the
budget most recently approved as of March 27, 2020, and (3) incurred during the
covered period. Additionally, we identified ineligible questioned costs of $29,517
reported under Grants greater than or equal to $50,000, and unsupported
questioned costs of $6,103 related to a variance between Maine’s general ledger
and the amount reported under Direct Payments greater than or equal to $50,000.
Maine subsequently provided eligible replacement expenses documentation for the
$35,620 questioned costs. As a result, Maine’s documentation supporting the uses
of CRF proceeds complied with the CARES Act and Treasury’s Guidance. We
determined that Maine’s risk of unallowable use of funds is low. Accordingly, we
will not be conducting an audit of Maine. Table 1 shows a summary of expenditure
totals and the results of our testing.
10
Section 15010 of P.L. 116-136 defined covered funds as any funds, including loans, that were
made available in any form to any non-Federal entity, not including an individual, under Public
Laws 116-123, 127, and 136, as well as any other law which primarily makes appropriations for
Coronavirus response and related activities.
11
Section 15011 of P.L. 116-136 defined large, covered funds as covered funds that amounted to
more than $150,000.
4
Table 1 Summary Non-Statistical Testing Results
Cumulative Cumulative
Expenditure Expenditure Number of Unsupported Ineligible Total
Payment Population Tested Transactions Questioned Questioned Questioned
Type Amount Amount Tested Costs Costs Costs
Contracts
>=
$50,000 $ 377,462,604 $ 1,027 ,541 12 $ - $ - $
Grant s
>=
$50,000 $ 375 ,378,634 $ 104,010 10 $ - $ - $
Direct
Payments
>=
$50,000 $ 8 ,329, 184 $ 6,459 ,8 16 3 $ - $ - $
Aggregate
Reporting
<
$50,000 $ 13 ,284,481 $ 288,777 6 $ - $ - $
Aggregate
Payments
to
Indiv iduals $ 475 ,545,097 $ 43,361 27 $ - $ - $
Totals $ 1,250,000,000 $ 7,923,506 58 $ - $ - $ -
Source : Treasury OIG
Contracts Greater Than or Equal to $50,000
We tested 12 transactions tota ling $1,027,54 1 without exception. Transactions
tested included expenditures that supported economic recove ry from the impacts
and ope rational disruption to local businesses and non-profit organizations
experienced due to COVID- 19; and provided mobile laboratory services for
COVID-19 testing.
Grants Greater Than or Equal to $50,000
We tested 10 transactions tota ling $104 ,010 with one exception identify ing tota l
ineligible questioned costs of $29,517. Transactions tested included expenditu res
that supported a safe learning environment fo r public sc hoo l students when they
co uld not attend sc hoo l due to COVID-19 restrictions; public schools additional
costs related to COVID-19; a re nt relief program fo r t hose facing potential housing
disruption due to ci rcumstances related to the COVID-19 pandemic; and university
costs for deploying COVID-1 9 testing plans, pu rchasing persona l protective
eq uipment, and quarantining students affected by COVID-19 th roughout the
cam pus.
5
We identified that Maine expended CRF proceeds to purchase a 3-year license for
learning software for a total amount of $48,300.00. The license was for the period
covering August 24, 2021, through August 21, 2024, which we deemed ineligible
because it was incurred outside of the covered period to use the funds. Since CRF
proceeds were expended to purchase the license beyond September 30, 2022, we
questioned $29,517 as ineligible costs.
Subsequently, Maine provided eligible replacement expenses documentation for the
$29,517 questioned costs. The replacement expenses were related to services for
mobile hotspots/connectivity used for remote learning.
Direct Payments Greater Than or Equal to $50,000
We tested three transactions totaling $6,459,816 with one exception identifying
total unsupported questioned costs of $6,103. Transactions tested included
expenditures related to data and equipment services for students and educators to
safely return to classroom-based instruction.
We identified a variance between Maine’s general ledger and the amount reported
under Direct Payments greater than or equal to $50,000 in the GrantSolutions
portal. Maine reported $6,459,816 with supporting documentation of $6,453,713,
resulting in a variance of $6,103. Since Maine did not provide supporting
documentation for the variance, we questioned $6,103 as unsupported costs.
Subsequently, Maine provided eligible replacement expenses documentation for the
$6,103 questioned costs. The replacement expenses were related to substantially
dedicated payroll 12 expenditures.
Aggregate Reporting Less Than $50,000
We tested six transactions totaling $288,777 without exception. Transactions
tested included expenditures for food delivery to vulnerable residents to comply
with COVID-19 public health precautions; replacement of equipment needed to
achieve increased air exchanges in buildings; a back to work program assisting
businesses facing workforce shortages due to COVID-19; assistance to childcare
providers with personal protective equipment, additional administrative, public
health, and food expenses related to COVID-19; and the purchase of equipment
and software to enhance video conference capabilities during the COVID-19
pandemic.
12
Substantially dedicated payroll costs are defined as employees whose services were substantially
dedicated to mitigating or responding to the COVID–19 public health emergency.
6
Aggregate Payment to Individuals
We tested 27 transactions totaling $43,361 without exception. Transactions
tested included expenditures for financial assistance payments to citizens due to
hardship or loss of income; unemployment insurance expenditures; payroll costs for
public health and safety personnel; and substantially dedicated payroll costs.
Conclusion
We determined that Maine’s expenditures, as tested, were necessary due to the
COVID-19 public health emergency, were not accounted for in the budget most
recently approved as of March 27, 2020, and were incurred during the covered
period that began March 1, 2020, and ended on December 31, 2021.
Overall, we determined that Maine’s risk of unallowable use of funds is low. As a
result, we will not be conducting an audit.
State of Maine’s Response
The State of Maine concurred with our assessment. On September 24, 2026, the
State of Maine provided its written response which is included in its entirety as
Appendix 1.
*****
All work completed complies with the Council of the Inspectors General on
Integrity and Efficiency’s Quality Standards for Federal Offices of Inspectors
General, which require that the work adheres to the professional standards of
independence, due professional care, and quality assurance to ensure the accuracy
of the information presented.13
We appreciate the courtesies and cooperation provided to our staff during the desk
review. If you have any questions or require further information, please contact me
at (202) 927-5400, or a member of your staff may contact Julie Wong, Acting
Deputy Assistant Inspector General for Audit, at (202) 439-6354.
cc: Michelle A. Dickerman, Deputy Assistant General Counsel, Department of the
Treasury
Thao P. Tran, Acting Chief Operating Officer, Office of Capital Access,
Department of the Treasury
13 https://www.ignet.gov/sites/default/files/files/Silver%20Book%20Revision%20-%208-20-12r.pdf
7
Shirley Brown, Deputy State Controller, Office of the State Controller,
State of Maine
John Baker, Director of Internal Audit, Office of the State Controller,
State of Maine
Faith Talbot, Audit Analyst, Office of the State Controller, State of Maine
Kelli Lascko, Audit Analyst, Office of the State Controller, State of Maine
8
(b)(6)
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