Emergency Rental Assistance (ERA1): Closeout Resource (Treasury, September 16, 2022)
Summary
U.S. Department of Treasury Emergency Rental Assistance (ERA1): Closeout Resource dated September 16, 2022, for ERA1 grantees whose awards have a period of performance ending September 30, 2022. It says grantees may not close out before the end of the period of performance, that funds received through reallocation are subject to a 90-day extension with closeout deferred until after December 29, 2022, and that Treasury will use the Uniform Guidance for closeout and administrative closeout if final reporting is not completed. It gives a timeline in which Group A grantees' final report to Treasury is due January 30, 2023 and Group B grantees' is due April 28, 2023. These are Treasury's own guidance statements.
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“Emergency Rental Assistance (ERA1): Closeout Resource (Treasury, September 16, 2022).”
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U.S. Department of Treasury
Emergency Rental Assistance (ERA1): Closeout Resource
September 16, 2022
The following information is to be used as a resource ERA1 grantees (“grantees”) for the
upcoming closeout of Emergency Rental Assistance (ERA1) awards that have a period of
performance that ends on September 30, 2022.1 Section I of this document details closeout
information and resources, while Section II provides additional guidance and reminders for
grantees’ compliance with the ERA1 award Terms and Conditions they accepted in connection
with their ERA1 award. Grantees are advised to monitor the ERA Guidance page on Treasury’s
website for additional compliance resources.
I. Closeout Overview
A. Basic Closeout Requirements
• Closeout must occur after the end of the award period of performance (also called the end
of the award term) to ensure collection of robust, and complete reporting data from all
grantees. Grantees may not close out their ERA1 awards before the end of the award
period of performance on September 30, 2022.
• ERA1 funds received through reallocation are subject to a 90-day extension of the
availability of such funds. Grantees that received reallocated funds may elect to begin
closeout after September 30, 2022 or to defer closeout until after December 29, 2022.
• After a grantee has completed its final reporting requirements, Treasury will implement
closeout procedures consistent with the applicable provisions in the Uniform
Administrative Requirements, Cost Principles, and Audit Requirements for Federal
Awards, 2 CFR Part 200 (Uniform Guidance), particularly, 2 CFR 200.344, 200.345, and
200.346.
• If a grantee fails to complete its final reporting requirements in accordance with 2 CFR
200.344, which is incorporated by reference in the terms and conditions of the ERA1
award, Treasury will move forward with administrative closeout in accordance with the
Uniform Guidance.
B. Closeout Timeline
A summary of the closeout timeline for ERA1 awards appears below. Upon the completion of
closeout actions and resolution of any outstanding matters regarding a particular grantee,
Treasury will inform each grantee that its award has been closed out and that no further action is
required (subject to terms and conditions of the award that extend beyond the closeout period,
1
The period of performance for ERA1 Award funds received through reallocation ends on December 29, 2022,
pursuant to a 90-day extension of the availability of reallocated award funds that Treasury granted on July 29, 2022.
Treasury anticipates granting a further 90-day extension for all reallocation requests submitted since that date.
ERA1 Program Closeout Resource
such as, record retention requirements, and compliance-monitoring, and if applicable, resolution
of audit findings after award closeout).
Closeout deadlines vary for (Group A) grantees that received ERA1 award funds only pursuant
to their initial allocations—which may include redirected2 award funds, as applicable—and
(Group B) grantees that received reallocated ERA1 award funds, whether through general
reallocation or directed voluntary reallocation.
Note: Grantees may submit the ERA1 Final Report any time after the end of the award period of
performance (September 30, 2022), before the Final Report due date, and after Treasury
launches the Final Report on Treasury’s Portal.
Group A: Any grantee that received ERA1 award funds only pursuant to its initial allocation
(including redirected funds)
Deadline Description End/Due Date
Period of performance: September 30, 2022
Regular quarterly reports to Treasury:
• Quarter 3 2022: October 17, 2022
(covering 7/1/2022-9/30/2022)
Final Report due:
• Subrecipient final report data to grantee December 29, 2022
(monitored by grantee)
• Grantee Final Report to Treasury January 30, 2023
Group B: Any grantee that received reallocated ERA1 award funds
Deadline Description End/Due Date
Period of performance:
• Initially allocated funds September 30, 2022
• Reallocated funds December 29, 2022
Regular quarterly reports to Treasury:
• Quarter 3 2022 October 17, 2022
(covering 7/1/2022-9/30/2022)
• Quarter 4 2022: January 17, 2023
(covering 10/1/2022-12/29/2022, if
applicable)
Final Report due:
• Subrecipient final report data to grantee March 29, 2023
(monitored by grantee)
• Grantee Final Report to Treasury April 28, 2023
2
Redirected funds are ERA1 award funds that would have been part of a grantee’s total allocation but for another
in-state grantee’s option to participate in ERA1. If the second grantee ultimately declines to participate, the funds
are “redirected” to the first grantee’s ERA1 allocation and become part of that grantee’s initial ERA1 allocation.
Redirected funds are thus distinct from, and should not be confused with, reallocated funds.
2
ERA1 Program Closeout Resource
After the submission (or submission deadline) of the grantees’ Final Report, Treasury will
implement a closeout review of ERA1 awards, which may include:
• Requesting verification of closeout information from grantees
• Sending repayment instructions to grantees
• Engaging grantees to resolve any issues found in their Final Report
• Initiating or furthering applicable remediation actions
For each of these activities, Treasury will communicate specific instructions and deadlines to
grantees. Treasury may engage in further compliance activities, closeout-review, and
communication with grantees as needed and in alignment with applicable provisions of the
Uniform Guidance.
C. Closeout Activities
1. Allowable Operations
The end date of the award period of performance is the last day for a grantee to obligate funds
for ERA1 activities (September 30, 2022 for award funds received pursuant to the grantee’s
initial allocation and December 29, 2022 for reallocated funds). Funds statutorily available for
administrative costs are not considered to be “automatically” obligated; therefore, grantees must
obligate award funds by the end of the award period of performance to cover their administrative
costs for closeout activities. Obligated funds may be expended by grantees for up to 120
calendar days after the end of the award period of performance for allowable administrative
activities. Obligated funds may be expended by subrecipients for up to 90 calendar days after the
end of the award period of performance for allowable administrative activities or an earlier date
as agreed upon by subrecipient and grantee per 2 CFR 200.344(a).
• If a grantee has obligated funds for these purposes by the end of the award period of
performance, it may use the funds to cover the following allowable operational activities,
which is a non-exhaustive list of examples:
• Administrative expenses to support closeout activities (including administrative
support services and other direct and indirect expenses that support administrative
activities provided through staffing costs, subawards, contracts, etc.)
• Payment processing for approved ERA1 applicants (for rent, utilities, or other
allowable expenses incurred prior to the end of the award period of performance, but
not prospective expenses that will be incurred for program services past the end of the
award period of performance)
• Payment processing for housing stability services that occurred prior to the end of the
award period of performance
• Reconciliation of general ledger, accounting, reporting, bank reconciliation, etc.3
3
Treasury does not prohibit ERA grantees from recharacterizing expenditures initially reported under one award as
ultimately being funded by the other (between ERA1 and ERA2 awards), provided the grantee updates all relevant
program reports to reflect the recharacterization and complies with all applicable requirements set forth in the ERA1
3
ERA1 Program Closeout Resource
• Continued internal auditing of approved applications for potential duplication of
benefits and associated remedial activities, as appropriate4
• Single Audits or program-specific audits required per 2 CFR 200 Subpart F, Audit
Requirements, if applicable
• Review and reconciliation of program policies, procedures, and controls to prevent
fraud (see ERA Frequently Asked Questions (FAQ), e.g. FAQ 1)
• Documentation, assessment, and retention activities
• Data security measures and continued protection of personally identifiable
information5
• Self-auditing of policies and procedures
• Follow-up with end-beneficiaries (tenants, landlords, and utility companies) to
reconcile documentation, as needed
• The following operational activities are prohibited after the end of the applicable period of
performance:
• New obligations of funds to support administrative activities
• Assessment of applicant eligibility for ERA1 services
• Providing housing stability services to households
• Expenditures on prospective rent or other prospective financial assistance
2. Regular Quarterly Reports
ERA1 grantees whose award period of performance ends on September 30, 2022 are required to
submit all quarterly reports from Q1 2021 through Q3 2022 through Treasury’s reporting Portal.
In addition, grantees that obligate or expend reallocated funds between October 1, 2022 and
December 29, 2022 must submit a quarterly report covering the fourth quarter of 2022.
Note: Treasury’s compliance team will concurrently continue to test the completeness and
accuracy of past ERA1 reports. Grantees may receive additional communications from the
and ERA2 statutes, the Uniform Guidance, the ERA1 Award Terms and ERA2 Award Terms, Treasury’s ERA
program guidance, and other applicable requirements, including the grantee’s own internal accounting policies and
internal controls. Whether to characterize an eligible expenditure as drawing on funds from a grantee’s ERA1 award
or ERA2 award is generally determined by the grantee and must be in accordance with requirements set forth in 2
C.F.R. 200.302-200.303 (regarding financial management and internal controls) and 200.403-200.405 (regarding the
allowability, reasonableness, and allocation of program costs). Note the statutes authorizing the ERA1 and ERA2
programs have requirements that differ in certain respects, including applicant eligibility requirements, thresholds
for administrative expenses, and permissible uses of program funds. Please be mindful that program financial
reporting must be updated should a grantee choose to recharacterize the allocation of expenditures between its
ERA1 and ERA2 awards. Grantees may contact Treasury at EmergencyRentalAssistance@treasury.gov with any
questions about updating submitted data.
4
See FAQ 45 for more information regarding duplication and recharacterizing of assistance.
5
The statute establishing the ERA1 program requires grantees to establish data privacy and security requirements
for certain information regarding applicants that (i) include appropriate measures to ensure that the privacy of the
individuals and households is protected; (ii) provide that the information, including any personally identifiable
information, is collected and used only for the purpose of submitting reports to Treasury; and (iii) provide
confidentiality protections for data collected about any individuals who are survivors of intimate partner violence,
sexual assault, or stalking. See FAQ 14.
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compliance team to correct past reports over course of the closeout period.
3. Final Report
Grantees must submit a Final Report with cumulative financial and performance information.
Treasury’s Portal can also offer grantees the flexibility to revise the financial data for past
quarterly reports.
• Key considerations/questions: The following considerations and questions can help support
an accurate report and clear communications as grantees work through the closeout process:
• Grantees must obligate sufficient ERA1 grant funds by the end of the award period of
performance to support anticipated closeout activities. Grantees may not obligate
ERA1 grant funds for the provision of financial assistance or housing stability
services after the end of the award period of performance.
• Grantees should review whether their reported numbers fall within statutory limits.
▪ Does the total amount expended on administrative expenses fall within the
statutory limit and guidelines?6
▪ Does the total amount expended on housing stability services fall within the
statutory limit and guidelines?7
Note: Contact EmergencyRentalAssistance@treasury.gov with concerns about funds
falling within the statutory limits due to reallocation.
• Grantees should confirm that all reports, including the Final Report, accurately reflect
the grantee's aggregate financial and programmatic data throughout the award period
of performance? Grantees should check:
▪ Whether total expenditures and obligations align with the total (net) award.
▪ Whether there are any unobligated balances by the end of the award term or
unliquidated obligations by the end of the closeout period. If yes, see section
below on Repayment of ERA1 funds.
▪ The completeness and accuracy of the project data and participant
demographics, as submitted in the Final Report and Quarterly Reports.
▪ Submittal of a final cumulative Participant Household Payment Data File
(PHPDF)
Note: as per the ERA Reporting Guidance, Tribes, Tribally designated housing
entities, and the Department of Hawaiian Home Lands are required to complete only
specific sections of the Quarterly Report form.
• Grantees must submit the Final Report via Treasury’s Portal.
• Following the submission of the Final Report:
• Treasury will review the submitted reports. If a report requires revision, Treasury will
request revisions and resubmission from the grantee.
6
For information on statutory limits and guidelines for administrative expenses see ERA1 statute (CAA 501(c)(5));
ERA1 Reallocation Guidance (especially “Use of Funds for Administrative Expenses and Housing Stability
Services” at section V); and other Treasury program guidance (e.g., FAQ 29)
7
For the statutory limit and guidelines on housing stability services see ERA1 statute (CAA 501(c)(3)) and
Treasury’s ERA guidance (e.g., FAQ 23 & FAQ 29)
5
ERA1 Program Closeout Resource
• If the grantee fails to submit the Final Report, Treasury will implement
administrative closeout in accordance with 2 CFR 200.344(h) of the Uniform
Guidance and the grantee will be deemed noncompliant with the ERA1 Award
Terms, as applicable.
• If a grantee does not resolve outstanding reporting issues, Treasury will provide a
formal opportunity to remedy the noncompliance prior to the grantee being found
noncompliant with the Award Terms.
4. Repayment of ERA1 Funds
• Under certain circumstances, Treasury may accept the return of ERA1 award funds on a
voluntary basis, prior to the end of the award period of performance, to reallocate those funds
to other grantees to support communities in need of additional funds for rental assistance and
housing stability services. For more information, please contact
EmergencyRentalAssistance@treasury.gov.
• Following receipt of the grantee’s Final Report, Treasury will also send repayment
instructions and deadlines for previously obligated funds that were not fully expended by the
grantee by the end of the closeout period.
• Note that Treasury’s ERA1 payments to states, territories, and the District of
Columbia are not subject to the requirement to remit interest to Treasury under the
Cash Management Improvement Act and Treasury’s implementing regulations at 31
CFR part 205. Treasury’s ERA1 payments to local governments, Tribes, and Tribally
designated housing entities are not subject to the requirements of 2 CFR
200.305(b)(8)-(9) to maintain balances in an interest-bearing account and remit
payments to Treasury (see FAQ #24).
• If a grantee owes money to Treasury due to excess funds, penalties, improper use of funds, or
other non-compliance, Treasury will send repayment instructions and deadlines, as
appropriate.
• If Treasury determines that a grantee is not in compliance with repayment instructions,
Treasury may put a “financial hold” on the grantee, which could result in withholding of
payment of remaining allocations of awards under other Treasury programs. Treasury may
also refer the grantee, as appropriate, for further remediation, including to the Office of the
Inspector General for recoupment of funds.
6
ERA1 Program Closeout Resource
II. Internal Controls and Compliance Reminders
While the following requirements are not specific to program closeout, grantees must continue to
comply with these requirements as they carry out closeout activities for their ERA1 awards. The
following is a non-exhaustive list of internal controls and compliance requirements for Federal
awards.
A. Financial Management
Each grantee must expend and account for its ERA1 award in accordance with state laws and
procedures for expending and accounting for its own funds (except insofar as such state laws are
superseded by applicable federal requirements). In addition, the grantee and its subrecipients,
and contractors’ financial management systems, including records documenting compliance with
Federal statutes, regulations, and the terms and conditions of the ERA1 award, must be sufficient
to permit the preparation of reports required by general and program-specific terms and
conditions; and the tracing of funds to a level of expenditures adequate to establish that such
funds have been used according to the Federal statutes, regulations, and the terms and conditions
applicable to the ERA1 award. For more information, see 2 CFR 200.302 Financial management.
B. Records Retention & Documentation
Per the ERA 1 Award Terms, financial records, supporting documents, statistical records, and all
other non-Federal entity records pertinent to the ERA1 award must be retained for a period of
five years after all funds have been expended or returned to Treasury.8
1. Policies and Procedures Documentation
While Treasury will not require all grantees to submit policy and procedure documentation as
part of the closeout process, it is a best practice to review and reconcile program policies and
procedures as part of the closeout process. Among other benefits, this work can support grantees
with program audits and provide legacy documentation to inform any future emergency rental
assistance programming.
• Alignment with ERA1 statutory and regulatory requirements:
ERA1 programs must abide by all applicable laws, regulations, guidance, and procedures,
including the grantee’s own internal accounting policies and internal controls; the Uniform
Guidance, including 2 C.F.R. 200.302-200.303 (regarding financial management and internal
controls) and 200.403-200.405 (regarding the allowability, reasonableness, and allocation of
program costs); and the statutory requirements set forth in section 501 of Division N of the
Consolidated Appropriations Act, 2021, Pub. L. No. 116-260 (Dec. 27, 2020).
8
Please note that 2 CFR 200.334 provides that pass-through entities that receive federal awards must not impose any
other record retention requirements on non-Federal entities, except if any litigation, claim, or audit is started before
the expiration of the five-year period. In such case, the records must be retained until all litigation, claims, or audit
findings involving the records have been resolved and final action taken.
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ERA1 Program Closeout Resource
• Alignment with the Treasury’s FAQs and supplemental guidance:
Treasury has provided FAQs as ERA1 program guidance in addition to supplemental
guidance provided to grantees through email notifications, notices posted on Treasury’s ERA
website, the ERA1 Reallocation Guidance, the ERA Guidance webpage, the ERA Award
Term webpage, and the ERA Reporting webpage.
The preamble to Treasury’s FAQs states that “grantees must establish policies and
procedures to govern the implementation of their ERA programs consistent with the statutes
and these FAQs. To the extent that these FAQs do not provide specific guidance on a
particular issue, a grantee should establish its own policy or procedure that is consistent with
the statutes and follow it consistently.”
Grantees should review their policies and procedures against Treasury’s most recently
published FAQs for the ERA programs and document alignment to these resources. Treasury
has also provided information about past iterations of the FAQs in the FAQ Change Log,
which grantees may use to support documenting changes in policy guidance over time.
See Appendix B for a non-exhaustive list of FAQs that refer to various documentation
requirements, administrative flexibilities, and program integrity measures
• Reference to “Promising Practices” and “Program Service and Design” Resources:
Treasury’s resources provided through Promising Practices and Program Service and Design
can also serve as illustrations that grantees might have considered when developing their
program policies and infrastructure, though all such policy development must proceed in
accordance with the governing legal authorities and published policy guidance. Reference to
these resources should not be construed as (i) altering these requirements or (ii) confirming
that any specific grantee’s program policies or administrative practices have been fully
reviewed and found compliant.
2. Documentation of Compliance with Federal Civil Rights Statutes and
Regulations:
Grantees are required to comply with federal civil rights statutes and regulations, including Title
VI of the Civil Rights Act of 1964, Section 504 of the Rehabilitation Act of 1973, the Age
Discrimination Act of 1975, and the Fair Housing Act (Title VIII of the Civil Rights Act of
1968) as outlined in the ERA1 Award Terms accepted by the grantees in connection with their
ERA1 awards. Note: Treasury does not impose nondiscrimination requirements on Tribal
governments beyond what would otherwise apply under federal law.
Information about the grantees’ civil rights obligations can be found in the Treasury Civil Rights
Toolkit. Treasury’s FAQ 37 notes that grantees must provide meaningful access to the program
for limited English proficient (LEP) individuals. Additional information about the LEP language
requirements is found in the Treasury Guidance to Federal Financial Assistance Recipients
Regarding Title VI Prohibition Against National Origin Discrimination Affecting Limited
English Proficient Persons.
8
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C. Audit Requirements
Thoughtful and thorough work related to award closeout can help support an accurate and
effective audit. Audit activities may fall outside of the timeliness associated with closeout
activities. However, grantees may use ERA1 award funds towards audit costs in accordance with
2 CFR 200.425, as long as the costs are obligated before the end of the award period of
performance and expended within 120 calendar days (or 90 calendar days in the case of
subrecipients) after the period of performance per 2 CFR 200.344(a).
Detailed information can be found in 2 CFR Part 200, Subpart F, Audit Requirements. Here is
some basic information auditee responsibilities (2 CFR 200.508) to help grantees plan:
• Grantees that expend $750K or more from all federal awards received within their fiscal
year are required to undergo either a single audit or program-specific audit at the end of
each fiscal year.
• Grantees are responsible for procuring or otherwise arranging for audits and ensuring the
auditor has the necessary experience to perform this type of audit in accordance with 2
CFR 200.509.
o Information with instructions for how auditors must perform these audits can be
found at 2 CFR 200.514-200.520 and in the ERA 2022 Compliance Supplement
published by the Office of Management and Budget.
o Grantees are advised to continue to check the ERA Guidance page on Treasury’s
website for additional compliance resources, e.g., 2022 ERA Compliance
Supplement and Compliance Supplements issued for subsequent fiscal years.
• Grantees must prepare their financial statements and other materials required by their
auditors to perform their audits and provide the auditors with all necessary
documentation (e.g., records).
• Grantees are expected to take prompt corrective action following any audit findings.
• Grantees must submit and certify their single audit reports to Federal Audit
Clearinghouse “within the earlier of 30 calendar days after receipt of an auditor’s
report(s), or nine months after the end of the audit period” per 2 CFR 200.512(a)(1). The
audit period is a grantee’s fiscal year.
• Grantees with audit findings must work with Treasury, as appropriate, to resolve those
findings.
D. Reporting Waste, Fraud, or Abuse
The Office of Inspector General offers the following guidance, which is also available at: Report
Fraud, Waste, and Abuse | Office of Inspector General (treasury.gov)
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Emergency Rental Assistance (ERA) - In addition to filing a complaint with our office, we
strongly recommend you also report ERA fraud to the local agency responsible for disbursing
Rental Assistance funds (the entity who accepts and processes ERA applications for rental
assistance) or the District of Columbia, Tribe, Tribally Designated Housing Entity (TDHE),
Department of Hawaiian Home Lands (DHHL), State, Local government, or Territorial Agency
that oversees the program. That agency may be able to take immediate action regarding the issue
or redirect funds appropriately.
Please be aware that local law enforcement is a valuable resource for many issues of the
type you may also refer to this Office. Local law enforcement may offer advantages such as
the ability to interact quickly with the community, prosecute criminal offenses, and often has
comprehensive victim, witness, and social services support programs which may better offer
real-time assistance. Your State, Local, Tribal, Territorial or DC law enforcement agency with
primary law enforcement jurisdiction is usually the same agency that responds to 911 calls.
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APPENDIX A: Definitions
Administrative closeout occurs when a non-federal entity does not submit all reports in
accordance with the terms and conditions of the federal award, and other statutory and regulatory
requirements.
Closeout refers to the process by which the federal awarding agency or pass-through entity
determines that all applicable administrative actions and all required work of the federal award
have been completed and takes actions as described in 2 CFR 200.344.
Federal financial assistance means assistance that non-Federal entities receive or administer in
the form of: (1) Grants; (2) Cooperative agreements; (3) Non-cash contributions or donations of
property (including donated surplus property); (4) Direct appropriations; (5) Food commodities;
and (6) Other financial assistance (except assistance listed in paragraph (2) of this definition). It
may also include assistance that non-federal entities receive or administer in the form of: (1)
Loans; (2) Loan Guarantees; (3) Interest subsidies; and (4) Insurance.
Financial Closeout refers to the review of an unliquidated obligation to determine whether that
amount will be de-obligated because it will not be paid against.
Grantees/recipients means states, the District of Columbia, U.S. territories, Indian tribes,
Tribally designated housing entities, the Department of Hawaiian Homelands, and units of local
government that participated in the Emergency Rental Assistance program under the
Consolidated Appropriations Act, 2021. In the case of this document, "recipient" and "grantee"
may be used interchangeably. These terms do not include subrecipients or beneficiaries of the
award.
Non-Federal entity means a State, local government, Indian Tribe, Institution of Higher
Education, or nonprofit organization that carries out a federal award as a recipient or
subrecipient.
Period of performance means the total estimated time interval between the start of an initial
federal award and the planned end date, which may include one or more funded portions, or
budget periods.
Post-close adjustment describes activities that occur after a federal awarding agency closes out
an award. These activities include: (1) The right of the federal awarding agency or pass-through
entity to disallow costs and recover funds on the basis of a later audit or other review; (2) The
requirement for the non-federal entity to return any funds due as a result of later refunds,
corrections, or other transactions including final indirect cost rate adjustments; (3) The ability of
the federal awarding agency to make financial adjustments to a previously closed award such as
resolving indirect cost payments and making final payments; (4) Audit requirements; (5)
Property management and disposition requirements; and (6) Record retention requirements.
Remediation actions refer to activities pursued to correct recipient material noncompliance with
statutes, regulations, or the terms and conditions of their award agreement.
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Subrecipient means an entity, usually but not limited to non-federal entities, that receives a
subaward from a pass-through entity to carry out part of a federal award; but does not include an
individual that is a beneficiary of such award. A subrecipient may also be a recipient of other
federal awards directly from a federal awarding agency.
Unliquidated Obligations means the amount of funds that have been obligated under a federal
award but not paid.
Unobligated balance means the amount of funds under a federal award that the non-federal
entity has not obligated.
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APPENDIX B: Highlighted FAQs referencing Documentation Requirements and Controls
This list is non-exhaustive. See FAQ webpage for full list of FAQs and language.
Applicant eligibility requirements:
• Establishing and documenting eligibility; implementing controls to support compliance
and fraud prevention: FAQ#1
• Financial hardship due to the COVID-19 pandemic; use of self-attestation: FAQ #2
• Risk of experiencing homelessness or housing instability; use of self-attestation: FAQ #3
• Income eligibility; use of self-attestation, categorical eligibility, and fact-specific proxies:
FAQ #4
• Imposing additional eligibility criteria: FAQ #44
• Prioritization of applications: FAQ #22
• Tribal members and Tribal lands: FAQ#16 and FAQ #17
Expenditure requirements:
• Limitations on financial assistance: FAQ #10 and FAQ #11
• Documentation of rental residence, rent, and rental arears; written attestation: FAQ #5
o Landlord outreach requirements: FAQ #12
o Additional payments to landlords: FAQ #41
o Preventing evictions during period covered by ERA assistance: FAQ #32
o Vacated units: FAQ #40
• Utilities and home energy costs: FAQ #6 and FAQ #19
• Bulk payments to landlords/utility companies: FAQ #38
• Documenting “other expenses”: FAQ #7
o Security deposits: FAQ #39
• Other living situations:
o Displaced households living in hotels or motels: FAQ #26
o Rent-to-own agreements: FAQ #27
o Manufactured housing: FAQ #28
o Additional payments to landlords for “hard to house” populations: FAQ #41
o Relocation and tenants without a preexisting rental obligation: FAQ #35
• Option for tenants to apply directly for ERA assistance: FAQ #30
• Documentation that funds are used for permissible purposes: FAQ #31
• Housing stability services and eviction prevention: FAQ #23 and FAQ#36
• Administrative expenses: FAQ #29
o Use of contractors, subrecipients, or intergovernmental cooperation agreements:
FAQ #21
o Written agreements with other entities to support more efficient payments: FAQ
#42
Other: Data, Compliance, and Recoupment:
• Data collection requirements, including privacy and security requirements: FAQ #14
• Subsidized housing, civil rights, and fair housing: FAQ #15
• Title VI and Treasury’s Title VI implementing regulations at 31 CFR Part 22: FAQ #37
• Source-of-income protection laws: FAQ #43
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• Collaboration between ERA1 grantees: FAQ #33
• Recharacterizing duplicative payments: FAQ #45
• Interest earned on ERA payments: FAQ #24
• Recoupment: FAQ #25
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