Increasing Transparency into COVID-19 Spending — Pandemic Response Accountability Committee (October 19, 2021)
Summary
This is a review by the Pandemic Response Accountability Committee (PRAC), Increasing Transparency into COVID-19 Spending, dated October 19, 2021, whose objective was to identify specific gaps in transparency in award data for federal assistance spending in response to COVID-19. It states that its review of award description data in USAspending.gov identified approximately 12,600 awards totaling approximately $11.6 billion where the award description simply matched the Assistance Listing name. It says COVID-19 funding is tracked at the prime recipient level but cannot be traced at the subrecipient level. It recommends that OMB, in coordination with the PRAC, offer resources to improve award descriptions and disseminate examples of insufficient ones, and states that OMB concurred.
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“Increasing Transparency into COVID-19 Spending — Pandemic Response Accountability Committee (October 19, 2021).”
Original at www.oversight.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/increasing-transparency-covid-19-spending10192021-2477fca802/
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PANDEMIC RESPONSE
ACCOUNTABILITY COMMITTEE
INCREASING
TRANSPARENCY
INTO COVID-19
SPENDING
OCTOBER 19, 2021
0
Background
In March 2020 the Coronavirus Aid, Relief, and $150,000. The CARES Act also contains
Economic Security (CARES) Act created the requirements for recipient reporting, similar to
Pandemic Response Accountability Committee those established during the American
(PRAC) to promote transparency and conduct Recovery and Reinvestment Act of 2009
and support oversight of pandemic-related (ARRA). Specifically, on a quarterly basis,
funds and the response to the Coronavirus recipients of awards over $150,000 (large
pandemic (COVID-19). covered funds) are required by statute to
report:
The objective of this review was to identify
specific gaps in transparency in award data for • The total amount of large covered funds
federal assistance spending in response to received from the agency;
COVID-19. We conducted the review in • The amount of large covered funds
accordance with the Quality Standards for received that were expended or
Inspection and Evaluation issued by the obligated for each project or activity;
Council of the Inspectors General on Integrity • A detailed list of all projects or activities
and Efficiency (CIGIE). for which large covered funds were
The CARES Act, the American Rescue Plan Act, expended or obligated, including the
and other related pandemic relief legislation name and description of the projects or
provided more than $5 trillion to support the activities;
nation’s response to COVID-19. Included in the • The estimated number of jobs created
legislation are numerous provisions designed or retained; and
to promote transparency and accountability in • Detailed information on any level of
pandemic spending. subcontracts or subgrants, to include
the data elements required to comply
Section 15010 of the CARES Act requires the with FFATA.
PRAC to maintain a public website
(PandemicOversight.gov) to provide—among Following passage of the CARES Act, the Office
other things—detailed data on any federal of Management and Budget (OMB) issued
government awards that expend covered Memorandum M-20-21, Implementation
funds 1 over $150,000. The reported data was Guidance for Supplemental Funding Provided
to include data elements required under the in Response to the Coronavirus Disease 2019
Federal Funding Accountability and (COVID-19). The guidance allows agencies and
Transparency Act of 2006 (FFATA), as recipients to meet the CARES Act reporting
amended by the Digital Accountability and requirements using the existing agency
Transparency Act (DATA Act), and data at the reporting processes under the FFATA and the
subgrant and subcontract level. DATA Act.
Section 15011 of the CARES Act requires The guidance also requires agencies to track
agencies to report on a monthly basis any COVID-19 relief spending by Disaster
obligations or expenditures of awards over Emergency Fund Codes (DEFC). OMB Memo M-
20-21 details the role of the DEFC code: “With
1 Section 15010(a)(6) of the CARES Act defines ‘‘covered an individual, under the CARES Act and other pandemic
funds’’ as any funds, including loans, that are made relief legislation.
available in any form to any non-Federal entity, not including
1
the inclusion of the DEFC attribute in agency The federal government provides a broad
DATA Act reporting, information on covered range of assistance to the American public in
funds will be available by obligation and various areas, such as education, health care,
expenditure at the award level so that the research, infrastructure, economic
American public will have insight into how development, and others—through grants,
COVID-19 relief funds were spent. This process loans, scholarships, insurance, and other types
provides low-burden transparency into how of financial assistance. Each assistance
COVID-19 relief funds have been distributed, program has a title and unique number, called
thus increasing accountability at multiple an Assistance Listing (previously called a
levels, and reducing the likelihood of waste, Catalog of Federal Domestic Assistance (CFDA)
fraud, and abuse, and provides a user-friendly Number), that follows the program throughout
mechanism for agencies and recipients to the lifecycle for data and funding transparency.
meet their financial reporting requirements For example, the Supplemental Nutrition
under sections 15010 and 15011 of the Act.” Assistance Program, operated by the U.S.
Department of Agriculture, is Assistance Listing
The OMB memo also stipulated that once
number 10.551. Additionally, FFATA and the
agencies have met these requirements, the
DATA Act require data reporting, based on the
information reported by agencies and
Assistance Listing number of the federal
recipients should be publicly available on
financial assistance, and this reporting is done
USAspending.gov.
through USAspending.gov.
USAspending.gov is the official source for
For transparency in pandemic spending,
spending data for the U.S. Government. In
USAspending.gov created a COVID-19
general, federal spending data flows to
Spending web page to capture the journey of
USAspending.gov based on the reporting
COVID-19 dollars from appropriation to
requirements in FFATA and the DATA Act. The
obligation and outlay by federal agencies,
DATA Act requires OMB and the U.S.
allowing users to see who received funding,
Department of the Treasury (Treasury), in
which agencies spent the funds, which
consultation with federal agencies, to establish
programs were funded, and more.
government-wide data standards that, to the
extent reasonable and practicable, produce The data submitted to USAspending.gov is
consistent, comparable, and searchable particularly important to achieving the CARES
spending data for any federal funds made Act transparency requirements. Foremost
available to or expended by federal agencies. among these is the award description field,
The DATA Act also requires OMB and Treasury which is designed to provide a plain language
to ensure that the standards are applied to the description of the purpose of the federal
data made available on USAspending.gov. assistance award.
2
Finding No. 1: Agencies Are Inconsistent in How They Interpret and Apply OMB
Guidance for Award Descriptions.
DATA REPORTED
• Recipient Name
• Award Description
• Place of Performance
• Awarding Agency
• ...
COVID AWARD
REPORTING
COVID FUNDS
AWARDED
Awarding Prime Subrecipients
Agencies Recipients
Figure 1 – Example of how COVID-19 funding flows from awarding agencies to prime recipients and to
subrecipients for federal assistance programs. With each award, the awarding agency (for prime awards)
and the prime recipient (for sub-awards) reports information regarding the purpose of the award, along
with other award details.
The PRAC found that agencies differ in how In this guidance, OMB states, “Award
they interpret and apply OMB guidance for the descriptions are distinct from the
award description field. As a result, data on programmatic level information provided in the
USAspending.gov are not always comparable, Assistance Listings and Federal awarding
and in many cases, users will have difficulty agencies are discouraged from including
understanding the purpose of an award based general programmatic level information in the
on the award description field. award description.” In other words, OMB is
reminding agencies to avoid re-using text from
In November 2020, OMB released OMB
other award data fields (such as the Assistance
Memorandum M-21-03, Improvements in
Listing field) in the award description field.
Federal Spending Transparency for Financial
Assistance, emphasizing the requirements that Our review of the award description data in
agencies: USAspending.gov for pandemic assistance
programs identified approximately 12,600
• develop award descriptions that avoid
awards totaling approximately $11.6 billion
acronyms or federal- or agency-specific
where the award description simply matched
terminology, and
the Assistance Listing name. In addition to
• include the purpose of the award along being non-complaint with OMB guidance, re-
with specific performance goals, using the Assistance Listing name in the award
indicators, milestones, or expected description field is both redundant and offers
outcomes, and intended beneficiary or no additional information regarding the intent
recipient of the funds. or purpose of each award. Of the 12,600
awards, more than 9,900 awards totaling
3
Poor Award Description
Child Care and Development
Good Award Description
Block Grant
Award ID: 2101TXCCC5
Education Stabilization Fund
“CCC5-2021”
Award ID: P425F202271
“Higher Education Emergency Relief
Fund for institutional cost related to Education Stabilization Fund
COVID-19 for expenses related to
moving education and services to Award ID: P425E201557
students to an online environment.”
“CARES”
Coronavirus Emergency
Supplemental Funding Program
Award ID: 2020VDBX0855
“COVID-19”
Figure 2 – An example of a COVID-19 award description that meets the OMB requirements compared to
poor award descriptions that use agency-specific jargon or only reference the legislation (e.g., CARES) or
COVID-19.
approximately $8.8 billion are from the U.S. award description “CCC5-2021.” We identified
Department of Housing and Urban a $300 million award from the Department of
Development (HUD). As an example, HUD has Transportation Federal Transit Formula Grants
more than 1,100 awards (totaling $2.1B) (Assistance Listing 20.507) with the award
within Assistance Listing 14.218, Community description “CRRSAA 2021.”
Development Block Grants/Entitlement Grants,
We identified more than 360 pandemic
all with the same award description of
assistance awards totaling more than $1.8
“Community Development Block
billion that include brief and non-descriptive
Grants/Entitlement Grants,” a verbatim match
award descriptions, such as “CARES,” “CARES
to the Assistance Listing title. When including
ACT,” or “COVID-19.”
all grants, loans, direct payments, and other
financial assistance awards, HUD has more Non-specific award descriptions prevent the
than 37,000 awards totaling approximately public, agency management, and policy makers
$11B in COVID assistance spending with award from determining the use of the federal
descriptions that are an exact or close match pandemic assistance. A lack of transparency
to the Assistance Listing name. We brought this also hampers oversight and accountability
preliminary finding to the attention of the Chief efforts.
Financial Officers Council and HUD leadership
These substandard entries were partially the
in March 2021 for further review.
result of the need to quickly award COVID-19
We also identified more than 2,450 awards assistance in the initial months of the
totaling approximately $19 billion in pandemic pandemic. These entries were also likely due to
assistance that include agency specific jargon a lack of continuous monitoring of government-
for award descriptions. For example, we wide agency submissions and the absence of
identified 276 Child Care and Development data governance processes that enforce the
Block Grants (Assistance Listing 93.575) consistent use of established standards and
totaling $9.8 billion from the U.S. Department guidelines. Without these processes,
of Health and Human Services (HHS) had the
4
preexisting challenges2 related to how This recommendation is resolved. To
agencies interpret and apply data standards close this recommendation, OMB will
were amplified by the pandemic. need to provide the PRAC evidence of
resources (training sessions, fact
During the ARRA reporting, recipient reporting
sheets, etc.) that support agency staff
included narrative data fields that provided
in addressing the quality of their award
details into the purpose of the award. These
descriptions to improve the quality of
data fields are not available for COVID-19
COVID-19 relief spending data reported
reporting. As a result, the award description
to USAspending.gov.
field is the lone remaining narrative field to
detail the purpose and intent of pandemic 2. OMB should develop and implement a
assistance spending. plan, leveraging its resources and in
coordination with the PRAC, to
We recognize that OMB has made efforts to
disseminate to individual agencies
enhance the quality of information in the award
examples of insufficient award
description field for pandemic assistance by
descriptions in need of remediation.
issuing guidance in Memo M-20-21 (April
2020), Memo M-21-03 (November 2020), and OMB Response and PRAC Evaluation:
Memo M-21-20 (March 2021), and Controller OMB concurred with the
Alert, Additional Instructions to Agencies for recommendation. OMB plans to
Contract Awards in Support of COVID-19 disseminate to agencies examples of
Response - Improve Clarity of Award & award descriptions that do not meet the
Modification Descriptions (August 2020). level of quality required in OMB policy.
OMB plans to complete planned actions
Recommendations: within the next year in coordination with
the PRAC.
1. OMB should, in coordination with the
PRAC, offer resources for agencies that This recommendation is resolved. To
focuses on improving the quality of close this recommendation, OMB will
award descriptions to result in need to provide the PRAC evidence that
consistent use and application of this OMB disseminated to each agency with
field across all agency submissions and COVID-19 relief award descriptions that
to provide clarity on the intent and do not meet OMB policy guidance
purpose of pandemic assistance. actions for improvement/remediation.
OMB Response and PRAC Evaluation: 3. OMB should engage with Congress to
OMB concurred with the consider legislating amendments to
recommendation. OMB plans to extend independent oversight of
develop resources to assist agencies in USAspending.gov data submissions,
addressing the quality of their including developing new requirements
descriptions. OMB plans to complete in consultation with CIGIE and the PRAC
planned actions within the next year in for the review of agency award
coordination with the PRAC. descriptions.
2 Government Accountability Office’s prior work on Federal Data Transparency: https://www.gao.gov/federal-data-transparency
5
OMB Response and PRAC Evaluation: This recommendation is resolved. To
OMB concurred with the close this recommendation, OMB will
recommendation. OMB plans to need to provide the PRAC evidence of
continue to work closely with PRAC and actions to initiate conversations and
Congress to ensure that PRAC and engage with Congress and/or key policy
CIGIE have the appropriate statutory stakeholders to consider legislative
mandates to conduct the proper amendments to extend independent
oversight of COVID-19 relief data. oversight of USAspending.gov data
submissions.
Finding No. 2: USAspending.gov Does Not Definitively Track COVID-19 Supplemental
Spending at the Subrecipient Level.
Figure 3 - COVID-19 funding is tracked at the prime recipient level; however, there is no way to trace COVID-
19 funding at the subrecipient level, which leads to a lack of transparency in how and where COVID-19
funding was used at the local level.
A large percentage of subrecipient 3 awards from this data which source funded a given
tracked on USAspending.gov can only be subaward.’
inferred to be COVID-19- related. This occurs
To determine how prevalent the issue is, the
because the prime recipient reporting the sub-
PRAC reviewed the top 100 grant Assistance
award information is not required—or able—to
Listings with the largest COVID-19 obligations.
identify the sub-award as COVID-19 funded
The PRAC discovered that 71 of the top 100
when the prime receives funds from multiple
Assistance Listings received funding from
appropriations/sources. USAspending.gov
multiple sources, thereby making it impossible
contains the following disclaimer: ‘If a prime
to definitively follow COVID-19 funding down to
award is funded by a combination of COVID-19
subrecipient awards. The CARES Act requires
supplemental appropriations and general
recipients to submit to agencies detailed
appropriations, there is no way to be certain
information on any level of subcontracts or
subgrants awarded by the covered (i.e., prime)
3 Covered, or pandemic-related funds, can also be spent by subrecipients—nonfederal entities that are awarded covered funding
through a legal instrument from the prime recipient to manage and support the performance of any portion of the substantive
project or program for which the prime recipient received the covered funding.
6
recipient or its subcontractors or subgrantees 4. misunderstanding of where and how the funds
Unlike prime award data submitted by federal were used.
agencies to USAspending.gov that use the
Not knowing this information could lead users
DEFC to track COVID-19 funding,
of USAspending.gov to inadvertently draw
USAspending.gov cannot display COVID-19
inaccurate conclusions from the data.
funding for subrecipients since it is not
reported.
Recommendation
Prime recipients submit their first-tier
sub-award data to the FFATA Subaward 4. OMB should conduct a feasibility study,
Reporting System (FSRS). The sub-award in coordination with relevant federal
information entered in FSRS is then displayed and non-federal stakeholders, as to
on USASpending.gov associated with the prime how to better track and report
award. However, FSRS does not have the subrecipient funding.
capability for prime award recipients to detail if OMB Response and PRAC Evaluation:
they used COVID-19 funding (i.e., a DEFC) when OMB concurred with the
reporting subrecipient awards. As a result, recommendation. OMB plans to
COVID-19 spending data for sub-awards is not conduct a feasibility study of how to
displayed on USAspending.gov. This means better track and report subrecipient
that the only way to know for certain if a spending and anticipates providing the
sub-award used COVID-19 funding is if the PRAC with better access to subrecipient
prime recipient only received COVID-19 funding data.
but not due to systemic tracking or reporting.
This recommendation is resolved. To
Without processes to definitively track close this recommendation, PRAC will
COVID-19 spending at the subrecipient level, need evidence that OMB initiated and
there is little transparency into how COVID-19 completed a feasibility study focused on
funding flows down to local projects. Moreover, improving the tracking and reporting of
the inability to track subrecipient spending for subrecipient spending presented on
many of the assistance programs leads to a USAspending.gov.
Finding No. 3: Populations of Pandemic Assistance Sub-Award Data Are Missing on
USAspending.gov.
LACK OF COVID
COVID AWARD AWARD REPORTING
REPORTING UNKNOWN/UNTRACKED
SUBRECIPIENTS
Figure 4 - Not all prime recipients
COVID FUNDS are reporting sub-award data to USAspending.gov,
UNCONFIRMED leading to questions as to
Subrecipients
whether there are a) no awards or b) awards do exist but AWARDED
AWARDED the prime
COVID FUNDSrecipient never reported the sub-award
Awarding Prime
data so it is not displayed on USAspending.gov.
Agencies Recipients
4 See CARES Act Section 15011.
7
Not all prime recipients are consistently Listing 84.425) that were not listed on
reporting subrecipient data, leading to USAspending.gov. However, information
questions as to whether there are (a) no such regarding these sub-awards was available for
awards or (b) awards do exist but the prime download on the California Department of
recipients never reported the sub-award data. Education website. We found at least two other
states (New York, Vermont) and the District of
We identified gaps in subrecipient reporting
Columbia that did not have any sub-awards
data by cross-referencing other authoritative
reported for the Education Stabilization Fund
sources of spending data, such as states’
on USAspending.gov as of May 2021, more
financial reports and federal and state agency
than 13 months after the enactment of the
websites. We found that, on average, only 59%
CARES Act (and obligation of the associated
of prime recipients are reporting any
COVID-19 supplemental funds). Sub-award
subrecipient data across the ten grant
data for each of these states and the District of
programs with the largest COVID-19
Columbia was updated in USAspending.gov in
obligations.
June 2021, after we brought this preliminary
The CARES Act requires agencies to submit finding to the attention of Chief Financial
detailed information on any level of Officers Council and OMB in March 2021;
subcontracts or subgrants awarded by the however, this reporting delay creates
covered recipient or its subcontractors or transparency concerns.
subgrantees. FFATA and the DATA Act require
We have determined that similar issues persist
that all data regarding sub-awards are
in other assistance programs. For example, the
disclosed in the same manner as data
State of Florida’s Comprehensive Annual
regarding other federal awards. Prime
Financial Report for FY2020 highlights the
recipients are required to self-report first-tier
state making more than 1,000 sub-awards
sub-award information in FSRS, however, there
totaling more than $1.2 billion for the U.S.
is minimal monitoring of the submissions by
Department of Homeland Security Disaster
the awarding agency.
Grants – Public Assistance (Presidentially
Furthermore, while limited data is Declared Disasters) program (Assistance
collected/reported for the first-tier sub-awards, Listing 97.036). None of these sub-awards are
no information is collected or reported at reported on USAspending.gov. Further analysis
subsequent second- to n-tier (third tier and shows that 55 states and territories received
beyond) sub-awards. awards as part of the Disaster Grants – Public
Assistance (Presidentially Declared Disasters)
This gap in reporting sub-award data was
program. However, only 37 states and
partially the result of the focus on awarding
territories are reporting any sub-award data.
assistance funds in OMB Memo M-20-21 which
The remaining 18 states and territories (such
stated that “time is of the essence” and
as Florida) are not reporting any sub-award
agencies should seek to balance mission
data, which means nothing is listed on
achievement, expediency, and transparency
USAspending.gov.
and accountability.
A lack of data is assumed as a lack of award(s).
During our review, for example, we identified
This is not always the case but due to the lack
more than 1,600 State of California sub-
of sub-award data, false assumptions are
awards for the U.S. Department of Education’s
likely. Furthermore, an incomplete
Education Stabilization Fund (Assistance
8
understanding of the impact of pandemic PRAC for the review of subrecipient
assistance programs leads to a lack of reporting.
transparency into the outcomes and objectives
OMB Response and PRAC Evaluation:
of the assistance program(s).
OMB concurred with the
As noted in Finding No. 2, the inability to track recommendation. OMB plans to
local (e.g., subrecipient) spending for many of continue to work closely with PRAC and
the assistance programs leads to a Congress to ensure that PRAC and
misunderstanding of where and how the funds CIGIE have the appropriate statutory
were used. mandates to conduct the proper
oversight of COVID-19 relief data.
Recommendation
This recommendation is resolved. To
5. OMB should engage with Congress to close this recommendation, OMB will
consider legislating amendments to need to provide the PRAC evidence of
extend independent oversight of actions to initiate conversations and
USAspending.gov data submissions, engage with Congress and/or key policy
including developing new requirements stakeholders to consider legislative
in consultation with the CIGIE and the amendments to extend independent
oversight of USAspending.gov data
submissions.
Other Matters: Delays in Updating or Omitting Key Data Elements on USAspending.gov
Could Lead Users to Draw Inaccurate Conclusions.
Outlay data not reported more than 19 USAspending.gov. Not knowing this information
months after the onset of the pandemic. could lead users of USAspending.gov to
Per OMB Memo 20-21, agencies were required inadvertently draw inaccurate conclusions from
to report outlay (or expenditure) data for the data.
pandemic funding beginning in June 2020.
Awards labeled “Unknown” create confusion
However, we discovered that some agencies
for users.
are not reporting any outlay data for COVID-19
As of July 2021, there are approximately 1,900
awards, more than 19 months after the onset
COVID-19 awards totaling more than $3.4
of the pandemic. The lack of outlay data 19
billion on USAspending.gov that are labeled
months into the pandemic means that there is
“unknown” and have no award information.
less transparency into how much has actually
These “unknown” awards are not tied to
been spent in response to the pandemic.
specific Assistance Listing(s), resulting in no
Although some agencies are reporting outlay transparency into what the funding is intended
data in their assistance submissions, other to support or achieve.
agencies are not providing data at all. Even
Subrecipient award data is reported in
within agencies, some Assistance Listings
USAspending.gov but is not tied to a specific
include outlay data, while others do not.
Assistance Listing.
Further compounding this issue, alerts or
As of April 2021, more than 24,000 sub-award
notices informing users about the potential
records within the Department of Education’s
lack of outlay data are not fully disclosed on
9
Education Stabilization Fund (Assistance or reported at subsequent n-tier sub-
Listing 84.425) had no information in the awards (second tier and beyond).
Assistance Listing field. As a result, these sub- 2. No information about jobs created or
awards are not presented on USAspending.gov retained by award.
when searching for the Education Stabilization Per OMB 20-21, agencies are not
Fund Assistance Listing. This is another required to collect and report data on
example of the difficulties in tracking sub- jobs created or retained as required by
awards, combined with the previously the CARES Act. Therefore, this data is
discussed issues around the inability to not available on USAspending.gov, as
definitively track COVID-19 sub-award funding required under the CARES Act.
and the significant populations omitting sub-
award data.
Additional Gaps Previously Identified
As identified in the November 2020 PRAC-
commissioned report, Transparency in
Pandemic-Related Spending: Report of
Alignment and Gaps, the following major data
gaps still exist in USAspending.gov although
the data is required by the CARES Act.
1. No Second- to N-tier award
information.
Data is collected for the first-tier sub-
awards, but no information is collected
10
Acronyms
ARRA American Recovery and Reinvestment Act of 2009
CARES Act Coronavirus Aid, Relief, and Economic Security Act
CFDA Catalog of Federal Domestic Assistance (recently retitled as Assistance Listing)
COVID-19 Coronavirus pandemic
CIGIE Council of the Inspectors General on Integrity and Efficiency
DAIMS DATA Act Information Model Schema
DATA Act Digital Accountability and Transparency Act
DEFC Disaster Emergency Fund Codes
FFATA Federal Funding Accountability and Transparency Act of 2006
FSRS FFATA Subaward Reporting System
FY Fiscal Year
HHS U.S. Department of Health and Human Services
HUD U.S. Department of Housing and Urban Development
OIG Office of Inspector General
OMB Office of Management and Budget
PRAC Pandemic Response Accountability Committee
Treasury U.S. Department of the Treasury
11
Appendix A: Summary of Poor COVID-19 Award Descriptions
Table 1: Examples of Award Descriptions That Match the Assistance Listing Name
Assistance Count of Award
Listing Description
Award Description Agency Number Occurrence COVID-19 Obligation
DEPARTMENT OF
EMERGENCY SOLUTIONS
HOUSING AND URBAN 14.231 354 $3,727,250,105
GRANT PROGRAM
DEVELOPMENT (HUD)
COMMUNITY DEVELOPMENT
BLOCK GRANTS/ENTITLEMENT HUD 14.218 1,104 $2,089,675,440
GRANTS
COMMUNITY DEVELOPMENT
BLOCK GRANTS/STATE'S
PROGRAM AND HUD 14.228 50 $2,085,916,492
NON-ENTITLEMENT GRANTS IN
HAWAII
DEPARTMENT OF
UNEMPLOYMENT INSURANCE 17.225 135 $1,143,687,844
LABOR
BLOCK GRANTS FOR DEPARTMENT OF
COMMUNITY MENTAL HEALTH HEALTH AND HUMAN 93.958 53 $813,323,457
SERVICES SERVICES (HHS)
PUBLIC AND INDIAN HOUSING HUD 14.850 6443 $684,547,081
EMERGENCY FOOD AND DEPARTMENT OF
SHELTER NATIONAL BOARD HOMELAND SECURITY 97.024 2 $310,000,000
PROGRAM (DHS)
HEAD START HHS 93.600 426 $123,590,593
INDIAN COMMUNITY
DEVELOPMENT BLOCK GRANT HUD 14.862 96 $99,100,000
PROGRAM
ASSISTANCE TO FIREFIGHTERS
DHS 97.044 1,608 $76,266,388
GRANT
EMERGENCY MANAGEMENT
DHS 97.042 33 $66,815,816
PERFORMANCE GRANTS
HOUSING OPPORTUNITIES FOR
HUD 14.241 205 $62,937,351
PERSONS WITH AIDS
12
TABLE 2: EXAMPLES OF AWARD DESCRIPTIONS USING AGENCY-SPECIFIC JARGON
Count of Award
Assistance Listing Description COVID-19
Award Description Agency Number Occurrence Obligation
DEPARTMENT OF
CCC5-2021 HEALTH AND HUMAN 93.575 276 $9,872,841,870
SERVICES (HHS)
CCC3-2020 HHS 93.575 275 $3,455,997,101
PHFE CDPH ELC
HHS 93.323 1 $2,251,104,897
2019-2024
CSC3-2020 HHS 93.569 111 $983,508,021
E5C3-2020 HHS 93.568 195 $899,998,456
HDC3-2020 HHS 93.045 56 $480,143,372
DEPARTMENT OF
CRRSAA 2021 20.507 1 $301,367,165
TRANSPORTATION
SSC3-2020 HHS 93.044 56 $199,856,628
HDC5-2021 HHS 93.045 56 $168,000,000
FCC3-2020 HHS 93.052 56 $100,000,000
2020 ILC3 –
HHS 93.432 352 $85,000,000
CARES
CWC3-2020 HHS 93.645 231 $44,897,402
FVC3-2020 HHS 93.671 188 $39,112,939
RADX-UP CDCC HHS 93.310 1 $27,816,167
DEPARTMENT OF
N/A 84.425 13 $22,009,561
EDUCATION
13
TABLE 3: EXAMPLES AWARD DESCRIPTIONS THAT REFERENCES TO CARES ACT, COVID-19, OR OTHER
SIMILAR TYPES OF ENTRIES
Assistance
Award Listing Award Description COVID-19
Description Agency Number Occurrence Count Obligation
CARES ACT DEPARTMENT OF
20.507 1 $817,487,351
FUNDING FY20 TRANSPORTATION (DOT)
DEPARTMENT OF EDUCATION
CARES ACT 84.425 65 $72,884,031
(ED)
CARES ACT DOT 20.507 3 $54,519,876
CARES ACT
OPERATING DOT 20.507 3 $123,776,765
ASSISTANCE
CARES ACT
ED 84.425 20 $72,964,845
FUNDING
CARES ACT
DOT 20.509 1 $359,675
FUNDING
FY 20 CARES ACT DOT 20.507 1 $61,307,439
CARES ACT 5311
DOT 20.509 1 $55,954,848
RURAL
RURAL AREA
DOT 20.509 1 $47,126,485
5311 CARES ACT
IADOT 5311
DOT 20.509 1 $42,820,959
CARES ACT
FY20 COVID-19
EMERGENCY ED 84.425 1 $31,448,178
GRANT
CARES ACT
ED 84.425 2 $30,476,999
RELIEF
2ND EMERGENCY
ED 84.425 1 $28,156,561
RELIEF FUND
CARES ACT
FUNDING – ED 84.425 3 $26,337,032
COVID-19
2020 CARES ACT DOT 20.507 1 $24,162,926
14
Appendix B: Subrecipient Data for the State of Florida in Florida’s
Comprehensive Annual Financial Report Compared to USAspending.gov for
Assistance Listing 97.036
15
Appendix C: OMB’s Response to the Draft Report
EXECUTIVE OFFICE OF THE PRESIDENT
OFFICE OF MANAGEMENT AND BUDGET
WASHINGTON, D.C. 20503
October 14, 2021
The Honorable Michael E. Horowitz
Chairman
Committee on Pandemic Response and Accountability
United States Senate
Washington, D.C. 20510-6250
Dear Mr. Chairman:
OMB provides this response on its actions related to the findings and recommendations
of the Pandemic Response and Accountability Committee (PRAC) in its report titled “Increasing
Transparency into COVID-19 Spending” pursuant to Section 15010 of the Coronavirus Aid
Relief and Economic Security (CARES) Act. In its final report, the PRAC provides three
findings and five recommendations to OMB to improve financial assistance spending
transparency. OMB generally agrees with the PRAC’s findings and recommendations. More
broadly, OMB appreciates the ongoing collaboration between OMB, the White House American
Rescue Plan (ARP) Implementation Team, and the PRAC to strengthen implementation to
deliver on pandemic relief programs provided by the Congress.
OMB remains committed to improving the quality of COVID-19 relief spending data
reported to USAspending.gov. OMB, in coordination with the PRAC, will continue to focus on
improving financial assistance award description and subaward data. Within the next year we
expect these efforts will include dissemination to agencies of examples of award descriptions
that do not meet the level of quality required in OMB policy (PRAC Recommendation 2), and
the development of resources to assist agencies in addressing the quality of their descriptions
going forward (PRAC Recommendation 1). Strengthening financial assistance award
descriptions has been an important implementation priority for OMB with regards to ARP
implementation. We also look forward to conducting a feasibility study of how to better track
and report subrecipient spending, and anticipate providing the PRAC with better access to
subrecipient data in order to facilitate our exchanges on that topic. (PRAC Recommendation 4).
Finally, OMB highly values the work of the PRAC and the Council of Inspectors General
on Integrity and Efficiency (CIGIE) in conducting independent oversight of the quality of
16
transparency reporting data, in particular with respect to award descriptions and subaward
reporting (PRAC Recommendations 3 and 5). OMB looks forward to continuing to engage with
the PRAC and Congress to ensure that the PRAC and CIGIE have the appropriate statutory
mandates to conduct needed oversight of these data.
Further, due to the high priority that OMB places on independent oversight of data
quality, and in accordance with the Single Audit Act Amendments of 1996, OMB updated the
Single Audit Compliance Supplement to require the review of recipient subaward reporting for
programs with COVID-19 spending in 2020, and for all programs as part of audits of fiscal years
ending after September 30, 2020. OMB anticipates this new requirement will allow agencies to
leverage insights from the Single Audits they receive to understand where further efforts on the
part of recipients to improve data quality may be needed.
OMB appreciates the efforts on the part of the PRAC to provide oversight and
accountability for transparency of federal spending in response to the COVID-19 pandemic, and
looks forward to continued engagement to advance these efforts.
If you have any questions, please contact OMB’s Office of Federal Financial
Management at 202-395-3993.
Sincerely,
Shalanda D. Young
Acting Director
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Appendix C: Scope and Methodology
The objective of this review was to identify specific transparency gaps in award data for federal
assistance spending in response to the Coronavirus Disease 2019 (COVID-19) pandemic. This review
was completed between March 2021 – August 2021.
To review federal assistance award data for COVID-19 spending, we used data from USAspending.gov’s
COVID-19 Spending web page. Data was originally downloaded from USAspending.gov in March, with
additional downloads in April, May, June, July and August 2021. The USAspending.gov COVID-19
Spending web page allows users to view spending data by Assistance Listing, along with total spending
by budget category, spending by recipient, spending by sub-agency, and other pre-set filters. For the
Assistance Listing award data, USAspending classifies the different federal assistance by grants, loans,
direct payments, and other financial assistance.
For this evaluation, we analyzed the award data across the ~250 different grant programs that received
COVID-19 funding. To view the metadata for all awards, we downloaded the USAspending.gov COVID-
19 download, which includes all data displayed on the USAspending.gov COVID-19 Spending web page
as well as many additional data elements. We then analyzed the award data to conduct our evaluation.
Key data elements we reviewed as part of the evaluation included:
- Award Description - Outlayed Amount Funded by COVID-19
- Recipient Name Supplementals
- Awarding Agency Name - Period of Performance, and
- CFDA Numbers and Titles - Other award data elements to examine
- COVID-19 Supplementals Funding the transparency of each award.
Obligations
In addition to data downloaded from USAspending.gov, where available, the PRAC reviewed federal
agencies’ websites, state agency websites, and other publicly available COVID-19 award data to
determine if additional award data exists beyond what is submitted to USAspending.gov. In addition,
the PRAC searched reports and audits published in the Federal Audit Clearinghouse
(https://facweb.census.gov/uploadpdf.aspx) to cross-reference data from these reports against data
posted on USAspending.gov.
This assessment is reliant on the quality of data made available on the USAspending.gov. The PRAC
did not alter or change any data downloaded from USAspending.gov in any capacity to conduct this
assessment.
We conducted this engagement in accordance with the Council of the Inspectors General on Integrity
and Efficiency’s Quality Standards for Inspection and Evaluation. Those standards require that we plan
and perform the engagement to obtain sufficient and appropriate evidence to provide a reasonable
basis for our conclusions and observations based on our objective. We believe that the evidence
obtained provided a reasonable basis for our conclusions and observations based on our evaluation
objective. We relied on computer-processed data to satisfy our evaluation objective. We relied on
previous audit work regarding the reliability of the computer-processed data we used and deemed the
data to be sufficiently reliable.
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PRAC Point of Contact
Brooke Holmes
Associate Director of Oversight and Accountability
Brooke.Holmes@cigie.gov
Visit Our Website at:
https://PandemicOversight.gov
Follow us social media:
@COVID_Oversight
REPORT FRAUD, WASTE, ABUSE, AND MISMANAGEMENT
To report allegations of fraud, waste, abuse, or misconduct regarding funds or
programs covered within the following Acts, please go to the PRAC website at
PandemicOversight.gov.
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