OIG Ca 25 041 Desk Review Of The State Of Wisconsin S Use Of Coronavirus Relief Fund Proceeds
Summary
A memorandum, OIG-CA-25-041, dated May 8, 2025, from the Department of the Treasury Office of Inspector General's Acting Assistant Inspector General for Audit to the Acting Chief Program Officer of Treasury's Office of Capital Access, reporting a desk review of the State of Wisconsin's use of Coronavirus Relief Fund proceeds. The review, begun February 14, 2023, examined Wisconsin's documentation for aggregate payments to individuals reported in the GrantSolutions portal. It states that Treasury issued a $1,997,294,786 CRF payment to Wisconsin, that reported API obligations and expenditures were $109,398,573, and that 143 transactions from 12 of 24 programs were selected. The memo finds the uses complied with the CARES Act and Treasury's Guidance, rates the risk of unallowable use as low, and states no audit will be conducted. Wisconsin concurred.
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
Full text
DEPARTMENT OF THE TREASURY
W ASHINGTON, D.C. 20220
OFFICE OF
INSPECTOR GENERAL
May 8, 2025
OIG-CA-25-041
MEMORANDUM FOR GREGORY TILL, ACTING CHIEF PROGRAM OFFICER,
OFFICE OF CAPITAL ACCESS, DEPARTMENT OF THE
TREASURY
FROM: Pauletta P. Battle /s/
Acting Assistant Inspector General for Audit
SUBJECT: Desk Review of the State of Wisconsin’s Use of
Coronavirus Relief Fund Proceeds
On February 14, 2023, we initiated a desk review of the State of Wisconsin’s
(Wisconsin) use of the Coronavirus Relief Fund (CRF) authorized under Title VI of
the Social Security Act, as amended by Title V Division A of the Coronavirus Aid,
Relief, and Economic Security Act (CARES Act). 1 The objective of our desk review
was to evaluate Wisconsin’s documentation supporting the uses of its CRF
proceeds for aggregate payments to individuals (API) as reported in the
GrantSolutions 2 portal and to assess the risk of unallowable use of funds. The
scope of our review included all obligation and expenditure data reported
quarterly in the GrantSolutions portal from March 1, 2020, through December 31,
2022 (cycles 1 through 11) and for the period of July 1, 2023, through September
30, 2023 (cycle 14).
As part of our desk review, we performed the following:
1) reviewed Wisconsin’s quarterly Financial Progress Reports (FPRs)
submitted in the GrantSolutions portal for cycles 1 through 11 and 14;
2) reviewed the Department of the Treasury’s (Treasury) Coronavirus Relief
Fund Guidance (Guidance) as published in the Federal Register on
January 15, 2021; 3
3) reviewed Treasury’s Office of Inspector General (OIG) Coronavirus Relief
1
P.L. 116-136 (March 27, 2020)
2
GrantSolutions, a grant and program management Federal shared service provider under the
U.S. Department of Health and Human Services which developed a customized and user-
friendly reporting solution to capture the use of CRF payments from recipients.
3
Coronavirus Relief Fund Guidance as published in the Federal Register (January 15, 2021)
https://home.treasury.gov/system/files/136/CRF-Guidance-Federal-Register_2021-00827.pdf
1
Fund Frequently Asked Questions Related to Reporting and
Recordkeeping (FAQs); 4
4) reviewed Treasury OIG’s monitoring checklists 5 of Wisconsin’s quarterly
FPR submissions for reporting deficiencies;
5) reviewed other issued audit reports, such as Single Audit 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 Wisconsin’s uses of CRF proceeds;
6) reviewed Treasury OIG Office of Investigations, the Council of the
Inspectors General on Integrity and Efficiency’s Pandemic Response
Accountability Committee (PRAC), 6 and Treasury OIG Office of Counsel
input on issues that may pose a risk or impact Wisconsin’s uses of CRF
proceeds;
7) interviewed key personnel responsible for preparing and certifying
the quarterly FPR submissions in Wisconsin’s GrantSolutions portal, as well
as officials responsible for obligating and expending CRF proceeds;
8) made a non-statistical selection of APIs 7 identified through GrantSolutions
reporting; and
9) evaluated documentation and records used to support Wisconsin’s
quarterly FPRs.
Based on the results of our desk review, Wisconsin’s documentation supporting
the uses of CRF proceeds complied with the CARES Act and Treasury’s Guidance.
Additionally, we determined that Wisconsin’s risk of unallowable use of funds is
low. As such, we will not be conducting an audit of Wisconsin.
4
Department of the Treasury Office of Inspector General Coronavirus Relief Fund Frequently
Asked Questions Related to Reporting and Recordkeeping (OIG-20-028R; March 2, 2021).
5
The checklists are used by Treasury OIG personnel to monitor the progress of prime recipient
reporting in the GrantSolutions portal. GrantSolutions quarterly submission reviews are
designed to identify material omissions and significant errors, and where necessary, include
procedures for notifying prime recipients of misreported data for timely correction. Treasury
OIG follows the CRF Prime Recipient Quarterly GrantSolutions Submissions Monitoring and
Review Procedures Guide to monitor the prime recipients quarterly (OIG-CA-20-029R; April 19,
2021).
6
Section 15010 of P.L. 116-136 established the Pandemic Response Accountability Committee
within the Council of the Inspectors General on Integrity and Efficiency to promote transparency
and conduct and support oversight of covered funds (see Footnote 11 for a definition 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
Obligations and expenditures for payments made to individuals, regardless of amount, are
required to be reported in the aggregate in the GrantSolutions portal to prevent inappropriate
disclosure of personally identifiable information.
2
Non-Statistical Transaction Selection Methodology
Treasury issued a $1,997,294,786 CRF payment to Wisconsin. As of September 30,
2023, Wisconsin’s cumulative obligations and expenditures for the API payment
type as reported in GrantSolutions for cycles 1-11 and subsequently cycle 14 was
$109,398,573.
We made a non-statistical selection of 143 transactions related to individuals
Wisconsin made payments to with its CRF proceeds. Selections were made using
auditor judgment based on (1) noticeable outliers; 8 (2) duplicate transactions; and
(3) transactions with the highest obligation/payment amounts.
These transactions were selected from 12 of 24 programs for which Wisconsin
reported API related expenditures. The 12 programs are listed below:
• Department of Administration – Federal Funds Team
• Department of Administration – Wisconsin Rental Assistance Program
Administration
• Department of Health Services – Direct Care Staff
• Department of Health Services – Federal Admin Leave
• Department of Health Services – Interchanged Staff
• Department of Public Instruction – State GEER Administration
• Department of Revenue – Agency Cost Tracker
• Department of Tourism – State Operations
• Department of Workforce Development – Unemployment Insurance
Administration
• University of Wisconsin – Higher Education
• University of Wisconsin – System (Madison) Testing
• University of Wisconsin – System Testing
Background
The CARES Act appropriated $150 billion to establish the CRF. Under the CRF,
Treasury made payments for specified uses to States; eligible units of certain local
governments; the District of Columbia; U.S. Territories, including the
Commonwealth of Puerto Rico, the United States Virgin Islands, Guam, American
Samoa, and the Commonwealth of the Northern Mariana Islands; and Tribal
governments. Treasury issued a CRF payment to Wisconsin for $1,997,294,786.
The CARES Act stipulates that a recipient may only use the funds to cover costs
that—
1) were necessary expenditures incurred due to the public health emergency
with respect to COVID-19;
8
Outliers include transactions (1) that did not align with the CARES Act criteria; (2) with
missing/inconsistent information; or (3) with obligations incurred outside of the period that
began on March 1, 2020, and ended on December 31, 2021.
3
2) were not accounted for in the budget most recently approved as of
March 27, 2020; and
3) were incurred between March 1, 2020, and December 31, 2021. 9
Section 15011 of the CARES Act required each covered recipient 10 to submit to
Treasury and the PRAC, no later than 10 days after the end of each calendar
quarter, a report that contained (1) the total amount of large covered funds 11,12
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 subcontracts or subgrants awarded by the
covered recipient or its subcontracts or subgrantees.
The CARES Act assigned Treasury OIG the responsibility for compliance
monitoring and oversight of the receipt, disbursement, and use of CRF proceeds.
Treasury OIG also has the authority to recoup funds if it is determined a recipient
failed to comply with the requirements of subsection 601(d) of the Social Security
Act, as amended by (42 U.S.C. 801(d)).
Desk Review Results
Our review of Wisconsin’s quarterly FPR submissions through September 30,
2023, found that FPR submissions were timely. Transactions selected for detailed
review were supported by documentation and were allowable expenditures in
accordance with the CARES Act and Treasury’s Guidance. We noted that the
tested API were necessary expenditures 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 of March 1, 2020, to
December 31, 2021. The transactions selected for testing were not selected
statistically, and therefore results cannot be extrapolated to the total universe of
transactions.
9
P.L. 116-260 (December 27, 2020). The period of performance end date of the CRF was
extended through December 31, 2021, by the Consolidated Appropriations Act, 2021.
10
Section 15011 of P.L. 116-136 defines a covered recipient as any entity that receives large
covered funds and includes any State, the District of Columbia, and any territory or possession
of the United States.
11
Section 15010 of P.L. 116-136 defines covered funds as any funds, including loans, that are
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.
12
Section 15011 of P.L. 116-136 defines large, covered funds as covered funds that amount to
more than $150,000.
4
Conclusion
Based on our review of Wisconsin’s documentation supporting the uses of CRF
proceeds as reported in the GrantSolutions portal, we determined that the
expenditures complied with the CARES Act and Treasury’s Guidance.
Additionally, we determined Wisconsin’s risk of unallowable use of funds was
low. As such, we will not be conducting an audit of Wisconsin.
State of Wisconsin Response
The State of Wisconsin concurred with our assessment. On April 30, 2025, the
State 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 Virginia Shirley, Acting Deputy Assistant
Inspector General for Audit, at (202) 246-0362.
Sincerely,
/s/
Pauletta P. Battle
Acting Assistant Inspector General for Audit
cc: Danielle R. Christensen, Deputy Chief Program Officer for State and Local
Programs, Office of Capital Access, Department of the Treasury
Michelle A. Dickerman, Deputy Assistant General Counsel, Department of the
Treasury
Anne Hanson, Deputy Secretary, Department of Administration, State of
Wisconsin
Colleen Holtan, Director, Bureau of Financial Management, Division of
13
https://www.ignet.gov/sites/default/files/files/Silver%20Book%20Revision%20-%208-20-12r.pdf
5
Enterprise Operations, Department of Administration, State of Wisconsin
Daniel Subach, Executive Policy and Budget Analyst, Division of Executive
Budget and Finance, Department of Administration, State of Wisconsin
6
Appendix
7
File and source
- File
- OIG-CA-25-041-desk-review-of-the-state-of-wisconsin-s-use-of-coronavirus-relief-fund-proceeds.pdf
- Size
- 344,361 bytes
- SHA-256
- 947a0db6690d19e2b9ee23e6f7be13abdb7b99b017e7a8dbe9d5edea2dacbab0
- Our copy
- OIG-CA-25-041-desk-review-of-the-state-of-wisconsin-s-use-of-coronavirus-relief-fund-proceeds.pdf
- Original
- oig.treasury.gov