OIG Ca 25 049 Desk Review Of The State Of Oregon S Use Of Coronavirus Relief Fund Proceeds
Summary
A Department of the Treasury Office of Inspector General memorandum, OIG-CA-25-049, dated May 30, 2025, reporting a desk review of the State of Oregon's use of Coronavirus Relief Fund (CRF) proceeds, addressed to the Acting Chief Program Officer of the Office of Capital Access and signed by Acting Assistant Inspector General for Audit Pauletta P. Battle. The review covered aggregate payments to individuals reported from March 1, 2020 through September 30, 2022 against a $1,388,506,837 CRF payment, testing 166 transactions. It finds Oregon's documentation complied with the CARES Act and Treasury's Guidance, rates the risk of unallowable use as low, and states no audit will be conducted. Under other matters, it reports $32,554 in unsupported questioned costs at the City of Lakeside, Oregon and recommends that amount be returned to Treasury.
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DEPARTMENT OF THE TREASURY
W ASHINGTON, D.C. 20220
OFFICE OF
INSPECTOR GENERAL
May 30, 2025
OIG-CA-25-049
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 Oregon’s Use of
Coronavirus Relief Fund Proceeds
On February 14, 2023, we initiated a desk review of the State of Oregon’s
(Oregon) 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 Oregon’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 (cycle 1), through September 30, 2022 (cycle 10).
As part of our desk review, we performed the following:
1) reviewed Oregon’s quarterly Financial Progress Reports (FPRs) submitted in
the GrantSolutions portal for cycles 1 through 10;
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
Fund Frequently Asked Questions Related to Reporting and
Recordkeeping (FAQs); 4
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, 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
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).
1
4) reviewed Treasury OIG’s monitoring checklists 5 of Oregon’s quarterly FPR
submissions for reporting deficiencies;
5) reviewed other audit reports issued, 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 risk or impact Oregon’s uses of CRF proceeds;
6) reviewed Treasury OIG Office of Investigations, the Council of the
Inspectors General on Integrity and Efficiency Pandemic Response
Accountability Committee (PRAC), 6 and Treasury OIG Office of Counsel input
on issues that may pose risk or impact Oregon’s uses of CRF proceeds;
7) interviewed key personnel responsible for preparing and certifying
the quarterly FPR submissions in Oregon’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 Oregon’s quarterly
FPRs.
Based on the results of our desk review, Oregon’s documentation supporting the
uses of CRF proceeds complied with the CARES Act and Treasury’s Guidance.
Additionally, we determined that Oregon’s risk of unallowable use of funds is low.
As such, we will not be conducting an audit of Oregon.
Non-Statistical Transaction Selection Methodology
Treasury issued a $1,388,506,837 CRF payment to Oregon. As of September 30,
2022, Oregon’s cumulative obligations and expenditures for the API payment type
as reported in GrantSolutions through Cycle 10 was $191,531,154.
We made a non-statistical selection of 132 transactions related to individuals
Oregon made payments to with its CRF proceeds. Selections were made using
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
auditor judgment based on (1) noticeable outliers; 8 (2) duplicate transactions; and
(3) transactions with the highest obligation/payment amounts. We identified
anomalies that resulted in the testing of 34 additional transactions, for a total of
166 transactions tested.
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 Oregon for $1,388,506,837. 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 the coronavirus disease 2019 (COVID-19);
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 subcontractors 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
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.
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.
3
also has authority to recoup funds in the event that it is determined a recipient
failed to comply with requirements of subsection 601(d) of the Social Security Act,
as amended, (42 U.S.C. 801(d)).
Desk Review Results
Our review of Oregon’s quarterly FPR submissions through September 30, 2022,
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.
Conclusion
Based on our review of Oregon’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 Oregon’s risk of unallowable use of funds is low. As such, we will
not be conducting an audit of Oregon.
Other Matters of Concern
We reviewed two complaints related to Oregon’s CRF payments. One complaint
was about CRF relevant findings identified in Oregon’s Statewide Single Audit
Report for Fiscal Year 2021. 13 We noted the issue was addressed and is currently
being handled through Treasury’s management decision process.
The second complaint was about CRF expenditures the State of Oregon provided to
a sub-recipient, the City of Lakeside, Oregon. The City of Lakeside, Oregon,
received $51,442.75 in grants from the State of Oregon for eligible CRF
expenditures. During our review, we found that the City of Lakeside, Oregon did
not comply with the CARES Act and Treasury’s Guidance as it failed to provide
adequate justification or supporting documentation for CRF expenditures, including
but not limited to payroll-related transactions, resulting in unsupported questioned
costs totaling $51,442.75. After our review, the City of Lakeside submitted
supporting documentation. We reviewed the newly submitted supporting
documentation and determined that $18,888.75 of the $51,442.75 in grant funds
the City of Lakeside received from the State of Oregon, were spent in accordance
with the CARES Act and Treasury’s Guidance. Accordingly, we reduced the total
13
Oregon Secretary of State, Statewide Single Audit Report for FY 2021 (Report 2022-18; July
2022) Statewide Single Audit for Fiscal Year 2021 (oregon.gov)
4
amount of unsupported questioned costs to $32,554. We recommend that the
Acting Chief Program Officer of the Treasury Office of Capital Access works with
the OIG to ensure that the State of Oregon returns to Treasury the $32,554 of CRF
proceeds that were used by the City of Lakeside, Oregon in violation of subsection
601(d) of the Social Security Act, as amended (42 U.S.C. 801(d)), as well as
Treasury’s Guidance and FAQs. To the extent funds are not returned, Treasury OIG
will seek recoupment under its authority assigned by the CARES Act.
******
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. 14 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
Attachment
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
George M. Naughton, Chief Financial Officer, State of Oregon
Kip Memmott, Senior Statewide Coordinator, State of Oregon
Robert W. Hamilton, CPA, State Controller, State of Oregon
Attachment
14
https://www.ignet.gov/sites/default/files/files/Silver%20Book%20Revision%20-%208-20-12r.pdf
5
Schedule of Monetary Benefits
According to the Code of Federal Regulations, 15 a questioned cost is a cost that is
questioned due to a finding:
(a) which resulted from a violation or possible violation of a statute,
regulation, or the terms and conditions of a Federal award, including for
funds used to match Federal funds;
(b) where the costs, at the time of the review, are not supported by
adequate documentation; or
(c) where the costs incurred appear unreasonable and do not reflect the
actions a prudent person would take in the circumstances.
Questioned costs are to be recorded in the Department of the Treasury’s (Treasury)
Joint Audit Management Enterprise System (JAMES). 16 The amount will also be
included in the Office of Inspector General (OIG) Semiannual Report to Congress. It
is Treasury management's responsibility to report to Congress on the status of the
agreed to recommendations with monetary benefits in accordance with 5 USC
405.
Recommendation Questioned Costs
Recommendation No. 1 $32,554
The questioned cost represents amounts provided by Treasury under the
Coronavirus Relief Fund. As discussed in the attached desk review, $32,554 is the
City of Lakeside’s total expenditures reported in the grant-reporting portal that
lacked supporting documentation.
15
2 CFR § 200.84 – Questioned Cost
16
JAMES is Treasury’s audit recommendation tracking system.
6
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