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DEPARTMENT OF THE TREASURY
W ASHINGTON, D.C. 20220
OFFICE OF
INSPECTOR GENERAL
December 4, 2025
OIG-CA-26-006
MEMORANDUM FOR JEFFREY STOUT
ACTING CHIEF PROGRAM OFFICER
OFFICE OF CAPITAL ACCESS
From: Pauletta P. Battle /s/
Acting Assistant Inspector General for Audit
Subject: Termination Memorandum – Audits of the Department of the
Treasury’s Implementation of Pandemic Programs (Job
Codes: A-FA-20-039, A-FA-20-040, A-ER-21-039,
A-HA-21-045, A-SL-22-079, A-SL-22-002, A-SL-22-078,
A-SL-22-081)
In response to the Coronavirus Disease 2019 pandemic, Congress established
several programs assisting the public- and private-sectors to support recovery and
navigate the pandemic. Specifically, the Coronavirus Aid, Relief, and Economic
Security Act (CARES)1 designated funding for the Coronavirus Relief Fund (CRF)
and Air Carrier Worker Support (PSP); 2 the Consolidated Appropriations Act, 2021 3
designated funding for Emergency Rental Assistance (ERA)4 and Coronavirus
Economic Relief for Transportation Services (CERTS); and the American Rescue
Plan Act of 2021 5 designated funding for the Homeowner Assistance Fund (HAF),
Coronavirus State and Local Fiscal Recovery Funds (SLFRF), Capital Projects
Fund (CPF), and Local Assistance and Tribal Consistency Fund (LATCF). These
programs, created under the Department of the Treasury (Treasury), provided
assistance for public health emergencies and housing; enabling work, education,
and health monitoring; maintaining vital public services; promoting long-term
growth; and strengthening the national economy, among other purposes.
1
P.L. 116-136 (March 27, 2020)
2 The PSP program was extended twice under the Consolidated Appropriations Act, 2021, and the
American Rescue Plan Act of 2021. The PSP implementation audit focused on Treasury’s
administration of PSP under the CARES Act.
3
P.L. 116-260 (December 27, 2020)
4 The American Rescue Plan Act of 2021 established a second ERA program. The ERA
implementation audit focused on Treasury’s administration of ERA under the Consolidated
Appropriations Act, 2021.
5 P.L. 117-2 (March 11, 2021)
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Between March 2020 and July 2022, the Treasury Office of Inspector General
initiated eight audits related to pandemic programs: CRF, PSP, ERA, CERTS, HAF,
SLFRF, CPF, and LATCF. The overall objective of these audits was to assess
Treasury’s implementation activities to establish the pandemic programs, to include
policies, procedures, and relevant terms and conditions for providing assistance
under the programs. The scope of our audits included Treasury’s activities to
implement the pandemic programs.
To accomplish the overall objective of the audits, we (1) reviewed applicable laws,
regulations, and Treasury policies, procedures, guidance and instructions,
(2) interviewed key Treasury personnel and contractors involved with the various
pandemic programs, (3) conducted walkthroughs of Treasury systems to assess
Treasury’s administration of awards and payments, and/or (4) assessed internal
controls to determine whether programs were properly designed and implemented.
We found that Treasury established all eight pandemic programs and generally met
the statutory deadlines for distributing funds. Treasury also developed
program-related policies and procedures, but they were not always sufficient and
complete. For example, while Treasury developed compliance monitoring
procedures, for ERA, HAF, and SLFRF, those procedures were incomplete
throughout most of the programs’ periods of performance. 6, 7 In addition, we
identified concerns with the processes for evaluating application submissions to
provide awards or distributions of funds for the PSP, ERA, and CERTS programs.
During audit fieldwork, we communicated our concerns and preliminary
observations with appropriate Treasury personnel. 8 We also noted concerns related
to the pandemic programs in our annual management and performance challenges
letters issued to Treasury. 9
We are terminating these audits because Treasury’s pandemic programs have
reached or are approaching the end of their periods of performance. We have also
experienced resource constraints that prevent us from continuing this work.
6
Treasury provided updated policies and procedures covering compliance monitoring in
November 2024, when the periods of performance for most of the programs had ended.
7
The CARES Act assigned Treasury’s Office of Inspector General with the responsibility for
monitoring; oversight of the receipt, disbursement, and use; and recoupment authority over the
Coronavirus Relief Funds.
8
We did not identify any concerns related to the implementation of the Local Assistance and Tribal
Consistency Fund and the Capital Projects Fund.
9
Treasury OIG, Management and Performance Challenges Facing the Department of the Treasury,
OIG-CA-21-006 (October 29, 2020); OIG-CA-22-002 (October 14, 2021); OIG-CA-23-002
(October 14, 2022); OIG-CA-24-001 (October 10, 2023); and OIG-CA-25-003 (October 15,
2024).
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Although we are terminating the eight implementation audits, the concerns
identified in this memorandum and previously communicated to Treasury are
noteworthy and should be considered when establishing programs in the future. We
may follow up on the programs discussed in this memorandum. Please note that
the subject job codes will be removed from our Monthly Status Report.
We appreciate the courtesies and assistance provided by your staff. Should you
have any questions, please contact me at (202) 927-5400 or Julie Wong, Acting
Deputy Assistant Inspector General for Audit, at (202) 439-6354.
cc: Michelle Dickerman, Deputy Assistant General Counsel, Treasury Office of the
General Counsel