OIG Ca 26 028 Desk Review Of The State Of Michigan S Use Of Coronavirus Relief Fund Proceeds
Summary
A Department of the Treasury Office of Inspector General memorandum, OIG-CA-26-028, dated April 15, 2026, reporting a desk review of the State of Michigan's use of Coronavirus Relief Fund proceeds. It is addressed to the Acting Chief Program Officer of the Office of Capital Access and signed by Assistant Inspector General for Audit Pauletta P. Battle. The review covered aggregate payments to individuals reported from March 1, 2020 through December 31, 2022, and tested a non-statistical selection of 80 transactions from 4 of the 18 programs. The memorandum states Treasury issued Michigan $3,080,689,545 and that reported cumulative obligations and expenditures for that payment type were $1,036,217,349. It finds the expenditures complied with the CARES Act and Treasury's Guidance, rates the risk of unallowable use low, and states no audit will be conducted; Michigan 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
April 15, 2026
OIG-CA-26-028
MEMORANDUM FOR JEFFREY W. STOUT, ACTING CHIEF PROGRAM
OFFICER, OFFICE OF CAPITAL ACCESS, DEPARTMENT OF
THE TREASURY
FROM: Pauletta P. Battle /s/
Assistant Inspector General for Audit
SUBJECT: Desk Review of the State of Michigan’s
Use of Coronavirus Relief Fund Proceeds
On February 14, 2023, we initiated a desk review of the State of Michigan’s
(Michigan) use of its 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 review was
to evaluate Michigan’s documentation supporting the uses of its CRF proceeds for
aggregate payments to individuals (API) as reported in the GrantSolutions 2 portal
and 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 the period of March 1, 2020, through December 31, 2022 (cycles 1 through
11).
As part of our desk review, we performed the following:
1) reviewed Michigan’s quarterly Financial Progress Reports (FPRs) submitted in
the GrantSolutions portal through December 31, 2022, for cycles 1 through
11;
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
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
3) reviewed Treasury’s Office of Inspector General (OIG) Coronavirus Relief
Fund Frequently Asked Questions Related to Reporting and Recordkeeping
(FAQ); 4
4) reviewed Treasury OIG’s monitoring checklists 5 of Michigan’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 Michigan’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 risk to or impact Michigan’s uses of CRF proceeds;
7) interviewed key personnel responsible for preparing and certifying the
quarterly FPR submissions in Michigan’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 API CRF expenditures
in Michigan’s quarterly FPRs.
Based on the results of our desk review, Michigan’s documentation supporting the
uses of CRF proceeds complied with the CARES Act and Treasury’s Guidance.
Additionally, we determined that Michigan’s risk of unallowable use of funds is
low. As such, we will not be conducting an audit of Michigan.
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. The term “prime recipient” refers to the entity which
received CRF proceeds directly from the Treasury. In this report, Michigan is the prime recipient.
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 PRAC within the Council of the Inspectors
General on Integrity and Efficiency to promote transparency and conduct and support oversight
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.
Non-Statistical Transaction Selection Methodology
Treasury issued a $3,080,689,545 CRF payment to Michigan. As of December 31,
2022, Michigan’s cumulative obligations and expenditures for API payment type as
reported in GrantSolutions for cycles 1-11 was $1,036,217,349.
We made a non-statistical selection of 80 transactions related to individuals
Michigan made payments to with its CRF proceeds. Selections were made using
auditor judgement based on (1) noticeable outliers; 8 (2) duplicate transactions; and
(3) transactions with the highest obligations/payment amounts.
These transactions were selected from 4 of the 18 programs from which Michigan
reported API-related expenditures. The 4 programs are listed below:
• Department of Corrections & State Police Payroll
• Department of Corrections Hazard-Premium Pay
• Department of Health and Human Services Psychiatric Public Health Payroll
• Direct Care Worker Hazard Pay Increase
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; and U.S. Territories, including the
Commonwealth of Puerto Rico, the U.S. Virgin Islands, Guam, American Samoa,
and the Commonwealth of the Northern Mariana Islands; and Tribal governments.
Treasury issued Michigan $3,080,689,545 in CRF payments. 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 ends on December 31, 2021. 9
Section 15011 of the CARES Act requires each covered recipient 10 to submit to
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.
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 sub-recipients.
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 was assigned authority to recoup funds if 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 Michigan’s quarterly FPR submissions through December 31, 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 Michigan’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 Michigan’s risk of unallowable use of funds was low. As such, we
will not be conducting an audit of Michigan.
State of Michigan Response
The State of Michigan concurred with our assessment. On April 13, 2026, the
State provided its written response which is included in its entirety as appendix 1.
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.
******
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
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
Rachael Eubanks, Treasurer, State of Michigan
Doug Ringler, Auditor General, State of Michigan
Jennifer Edmonds, Director, Office of Accountability, State Budget Office,
State of Michigan
Jessica Thomas, Director of the Office of Internal Audit Services, State of
Michigan
13
https://www.ignet.gov/sites/default/files/files/Silver%20Book%20Revision%20-%208-20-12r.pdf
Appendix 1
File and source
- File
- OIG-CA-26-028-desk-review-of-the-state-of-michigan-s-use-of-coronavirus-relief-fund-proceeds.pdf
- Size
- 674,281 bytes
- SHA-256
- 3beafa30a022d96967160aa567a68bbdad317ccb3dc2393e8d6d215908d771a7
- Our copy
- OIG-CA-26-028-desk-review-of-the-state-of-michigan-s-use-of-coronavirus-relief-fund-proceeds.pdf
- Original
- oig.treasury.gov