OIG-CA-26-035: Emergency Rental Assistance (ERA2) – Questioned Cost Finding, Riverside County, California

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A Department of the Treasury Office of Inspector General memorandum dated May 14, 2026 (OIG-CA-26-035) from Julie Wong, Acting Deputy Assistant Inspector General for Audit, to Jeffrey Stout, Acting Chief Program Officer, Office of Capital Access, on the Emergency Rental Assistance Program (ERA2) Questioned Cost Finding, Riverside County, California. It states that in July 2023, August 2023, and April 2024 OIG received reports from Inland Southern California 211, a subrecipient of Riverside County, about 17 cases of ineligible payments made with ERA2 funds. It states that OIG agreed with the conclusions on five cases, questions $82,815 paid for applications lacking valid eligibility documentation, and that Riverside County agreed it would repay the $82,815.

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                                           DEPARTMENT OF THE TREASURY
                                                  W ASHINGTON, D.C. 20220




     OFFICE OF
INSPECTOR GENERAL




                                                        May 14, 2026

            OIG-CA-26-035

            MEMORANDUM FOR JEFFREY STOUT
                           ACTING CHIEF PROGRAM OFFICER, OFFICE OF CAPITAL
                           ACCESS
            From:                       Julie Wong /s/
                                        Acting Deputy Assistant Inspector General for Audit


            Subject:                    Emergency Rental Assistance Program (ERA2) – Questioned
                                        Cost Finding, Riverside County, California

            During the coronavirus pandemic, Congress authorized and funded two
            Emergency Rental Assistance (ERA) programs administered by the Department of
            the Treasury (Treasury) to provide rental assistance to eligible households:
            (1) ERA1 - Division N, Title V, Subtitle A, § 501 of the Consolidated Appropriations
            Act, 2021 (Pub. L. No. 116-260), Dec. 27, 2020, and codified as 15 USC § 9058a: and
            (2) ERA2 - Title III, Subtitle B, § 3201 of the American Rescue Plan Act (Pub. L. No.
            117-2), Mar. 11, 2021, and codified as 15 USC § 9058c.
            In July 2023, August 2023, and April 2024, we received reports from Inland
            Southern California 211 (ISC211); 1 a subrecipient of Riverside County, California,
            about 17 cases of ineligible payments it made with ERA2 funds. 2 After reviewing
            documentation provided by ISC211 and Riverside County, we agreed with
            ISC211’s conclusions on five cases. ISC211 Paid $82,815 on behalf of Riverside
            County for applications that lacked valid documentation to establish eligibility and
            therefore is in violation of the Use of Funds statute. Accordingly, we question
            these costs. In response to a draft of this questioned cost finding, Riverside
            County agreed it would repay the $82,815. We are recommending that the

            1
                ISC211 is a subsidiary of Inland Southern California United Way.
            2
                Pursuant to 2 CFR § 200.113, Mandatory disclosures, under the Uniform Administrative
                Requirements, Cost Principles, and Audit Requirements for Federal Awards; The non-Federal
                entity or applicant for a Federal award must disclose, in a timely manner, in writing to the
                Federal awarding agency or pass-through entity all violations of Federal criminal law involving
                fraud, bribery, or gratuity violations potentially affecting the Federal award. Non-Federal entities
                that have received a Federal award including the term and condition outlined in appendix XII to
                this part are required to report certain civil, criminal, or administrative proceedings to SAM
                (currently FAPIIS). Failure to make required disclosures can result in any of the remedies
                described in § 200.339. (See also 2 CFR part 180, 31 U.S.C. 3321, and 41 U.S.C. 2313.)


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Treasury Office of Capital Access disallow these costs and direct Riverside County
to reimburse the Federal Government $82,815.
Background/Legal Authority
Under the ERA2 statute at 15 U.S.C. § 9058c(d)(1), Use of Funds, an eligible
grantee shall use ERA2 award funds to provide eligible households with financial
assistance, housing stability services, administrative costs, and as applicable,
other affordable rental housing and eviction prevention activities. The financial
assistance includes the payment of: rent; rent arrears; utilities and home energy
costs; utilities and home energy costs arrears; and other expenses related to
housing, as defined by the Secretary of the Department of the
Treasury (Treasury). The aggregate amount of such financial assistance an eligible
household may receive under an ERA2 award, when combined with financial
assistance provided under an ERA1 award authorized by 15 USC § 9058a, shall not
exceed 18 months. See 15 U.S.C.§ 9058c(d)(1)(A)(ii).
The ERA2 statute at 15 U.S.C. § 9058c(f)(2) defines an eligible household as a
household of one or more individuals who are obligated to pay rent on a
residential dwelling and with respect to which the eligible grantee involved
determines that: (1) one or more individuals within the household has (a) qualified
for unemployment benefits or (b) experienced a reduction in household income,
incurred significant costs, or experienced other financial hardship during or due,
directly or indirectly, to the coronavirus pandemic; (2) one or more individuals
within the household can demonstrate a risk of experiencing homelessness or
housing instability; and (3) the household income is not more than 80 percent of
the area median income for the jurisdiction.
Pursuant to the ERA2 statute at 15 U.S.C. § 9058c(g), the last day of the period of
performance for grantees was September 30, 2025.
Facts and Analysis
In July 2023, August 2023, and April 2024, we received reports from ISC211 a
subrecipient of Riverside County, California, about 17 cases of ineligible payments
it made with ERA2 funds. ISC211 explained they detected the ineligible payments
when performing secondary (post-payment) reviews. While ISC211 identified 17
cases as ineligible, we agreed with ISC’s determination on 5 of them. Of the other
12 cases, ISC211 considered 3 cases ineligible due to familial relationships
between the landlord and tenant. The ERA1 statute at 15 U.S.C. § 9058a(k)(3) does
not specifically exclude such familial relationships in the definition of an eligible
household; therefore, we do not challenge payments made in these cases if the
payments otherwise met ERA2 eligibility requirements. Accordingly, we
determined that these three cases did meet eligibility requirements. In another
case, ISC211 informed us that upon subsequent review, they could not
substantiate a claim of fraud. Upon inquiry, for the other eight cases, ISC211

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provided additional documentation that demonstrated the payments were
eligible.
We agreed with ISC211’s conclusions on 5 of 17 cases, as follows:


   1. Application #(b) (6) : ISC211 determined that the applicant stole an
      individual’s identity, purporting to be a landlord. ISC211 paid ERA2
      assistance based on an application that contained fraudulent
      documentation; therefore, ISC211 cannot establish an eligible use of funds.
      ISC211 informed us that at the time of the application, all documents had
      been validated to determine eligibility. We reviewed the police report
      provided by ISC211, the landlord contact and bank information as
      presented in the application documents did not belong to the landlord.
      Accordingly, we determined that the rent and rental arrears paid, in the
      amount of $29,900, is an ineligible ERA2 expenditure that failed to comply
      with the requirements of the ERA2 statute.

   2. Application #(b) (6) : ISC211 determined that the applicant used a deceased
      person’s information to collect ERA funds. ISC211 paid ERA2 assistance
      based on an application that lacked valid documentation to establish
      eligibility; therefore, ISC211 cannot establish an eligible use of funds.
      Accordingly, we determined that the rent and rental arrears paid, in the
      amount of $17,055, is an ineligible ERA2 expenditure that failed to comply
      with the requirements of the ERA2 statute.

  3.   Application #(b) (6) : ISC211 determined that the applicant submitted altered
       unemployment and utility bill documents. ISC211 paid ERA2 assistance
       based on an application that lacked valid documentation to establish
       eligibility; therefore, ISC211 cannot establish an eligible use of funds.
       Accordingly, we determined that the rent and rental arrears paid, in the
       amount of $14,100, is an ineligible ERA2 expenditure that failed to comply
       with the requirements of the ERA2 statute.

  4.   Application #(b) (6) : ISC211 determined that the applicant stole an
       individual’s identity and submitted altered application documents
       purporting to be a landlord. ISC211 paid ERA2 assistance based on an
       application that lacked valid documentation to establish an obligation to
       pay rent; therefore, ISC211 cannot establish an eligible use of funds.
       Accordingly, we determined that the rent and rental arrears paid, in the



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Methodology
We conducted our review of this ERA case from July 2023 to January 2026. We
inquired of the grantee and other relevant parties, reviewed related
documentation, and performed other appropriate procedures. We believe the
evidence obtained is sufficient and appropriate to provide a reasonable basis for
our findings and conclusions in this memorandum.
In conducting our review, we followed the OIG’s system of quality management
for ensuring that the information in this Notice is accurate. We also followed the
Council of the Inspectors General on Integrity and Efficiency (CIGIE) Quality
Standards for Federal Offices of Inspector General which require that our work
adheres to its general standards for integrity to include objectivity, independence,
professional judgment, and confidentiality as well as its general standard for
receiving and reviewing allegations.




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                                                                        Appendix 2


Schedule of Monetary Benefits
According to the Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards at Title 2 of the Code of Federal Regulations
§ 200.1 a “questioned cost” is an amount, expended or received from a Federal
award, that in the auditor's judgment:
   (i)    is noncompliant or suspected noncompliant with Federal statutes,
          regulations, or the terms and conditions of the Federal award;

   (ii)   at the time of the audit, lacked adequate documentation to support
          compliance; or

   (iii) appeared unreasonable and did not reflect the actions a prudent person
         would take in the circumstances.
Questioned costs will be recorded in Treasury’s Joint Audit Management
Enterprise System. The amount will also be included in the 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(c) of the Inspector General Act of 1978, as
amended.
Recommendation               Questioned Costs
Recommendation No. 1              $82,815.00
The questioned costs represent ERA2 amounts provided by Treasury under the
American Rescue Plan Act of 2021 that were paid by Riverside County to ineligible
households in violation of the ERA2 statute at 15 U.S.C. § 9058c(d), Use of Funds.




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Distribution

   Department of the Treasury

      Jeffrey W. Stout, Acting Chief Program Officer, Office of Capital Access

      Danielle Christensen, Deputy Chief Program Officer for State & Local
      Programs, Office of Capital Access

      Kendra N. Young-Freeman, Director, Housing Programs, Office of Capital
      Access

      Michelle Dickerman, Deputy Assistant General Counsel, Office of the
      General Counsel

      Carolyn Appel, Attorney-Advisor, Office of the General Counsel

      Blossom Butcher-Sumner, Attorney-Advisor, Office of the General Counsel

   Riverside County

   Inland Southern California 211




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