Emergency Rental Assistance (ERA1) Program Notice of Recoupment — Riverside County, California (OIG-CA-26-037)

Summary

Pages from a Treasury Office of Inspector General Emergency Rental Assistance (ERA1) Notice of Recoupment concerning Riverside County, California, beginning with the end of the review-standards paragraph and the distribution list. The Facts and Analysis section states that OIG received reports from Inland Southern California 211 (ISC211), a subrecipient of Riverside County, about 14 cases of ineligible payments, and that OIG agreed with ISC211's conclusions on 2 of the 14 cases. It states that in those two cases applications lacked valid documentation, and that OIG determined ERA1 payments of $24,610 and $16,800 were ineligible expenditures. It cites 15 U.S.C. § 9058a on eligible households, the December 29, 2022 last day of the period of performance for reallocated funds, and recoupment as a debt.

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In conducting our review, we followed the OIG’s system of quality management
for ensuring that the information in this report 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.
Distribution
   Department of the Treasury
      Jeffrey W. Stout, Acting Chief Operating 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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The ERA1 statute at 15 U.S.C. § 9058a(k)(3)(A) defines 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: (1) that 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 due, directly or
indirectly, to the COVID-19 outbreak, which the applicant shall attest in writing;
(2) that one or more individuals within the household can demonstrate a risk of
experiencing homelessness or housing instability, which may include (a) a past
due utility or rent notice or eviction notice; (b) unsafe or unhealthy living
conditions; or (c) any other evidence of such risk, as determined by the eligible
grantee involved; and (3) the household has a household income that is not more
than 80 percent of the area median income for the household.
In accordance with the ERA1 statute at 15 U.S.C. § 9058a(k)(3)(B), the grantee
must also ensure that, to the extent feasible, any rental assistance provided to an
eligible household is not duplicative of any other federally funded rental
assistance provided to such household.
Pursuant to the ERA1 statute at 15 U.S.C. § 9058a(e)(2), the last day of the period
of performance for grantees that received ERA1 reallocated funds was
December 29, 2022.
The ERA1 statute at 15 U.S.C. § 9058a(i) Inspector General Oversight;
Recoupment, directed that Treasury’s Office of Inspector General (OIG) conduct
monitoring and oversight of the receipt, disbursement, and use of funds made
available under the ERA1 program. As part of this authority, if OIG determines that
a grantee failed to comply with the use of funds requirements in ERA1 statute (15
U.S.C. § 9058a(c)), the amount equal to the amount of funds used in violation of
15 U.S.C. § 9058a(c) shall be booked as a debt of such grantee owed to the Federal
Government. Amounts recovered shall be deposited into the general fund of the
Treasury.
Facts and Analysis
In July 2023, January 2024, and April 2024, we received reports from Inland
Southern California 211 (ISC211), a subrecipient of Riverside County, California,
about 14 cases of ineligible payments made from Riverside County’s ERA1
financial assistance award. 1 ISC211 explained they detected the ineligible
payments when performing secondary (post-payment) reviews. While ISC211
initially identified 14 cases to be ineligible payments, we agreed with ISC211’s

1
    Pursuant to 2 CFR § 200.113, Mandatory disclosures, under the Uniform Administrative
    Requirements, Cost Principles, and Audit Requirements, grantees must disclose, in a timely
    manner, in writing to the Federal awarding agency all violations of Federal criminal law
    involving fraud potentially affecting the Federal award.
                                                 2

          This Notice may contain information protected under the Privacy Act, 5 USC 552a.
determination on 2 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 ERA1
eligibility requirements. Accordingly, we determined that these three cases did
meet eligibility requirements. In another case, ISC211 detected fraud; therefore, a
payment was not issued for this case. Upon inquiry, ISC211 provided additional
documentation that demonstrated that the other eight cases resulted in eligible
payments.
We agreed with ISC211’s conclusions on 2 of 14 cases, as follows:
   1.   Application #(b) (6) : ISC211 determined that the tenant submitted altered
        identification and income documents. ISC211 paid ERA1 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 ERA1 rent and rental arrears paid, in the amount
        of $24,610, are an ineligible ERA1 expenditure that failed to comply with
        the requirements of the ERA1 statute.

   2.   Application #(b) (6) : ISC211 determined that the applicant submitted
        altered income, deed, and tax documents. ISC211 paid ERA1 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 ERA1 rental arrears paid, in the
        amount of $16,800, are an ineligible ERA1 expenditure that failed to
        comply with the requirements of the ERA1 statute.
Based on the information provided, we determined that Riverside County, through
its subrecipient, ISC211, failed to comply with the use of funds requirements in
the ERA1 statute (15 U.S.C. § 9058a(c)) when it paid ERA1 award funds totaling
$41,410 to ineligible households. Accordingly, these funds are required to be
returned to the Federal Government.
Grantee Response
We provided Riverside County with an opportunity to respond to our Proposed
Notice of Recoupment. On March 19, 2026, the Director, Housing and Workforce
Solutions, Riverside County, provided written response by email, stating they
concurred with OIG’s conclusions. See Appendix I for the response in its entirety.
OIG Evaluation
Riverside County’s response and planned action to return $41,410 to the Federal
Government addresses our notice.
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        This Notice may contain information protected under the Privacy Act, 5 USC 552a.


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