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DEPARTMENT OF THE TREASURY
WASHINGTON, O.C. 20220
OFFICE OF
INSPECTOR GENERAL
OIG-CA-26-039
June 04, 2026
Coronavirus Relief Fund
Notice of Recoupment - Native Village of Selawik
On May 20, 2026, Treasury's Bureau of the Fiscal Service issued a demand letter
for $1, 176,698 to the Native Village of Selawik establishing a debt to the Federal
Government. The following document is the Office of Inspector General's Notice of
Recoupment that established this debt. The Native Village of Selawik was given an
opportunity to comment on a draft of the Notice, and its written response and our
evaluation of that response is included in the Notice of Recoupment.
cc: Jeffery W. Stout, Acting Chief Program Officer, Office of Capital Access,
Department of the Treasury
Danielle 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
Thao P. Tran, Acting Chief Operating Officer, Department of the Treasury
Tanya Ballot, Tribal Administrator, Native Village of Selawik
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This Notice may contain information protected under the Privacy Act, 5 USC 552a.
DEPARTMENT OF THE TREASURY
WASHINGTON, D.C. 20220
OFFICE OF
INSPECTOR GENERAL
Notice of Recoupment
Coronavirus Relief Fund Program
May 15, 2026
Recipient: Native Village of Selawik
Point of Contact: Tanya Ballot, Tribal Administrator
Mailing Address: 59 N Tundra, Selawik, AK 99770-0000
Recipient Point of Contact Phone Number and email address: (b) (6)
tribeadmin@akuligaq.org (CC: [Q]l(;J_, finance@akuligaq.org)
Federal Award Identification Numbers: SL T0704, SLT1143, SLT1701
Supplier Identification Numbers: 612092861SLT
Recoupment Amount: $1,176,698
Background/Legal Authority
Section 601 of the Social Security Act, as added by section 5001(a) of Division A,
Title V of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), 1
and codified at 42 U.S.C. 801, established the Coronavirus Relief Fund (CRF) and
appropriated $150 billion for making payments to States, Tribal governments, units
of local government, the District of Columbia, and U.S. Territories. Payments were
to be made in accordance with requirements outlined in 42 U.S.C. 801(a)(2), of
which $3 billion is reserved for payments to the District of Columbia and U.S.
Territories and $8 billion is reserved for payments to Tribal governments. In
accordance with 42 U.S.C. 801(c)(2)(A), no State was to receive a payment of
less than $1.25 billion.
The CRF statute at 42 U.S.C. 801(d) stipulated that CRF recipients may only use
the CRF award funds to cover costs that:
1
P.L. 116-136 (March 27, 2020)
This Notice may contain information protected under the Privacy Act, 5 USC 552a.
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 government’s budget most recently approved
as of March 27, 2020; and
3. were incurred during the period that began on March 1, 2020, and ended on
December 31, 2021, for States, local governments, and Territories. In the
case of Tribal governments, were incurred during the period that began on
March 1, 2020, and ended on December 31, 2022 (covered period).
The Consolidated Appropriations Act, 2021 extended the period for CRF recipients
to use CRF award funds for eligible expenses through December 31, 2021.2 In
accordance with Treasury’s Coronavirus Relief Fund Guidance (Guidance), 3
Treasury determined that, for a cost to be considered incurred within the covered
period, performance of services or delivery of goods must have occurred during the
covered period. In December 2021, Treasury revised its interpretation of when a
cost is considered incurred in light of the ongoing COVID-19 pandemic surges,
supply chain interruptions, and the resolution of litigation that delayed the payment
of CRF funds to certain tribes. In its revised guidance, Coronavirus Relief Fund
Revision to Guidance Regarding When a Cost is Considered Incurred, 4 Treasury
provides that a cost associated with a necessary expenditure incurred due to the
public health emergency shall be considered to have been incurred by
December 31, 2021, if the recipient has incurred an obligation with respect to such
cost by December 31, 2021. The period of performance end date for Tribal entities
was further extended to December 31, 2022. 5
Section 15011(b)(2) of the CARES Act required each covered recipient to submit to
Treasury and the Pandemic Response Accountability Committee, 6 no later than 10
days after the end of each calendar quarter, a report that contained (1) the total
2
Recipients were initially permitted to incur eligible costs using CRF award funds from
March 1, 2020, to December 30, 2020. Division N, Title X, Section 1001 of the Consolidated
Appropriations Act, 2021, Pub. L. No. 116-260 (December 27, 2020) extended the end of the
covered period for CRF expenditures from December 30, 2020, to December 31, 2021.
3
Treasury’s Coronavirus Relief Fund Guidance was published in the Federal Register on January
15, 2021, at 86 FR 4182 and can also be found at
https://home.treasury.gov/system/files/136/CRF-Guidance-Federal-Register 2021-00827.pdf
4
The Coronavirus Relief Fund Revision to Guidance Regarding When a Cost is Considered Incurred
dated December 14, 2021 can be found at https://home.treasury.gov/system/files/136/CRF-
Guidance Revision-Regarding-Cost-Incurred.pdf.
5
The State, Local, Tribal, and Territorial Fiscal Recovery, Infrastructure, and Disaster Relief
Flexibility Act included in Division LL, Section 104 of the Consolidated Appropriations Act, 2023,
Pub. L. No. 117-328 (December 29, 2022)
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Section 15011(a)(2) of the CARES Act, Pub. L. No. 116-136, defined a covered recipient as
“any entity that receives large covered funds and included any State, the District of Columbia,
and any territory or possession of the United States.”
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This Notice may contain information protected under the Privacy Act, 5 USC 552a.
amount of large covered funds received from Treasury; 7,8 (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, including—(i) the name of the project or activity; (ii) a
description of the project or activity; and (iii) the estimated number of jobs created
or retained; and (4) detailed information on any level of subcontracts or subgrants
awarded by the covered recipient or its subcontractors or subgrantee to include the
data elements required to comply with the Federal Funding Accountability and
Transparency Act of 2006 allowing the aggregate reporting on awards below
$50,000 or to individuals, as prescribed by the Office of Management and Budget.
The CARES Act assigned the Department of the Treasury (Treasury) Office of
Inspector General (OIG) with responsibility for monitoring and oversight of the
receipt, disbursement, and use of CRF payments. Treasury OIG also was assigned
authority to recoup CRF funds in the event that it is determined that a CRF
recipient failed to comply with the use of funds requirements set forth at 42 U.S.C.
801(d). As part of this authority, if OIG determines that a CRF recipient failed to
comply with the use of funds requirements for CRF award funds in 42 U.S.C.
801(d), the amount equal to the amount of funds used in violation shall be booked
as a debt of such entity owed to the Federal Government. See 42 U.S.C. 801(f)(2).
Facts and Analysis
Treasury issued a $2,568,863.45 CRF payment to the Native Village of Selawik.
Under a contract monitored by our office, a certified independent public accounting
firm (IPA), performed a desk review to evaluate Native Village of Selawik’s
documentation supporting its uses of CRF award funds as reported in the
GrantSolutions 9 portal and to assess the risk of unallowable use of funds. The IPA
identified total questioned costs of $1,176,698. 10 Specifically, the IPA found
“direct payments greater than or equal to $50,000,” “aggregate reporting less than
$50,000,” and “aggregate payments to individuals” categories did not comply with
the CARES Act and Treasury’s Guidance. The transactions tested related to
construction of the “new store”; hardship payments; purchase of a loader truck
7
Section 15010(a)(6) of the CARES Act, Pub. L. No. 116-136, defined 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 made appropriations for Coronavirus response and related activities.
8
Section 15011(a)(3) of the CARES Act, P.L. 116-136, defined large covered funds as “covered
funds that amount to more than $150,000.”
9
GrantSolutions, a grant and program management Federal shared service provider under the
United States Department of Health and Human Services, developed a customized and user-
friendly reporting solution to capture the use of CRF payments from prime recipients.
10
Treasury OIG, Desk Review of the Native Village of Selawik’s Use of Coronavirus Relief Fund
Proceeds OIG-CA-25-027 (December 20, 2024)
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This Notice may contain information protected under the Privacy Act, 5 USC 552a.
(vehicle); an illness prevention program; purchase of two all-terrain vehicles (ATVs);
purchase of a new septic waste removal truck; and payroll as detailed below:
• Construction of the “New Store” - ineligible transactions totaling $204,482
questioned costs related to the construction of the “new store.” The IPA
determined that construction for the “new store” was already underway at
the beginning of 2006; therefore, costs related to the “new store” were
considered ineligible.
• Hardship Payments - ineligible and unsupported transactions totaling
$759,583 questioned costs related to hardship payments. 11 The IPA
determined that:
• $739,502 was ineligible because transactions incurred prior to the
CRF covered period (March 1, 2020, to December 31, 2022) and/or
did not perform a need assessment to determine an applicant’s
eligibility; 12
• $20,081 was unsupported because documentation was not provided
such as utility shut-off notices, utility billing statements, tax returns,
and credit card receipts for reimbursement for the purchase of
quarantine supplies for the tribe.
• Purchase of a Loader Truck (Vehicle) - an ineligible transaction of $150,000
for the purchase of a loader truck (vehicle) dated February 13, 2020. The
transaction was incurred prior to the CRF covered period (March 1, 2020, to
December 31, 2022).
• Illness Prevention Program - ineligible and unsupported transactions totaling
$2,886 related to an illness prevention program. The IPA determined that:
11
Hardship payments are payments made by a government to citizens who have experienced a
hardship due to the pandemic.
12
https://home.treasury.gov/system/files/136/CRF-Guidance-Federal-Register 2021-00827.pdf.
Federal Register Notice Volume 86, Number 10 FAQ#43 for the CRF, Treasury’s Guidance,
published January 15, 2021, Necessary Expenditures Incurred Due to the Public Health
Emergency, “Must a State, local, or tribal government require applications to be submitted by
businesses or individuals before providing assistance using payments from the Fund?
Governments have discretion to determine how to tailor assistance programs they establish in
response to the COVID–19 public health emergency. However, such a program should be
structured in such a manner as will ensure that such assistance is determined to be necessary in
response to the COVID–19 public health emergency and otherwise satisfies the requirements of
the CARES Act and other applicable law. For example, a per capita payment to residents of a
particular jurisdiction without an assessment of individual need would not be an appropriate use
of payments from the Fund.”
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This Notice may contain information protected under the Privacy Act, 5 USC 552a.
• an ineligible transaction of $2,664 dated January 31, 2020, was
incurred prior to the CRF covered period (March 1, 2020, to December
31, 2022).
• an unsupported variance of $222 the IPA was unable to recalculate
the payroll amounts due to the timesheets missing job titles,
days/hours worked, pay period dates, and/or pay rates.
• Purchase of Two ATVs - unsupported transactions totaling $19,228 for the
purchase of two ATVs. Documentation was not provided of any
consideration of other cost-effective alternatives 13 and if the purchase was
necessary due to COVID-19.
• Purchase of New Septic Waste Removal Truck - an unsupported transaction
of $17,105 for the purchase of a new septic waste removal truck. The IPA
was unable to determine if these expenditures were eligible and not
previously budgeted because the most recently approved budget, as of
March 27, 2020, was not provided.
• Payroll – ineligible and unsupported transactions totaling $23,414. The IPA
determined that:
•
-
an ineligible payroll transaction of $(b) (4) for employees that were
designated to perform tasks related to the COVID-19 pandemic. The
timesheet and pay stub stated the costs were for the annual vacation
payout. The IPA determined that using CRF award funds for an annual
vacation payout of previously accrued benefits was essentially using
CRF award funds to cover a cost previously budgeted prior to
March 27, 2020.
•
-
unsupported transactions related to payroll expenses, totaling
$(b) (4) . These expenses lacked detailed descriptions regarding
COVID-19 hazardous pay, explanations to clarify the individual’s
positions, and if the employees were working on tasks that were
related to COVID-19.
13
Treasury’s Guidance in the Federal Register Notice Volume 86, Number 10, CRF Frequently
Asked Questions #58 stated “…a government must (i) determine that it is not able to meet the
need arising from the public health emergency in a cost- effective manner by leasing property or
equipment or by improving property already owned and (ii) maintain documentation to support
this determination.”
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This Notice may contain information protected under the Privacy Act, 5 USC 552a.
Based on the work performed, the IPA recommended that Treasury OIG confirm if
the transactions noted as unsupported or ineligible expenditures can be supported.
If support is not provided, Treasury OIG should recoup the questioned costs or
request that the prime recipient provide support for replacement expenses, not
previously charged to its CRF award, that were incurred during the CRF award
period of performance. Treasury OIG personnel began outreach with the Native
Village of Selawik to inform it of the total questioned costs of $1,176,698 as
follows:
• On December 11, 2024, we issued the Draft Desk Review of the Native
Village of Selawik’s Use of Coronavirus Relief Fund Proceeds for technical
review comments. On the same day, the IPA emailed the Native Village of
Selawik requesting an exit conference.
• On December 12, 2024, the IPA sent a 2nd request to hold an exit
conference. The Native Village of Selawik responded, stating the draft desk
review report was received and would be reviewed.
• On December 17, 2024, the IPA sent a final correspondence to the Native
Village of Selawik requesting an exit conference. An exit conference was not
held due to the Native Village of Selawik’s lack of response to repeated
requests. The IPA and Treasury OIG proceeded to issue the final desk review
report.
• On December 20, 2024, we issued the Final Desk Review of the Native
Village of Selawik’s Use of Coronavirus Relief Fund Proceeds.
• On April 28, 2025, Treasury OIG emailed a letter to the Native Village of
Selawik’s Tribal Administrator, notifying her that all supporting
documentation for the questioned costs identified in the desk review
memorandum must be submitted to Treasury OIG no later than
May 7, 2025.
• On April 30, 2025, Treasury OIG emailed the Native Village of Selawik’s
Tribal Administrator notifying her that due to the end of the performance
period for the CRF program, and limited staffing resources, Treasury OIG
was no longer able to provide the option of submitting other eligible
expenditures, not previously charged to the CRF award, that were incurred
during the period of performance. Treasury OIG requested that the amount
noted as questioned costs be voluntary returned to Treasury. Otherwise,
those funds are subject to recoupment.
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This Notice may contain information protected under the Privacy Act, 5 USC 552a.
• On June 16, 2025, Treasury OIG emailed a Draft Notice of Proposed
Recoupment to the Native Village of Selawik’s Tribal Administrator, notifying
her that Native Village of Selawik’s failure to provide documentation for the
questioned costs as acknowledgement that it is unable to demonstrate that it
used the funds for eligible CRF purposes and that these monies are
accordingly subject to recoupment. We requested a written response from
Native Village of Selawik by June 30, 2025. We also advised the Tribal
Administrator that if a written response was not received, we would proceed
with recoupment.
• On June 26, 2025, we received a written response and documentation from
the Native Village of Selawik’s Tribal Administrator. On the same day, we
acknowledged receipt of the information.
In a written response, the Tribal Administrator stated that included with the
letter is the supporting documentation for the questioned costs. See
Appendix I for the response in its entirety.
The Native Village of Selawik provided eight documents totaling $216,295 14
and one document for $17,744 to support the questioned costs. We
determined that the documentation did not support the questioned costs.
Specifically, the eight documents totaling $216,295 were the exact same
documents the Native Village of Selawik provided to the IPA during the desk
review, which was deemed insufficient support. The remaining document
totaling $17,744 was for the purchase of ATVs, but it was not for the same
two ATV transactions totaling $19,228 15 that were questioned during the
desk review. The vehicle identification numbers from the document did not
match the identification numbers from the transactions tested. Additionally,
the Native Village of Selawik did not provide documentation to support any
consideration of cost-effective alternatives, such as leasing or improving the
ATVs already owned.
• On September 5, 2025, Treasury OIG emailed Native Village of Selawik’s
Tribal Administrator, notifying her that the documentation provided on June
26th was inadequate to address the $1,176,698 questioned costs. Treasury
OIG requested that the Native Village of Selawik voluntarily return the total
amount of $1,176,698 no later than September 12, 2025.
14
The $216,295 from the “direct payments greater than or equal to $50,000” category consisted
of $150,000 for the purchase of loader truck (vehicle), $2,664 related to an illness program,
$9,500 related to construction of the “new store,” and $54,131 in hardship payments.
15
This amount was from the “aggregate reporting less than $50,000” category for the purchase of
two ATVs.
8
This Notice may contain information protected under the Privacy Act, 5 USC 552a.
Treasury OIG interprets the Native Village of Selawik’s failure to provide adequate
documentation for these questioned costs as acknowledgement that it is unable to
demonstrate that it used the funds for eligible CRF purposes; and that these monies
are accordingly subject to recoupment.
This is a final recoupment notice for the Native Village of Selawik. Since the Native
Village of Selawik failed to return the total questioned costs of $1,176,698 by
September 12, 2025, Treasury OIG will instruct the Department of the Treasury
Administrative Resource Center’s Accounts Receivable Branch to book this amount
as a debt of the Native Village of Selawik owed to the federal government and
pursue debt collection, which may include addition of appropriate fees and interest.
In addition, Treasury OIG may report the Native Village of Selawik to SAM.gov in
the Responsibility/Qualification Reports (formerly known as Federal Awardee
Performance Integrity Information System), which may impact the Native Village of
Selawik’s future eligibility to receive financial assistance from the federal
government.
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This Notice may contain information protected under the Privacy Act, 5 USC 552a.
Appendix 1
Recipient Response
Natfve 'Vi{{age of Se(awik
Selawik Tribal Council
P .O . Box 59
Selawik, AK 99770
Phone: 907-484-21 65
June 25, 2025
To : CARES Act OIG Treasury
Re: Response to Desk Review and Notice of Proposed Recoupme nt of
CARES Act Funds
Federal Award Identificat ion Numbers: SLT0704, SLTl 143 SLTl 701
Good morning,
I am writing this letter in regards to the notice of proposed recoupme nt of
funds for the CARES Act funds for the Native Village of Selawik.
First let me apologize for not respondin g in the timely manner previously . My
job can get very over whelming from time to time. We are and have been the
main organizati on to respond to every communit y situation .
Our water and sewer has been frozen for half the town from October 2024 to
June 2025. 54 homes were without services. Our communit y has village
d eaths, the Tribe responds to supportin g the family's. I have working to get
our s ingle audit preparatio ns ready these past couple of months and also
trying to write up budget and narratives for four grants we received and had no
awareness of it. We are working on building capacity within the organizati on.
One of the reasons we got a desk review, is we had angry tribal members
saying that we didn't give them enough COVID-19 funds, they believed that the
funding was ALL for them. They believed the Tribe received these funds on
their behalf and we had to give it to them.
Expenses for the tribal m e mbe rs were paid to help the Tribal members b e able
to purchase necessary cleaning supplies for their homes to prevent the sprea d
of COVID- 19.
Expenses for a "water truck", this is not correct. We do not have any truck
type of vehicles. We have small heavy equipmen t pieces that we use to
compact our dumpsite /honey bucket waste site. We live in rural Alaska, and
we are one of the communit ies that don't have roads, we use ATV, hence the
purchase of two ATV vehicles to also help the communit y respond to COVID-
19.
Expenses for the utility payments for electricity and water and sewer, we
needed our home to be able to have working utilities to respond to COVID-19 .
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This Notice may contain information protected under the Privacy Act, 5 USC 552a.
The Native Village of Selawik is a small tribe in Northwest Alaska. We are
unique, we are behind the times, we did the best we could. Along with this
letter are the supporting documents for each of the questioned costs.
Procurement p1·actices were in place, and the supporting documentation is
along each expense item.
Please accept this letter on beha If of the Nativ�awik. If you
re uire further information, please call me at�or email me at
Thank you for your time.
R tf 11
(b} (6)
-Tanya(llallot
AdmiMstrator
Native Village of Selawik
Cc: Selawik Tribal Council
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This Notice may contain information protected under the Privacy Act, 5 USC 552a.