Topics Discussed on April 4 and 5, 2022, webinars for Tribes, TDHEs and the DHHL

Summary

A Treasury summary of topics discussed at ERA reporting webinars for Tribes and Tribally Designated Housing Entities on April 4 and April 5, 2022, with questions and answers edited for clarity. It notes that each ERA Recipient must report its obligations to subrecipients, contractors and beneficiaries and the related expenditures. Question 1 explains that a utility company paid directly for many tenants is a beneficiary, and that when it receives more than $30,000 the Recipient must create records for it and report the payment among expenditures valued at $30,000 or more. Question 2 explains that utility payments made to households are reported in total on the screen for payments to individuals. The document closes by noting that the portal lets Recipients download previously submitted data.

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Tribal and Tribally Designated Housing Entity (“TDHE”) ERA Reporting
Webinar
April 4 and April 5, 2022
Topics Discussed

The following topics were discussed on the ERA reporting webinars on April 4 and April 5,
2022. The questions and answers have been modified for clarity and accuracy.
Special Note: Each ERA Recipient must report on its uses of ERA funds. This includes reporting
on all the Recipients’ obligations to subrecipients, contractors and beneficiaries and the
associated expenditures on subawards, contracts and direct payments. Additional clarifying
information and scenarios/reporting examples can be found in ERA Reporting Guidance under
Appendix 9 -- Scenarios on Reporting an ERA Recipient’s Allocations of ERA funds to
Subrecipients, Contractors and Beneficiaries.

Question 1: Our ERA project paid electric utility bills for 20 applicants directly to the
utility company. Each tenant’s utility bill was for less than $30,000, but the overall
payment made to Electric Company A for all 20 bills was more than $30,000. How should
we report this on the quarterly report form?
Answer: This question focuses on how to report utility payments made directly to utility
companies. Please see Question 2 below for information on reporting utility payments paid to
households.
When the ERA Recipient makes utility payments directly to a utility company (such as an
electric company), the company is considered a beneficiary, not a subrecipient or contractor.
Because, as outlined in the question, the electric company received more than $30,000 in
payments, the ERA Recipient (the Tribe) must set up a record for the electric company in the
“Subrecipients, Contractors and Beneficiaries” tab on the reporting portal. Each Recipient should
also create a record on the “Subawards, Contracts and Direct Payments” tab, to show that it has
obligated $30,000 to the electric company and associate that obligation with the company.
Finally, the Recipient will record this payment as an expenditure in the “Expenditures” tab under
the “Expenditures Associated with the ERA Recipient’s Subawards, Contracts and Direct
Payments Valued at $30,000 or More” section.

Question 2: Our communities may all use one vendor for utilities. Are we supposed to set
up a new tab for every amount over $30,000? For example, if we assisted 300 of our
households all using the same utilities vendor, can we report this as one lump sum amount?
Answer: In the situation where the ERA Recipient makes utility payments to households (rather
than making them directly to utility companies as discussed in Question 1 above), the Recipient
should use the “Recipient Obligations and Expenditures (Payments) to Individuals

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(Beneficiaries)” screen to report the total amount it paid (expended) to all individuals in the
quarter for utility payments (expenditures). The Recipient should use that screen to separately
report the total amount paid to individuals for utility payment arrears.

Question 3: If we have numerous payments in amounts less than $30,000 to different
individual beneficiaries, do we have to complete a subaward or contract form for each of
them?
Answer: If a Recipient makes payments to numerous individual beneficiaries and each payment
is less than $30,000, the Recipient would need to use the “Recipient and Obligations to
Individuals (Beneficiaries)” section of the portal to report lump sum amounts by the type of
benefit (rent, rental arrears, utility/home energy costs or arrears, and so forth).

Question 4: Is the $30,000 per beneficiary report threshold assessed per quarter or it is the
cumulative amount? For example, if we make many small utility payments to an electric
company, and over two quarters, the total amount paid reaches $30,000, must we report
the utility company as a beneficiary receiving more than $30,000?
Answer: The $30,000 threshold is cumulative over the life of the grant. Recipients should
consider creating a vendor report within their internal financial systems that will flag once
payments to a specific vendor reach a specified amount (for example: ERA requirement is
$30,000 or more). Once this threshold is reached, the Recipient is required to create a record for
the entity under the “Subrecipients, Contractors, and Beneficiaries” tab.

Question 5: At what point do “cumulative expenditures” begin?
Answer: Cumulative expenditures are counted from the time of the award was made to the
recipient.

Question 6: Please clarify the difference between the two Tabs: “Subrecipients,
Contractors and Beneficiaries” and “Recipient Subawards, Contracts and Direct
Payments”.
Answer: Recipients use the “Subrecipients, Contractors, and Beneficiaries” tab to report basic
information about organizations, such as subrecipients and contractors, that are assisting the
Recipient with administering the ERA project and to which it has awarded $30,000 or more.
(Recipients also use this tab to report basic information about any business or non-profit that
receives more than $30,000 in ERA benefits.)
Recipients use the “ Subawards, Contracts, and Beneficiaries” tab to provide more detailed
information about the subawards, contracts or direct payment(s) made to the entities listed in the
previous tab. The additional required details include the amount obligated to the entity, the place

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of performance, and the period of performance timeframes.

Question 7: Is the place of performance the individual tenant’s address or the vendor’s
address?
Answer: On the “Recipient Subawards, Contracts, and Direct Payments” tab, the performance
address is the vendor address, not the individual tenant’s address.
Question 8: Would Beneficiaries mean landlords and utility companies?
Answer: Yes, a landlord or utility company that receives direct payments is considered a
beneficiary.

Question 9: When a TDHE is a landlord to which direct payments are made, is that TDHE
reported as a beneficiary?
Answer: Yes, in the situation described here, the TDHE is considered a beneficiary.

Question 10: What if I need to correct information after a report is submitted?
Answer: To limit errors, a recommended practice is to compare the general ledger detail from
the Recipient’s accounting software to the information entered in the portal. If an erroneous
information is later discovered to have been reported, in lieu of submitting a corrected or
modified report, information should be submitted that balances the error from the previous
report. For example, if a Recipient overreported expenditures in a category by $1,500 on a Q2
report, the next Q3 report should note the error in the appropriate narrative box and reduce
relevant expenditure category by the same amount to correct for initial error. Additionally, at the
end of the Performance and Financial Reporting section, there is a Recipient Comments section
where the Recipient should include notes on the error.

Question 11: Can Treasury make a simple chart with the deadlines and place in a location
where it is easy to find please?
Answer: Please review Table 2 on page 10 of the ERA Reporting Guidance. This document
provides detailed information on ERA1 and ERA2 reporting requirements and reporting
deadlines. The ERA Reporting Guidance is posted on Treasury’s ERA website at
www.treasury.gov/era under the “reporting” section.

Question 12: Are we required to send 1099s to landlords?
Answer: Yes, ERA benefit payments paid to landlords are considered income for the landlord.
Recipients must distribute copies of IRS Form 1099-MISC to landlords, utility companies, or
other service providers that receive more than $600 in ERA benefit payments.

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However, ERA benefit payments are excludable from tenants’ gross income and therefore are
not taxable as income to the tenant. ERA Recipient should not distribute Form 1099-MISC to
tenants who receive ERA benefit payments. For further information, please see the Internal
Revenue Service’s Draft FAQs for Payments by Indian Tribal Governments to their Individual
Members Under COVID-Relief Legislation and Notice of Tribal Consultation.

Portal Functionality and Navigation
Question 13: Is there any effort being made to populate fields to simplify future reporting?
Answer: Based on helpful feedback from Tribes and TDHEs, the Treasury Department has
updated the reporting portal. For example, previous versions of the portal required SF-425 and
data entry of the information. Later, the Treasury Department removed the requirement for the
SF-425. Parts of the portal does retain information for future reporting, such as profile
information for subrecipients, contractors and beneficiaries.

Question 14: What is the process for giving new staff access to Treasury’s portal so they
can assist with inputting information for quarterly reports?
Answer: Please see the Accessing Treasury’s Portal section on the ERA Reporting page and the
Hints and Tips for Designating Points of Contact for ERA1 and ERA2 Reporting document.

Question 15: If we are entering both program and financial information for the quarter,
where do we see total (cumulative) information?
Answer: Treasury’s portal maintains each Recipient’s previously submitted financial
information. Recipients can download their previously submitted quarterly reports to review
information submitted in those reports. After a report is submitted, a Recipient can navigate to
the Compliance Reports section, download the report, and print/store the report in its records.
Recipients should consider printing the reports as a preparatory measure for future audits.
In addition, when submitting new quarterly reports, Treasury’s portal allows Recipients to view
previously submitted data such as subrecipient/contractor/beneficiary records,
subaward/contract/direct payment obligation information and information reported under the
“Expenditures” tab. For each of these sections, each Recipient can download an Excel file with
cumulative information that it has submitted under that specific tab over the life of the award.
Recipients might find it helpful to download and review previously submitted financial data
offline to determine if any corrections are required.

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