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Treasury, Capital Projects Fund Compliance and Reporting Guidance for Tribal Entities

Summary

Treasury's July 2026 Compliance and Reporting Guidance for Tribal entities holding Coronavirus Capital Projects Fund (CPF) grants, the program the American Rescue Plan Act created on March 11, 2021. Tribal governments are responsible for project reporting, may designate a Consortium to submit reports through the Reporting Portal, and must keep an active SAM.gov registration under 2 CFR 25.200(b)(2). Reports are due within 30 calendar days after each period. The annual report for July 1, 2025 – June 30, 2026 is due July 31, 2026; the last, for July 1, 2026 – December 31, 2026, the end of the period of performance, is due January 31, 2027. The final closeout report is due within 120 calendar days after the period of performance ends. Recipients that report spending their full allocation get a pop-up asking about early closeout; answering it does not, by itself, request closeout.

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“Treasury, Capital Projects Fund Compliance and Reporting Guidance for Tribal Entities.” Original at home.treasury.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/treasury-capital-projects-fund-compliance-and-reporting-guidance-for-t-1865d752fc/, SHA-256 80f952f0f9b0317be4190d6283b9a8e3d92f0134d5faf05ff4d73cd5599c5216.

Full text

 Coronavirus Capital Projects Fund
Compliance and Reporting Guidance
        For Tribal Entities
            July 2026
Table of Contents

PART 1: INTRODUCTION .................................................................................... 1

PART 2: REPORTING REQUIREMENTS ............................................................. 2

PART 3: GENERAL GUIDANCE ........................................................................... 9
        A. Compliance Requirements ..................................................................................................... 9
        B. Uniform Administrative Requirements ................................................................................... 9


APPENDIX 1: DEFINITIONS............................................................................... 13
                 Coronavirus Capital Projects Fund
                Compliance and Reporting Guidance
                        for Tribal Entities


Part 1: Introduction
On March 11, 2021, the American Rescue Plan Act was signed into law, establishing the
Coronavirus Capital Projects Fund (Capital Projects Fund or CPF). CPF is administered by the
U.S. Department of the Treasury and provides grants to eligible Tribal governments, states,
territories, and freely associated states, to carry out critical Capital Projects directly enabling
work, education, and health monitoring, including remote options, in response to the public
health emergency with respect to the Coronavirus Disease (COVID-19).

This guidance provides detail and clarification about reporting and compliance responsibilities
for Tribal governments, including responsibilities regarding Tribal consortia as applicable, under
the CPF. This guidance should be read in concert with the following documents:
    • Capital Projects Fund Statute;
    • Capital Projects Fund Guidance for Tribal Governments;
    • Grant Agreement entered into by each Recipient;
    • Frequently Asked Questions (FAQs);
    • Assistance Listing 21.029 published on SAM.gov;
    • Other regulatory and statutory requirements, including under the Uniform Guidance (2
        CFR Part 200).

Recipients are advised to monitor the CPF for Tribal Governments page of Treasury’s website
for additional compliance resources.

Tribal governments are responsible for ensuring that reporting requirements for Projects are
met. Tribal governments may designate a Consortium to submit reports. Recipients must
maintain an active SAM.gov registration for the duration of their CPF award pursuant to 2 CFR
25.200(b)(2).

Please Note: This guidance document applies to CPF only and does not change or impact
reporting and compliance requirements applicable to the other funding sources when the Capital
Projects Fund is used in conjunction with other funding sources, such as National
Telecommunications and Information Administration (NTIA) grants, or the State and Local Fiscal
Recovery Funds (SLFRF).




 Coronavirus Capital Projects Fund Compliance and Reporting Guidance for Tribal Entities
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Part 2: Reporting Requirements
There are two types of CPF reporting requirements for Tribal governments.
•     Annual Report: An annual report to provide information on Projects funded, Obligations,
      Expenditures, Project status, outputs, performance indicators, and other information.
•     Closeout Report: A report to provide information related to program accomplishments
      compared against the stated objectives in the approved application upon closeout of the
      grant. Additional guidance will be provided at a future date. Recipients interested in
      submitting a Closeout Report prior to the release of further guidance should contact
      Treasury.

Reporting will be due according to the schedule in Table 1, which may be modified by Treasury
with prior notice to Recipients.

All reporting must be submitted through the Reporting Portal. Tribes with limited or no internet
access may submit the Annual Report via mail or e-mail. Reasonable accommodations will be
met upon request.

Table 1 shows the reporting requirements for Tribal governments.

                             Table 1: Report Timelines
    Report Report Type                        Reporting Period                            Due Date

      1         Annual         All Obligations and Expenditures Through                 July 31, 2023
                Report         June 30, 2023 (Including Pre-Award Costs)
      2         Annual                 July 1, 2023 – June 30, 2024                     July 31, 2024
                Report
      3         Annual                 July 1, 2024 – June 30, 2025                     July 31, 2025
                Report
      4         Annual                 July 1, 2025 – June 30, 2026                     July 31, 2026
                Report
      5         Annual             July 1, 2026 – December 31, 2026 1                 January 31, 2027
                Report
    Final      Closeout                  Full Period of Performance                    120 Days After
                Report                                                                 End of Period of
                                                                                        Performance




1 This Annual Report will cover the six-month period corresponding with the end of the period of performance on

December 31, 2026.

    Coronavirus Capital Projects Fund Compliance and Reporting Guidance for Tribal Entities
                                                         2
Annual Report
Recipients are required to submit Annual Reports according to the due dates noted in Table
1 for the period of performance. Recipients or their designees are required to submit one Annual
Report per reporting period. The information provided by Recipients in these reports regarding
their plans and practices will promote on-time and on-budget delivery of CPF Projects.

A consortium may submit a single Annual Report on behalf of all Tribal governments that have
designated the Consortium to act on their behalf. However, such an Annual Report must provide
reporting data for each member Tribe. Tribes may designate third parties, including other Tribes,
to submit the Annual Reports on their behalf. Irrespective of which entity files reports on behalf
of a Tribal government, the Tribal government is ultimately responsible for ensuring compliance
with reporting requirements.
Following Report 1, all Annual Reports will cover one 12-month reporting period and must be
submitted to Treasury within 30 calendar days after the end of each reporting period, except for
the final report, which is due within 120 calendar days after the end of the period of performance
or sooner if all award funds have been expended before the end of the period of performance. 2
Treasury may issue additional closeout instructions prior to the end of the period of
performance.
Expenditures may be reported on a cash or accrual basis as long as the methodology is
disclosed and consistently applied.
The following information must be submitted in each Annual Report:
a. Application Amendment Request
   Recipients must indicate whether they request an amendment to their approved CPF
   application. If so, the Recipient must provide a brief explanation describing the requested
   amendment.

b. Program Administrative Costs
   Note: The total Program Administrative Costs must not exceed $25,000 for the entire
   grant period of performance
     • Administrative Expenditures for the period of performance
     • Cumulative administrative Expenditures
     • Administrative Obligations for the period of performance
     • Cumulative administrative Obligations

    Note that Program Administrative Costs should be reported in the aggregate rather than
    separated out by Project. Recipients should refer to the Guidance for the Coronavirus
    Capital Projects Fund for Tribal Governments for more information about requirements
    related to Program Administrative Costs.

    Pursuant to the Grant Agreement, Recipients are permitted to charge both direct and
    indirect costs to their CPF award as Program Administrative Costs. Direct costs are those
    that are identified specifically as costs of implementing CPF, such as materials and supplies.
    Recipients are reminded of the requirement for costs to be treated consistently. In particular,

2 For additional information on final reports, see 2 CFR 200.344(a).



 Coronavirus Capital Projects Fund Compliance and Reporting Guidance for Tribal Entities
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    the Uniform Guidance at 2 CFR 200.403(d) provides that a cost may not be assigned to a
    Federal award as a direct cost if any other cost incurred for the same purpose in like
    circumstances has been allocated to the same Federal award as an indirect cost.
   If a Recipient has a current Negotiated Indirect Cost Rate Agreement (“NICRA”), then the
   Recipient may use its current NICRA to charge indirect costs to its CPF award. However, if
   the Recipient does not have a current NICRA, the Recipient may elect to use the de minimis
   rate of 10 percent of the modified total direct costs to charge indirect costs to its CPF award
   pursuant to 2 CFR 200.414(f). Recipients that apply their NICRA to their award may do so to
   the extent that the total administrative expenses does not exceed $25,000.

c. Project Information: The Annual Report should contain the following for each Recipient,
   some of which may be automatically populated by Treasury:

      •   Federal Award Identification Number (FAIN).
      •   A brief description with sufficient detail to provide an understanding of the goal(s) and
          major activities that will be funded by the Project.
      •   Type of owner for the capital asset (such as private, public-private partnership, Tribal
          government, co-operative, etc.).
      •   For consortia, provide for each Tribal government represented, as applicable:
             o Name
             o Contact information
             o Date of award
             o Total award amount
      •   Start date for construction (Planned/Actual) (if applicable)
      •   Date for completion of construction (Planned/Actual) (if applicable)
      •   Date of the initiation of operations (Planned/Actual)

   If applicable, the Recipient will also be required to answer the following questions regarding
   additional sources of funding being used in conjunction with the CPF award:

      •   Is CPF funding used in conjunction with other federal funding for the Project? (Y/N)
      •   If “Y”:
              o Provide the Program Name and Assistance Listing number of the other
                  program(s) providing federal funding
      •   Provide the amount of the other federal funding obligated (by Assistance Listing
          number)
      •   Total amount budgeted from all sources, including all non-CPF sources.

   Throughout the Project, the Recipient will be accountable for the accuracy of this information
   and for reflecting any changes in each Annual Report submission.

d. Project Obligations and Expenditures: For each Project, the Recipient will report the
   following as they relate to Expenditures. Consortia will report the following for each member
   Tribe. (NOTE: Program Administrative Costs must be reported separately from Project
   Obligations and Expenditures to avoid double counting):
      • Current period Obligation
      • Cumulative Obligation
      • Current period Expenditure

 Coronavirus Capital Projects Fund Compliance and Reporting Guidance for Tribal Entities
                                                 4
         •   Cumulative Expenditure

Program Income: For approved projects that are not Broadband Infrastructure Projects (i.e.
Digital Connectivity Technology and Multipurpose Community Facility Projects, or other
projects), Recipients must add program income to their CPF award pursuant to 2 CFR 200.307.
Note that program income must be utilized and applied to benefit the same project from which it
was generated. Recipients must report on program income earned and expended for each
reported specified use during the reporting period:
        •    Current period Program Income Earned
        •    Current period Program Income Expended
        •    Cumulative Program Income Earned
        •    Cumulative Program Income Expended

Recipients must certify that program income generated from CPF funds is used for the purposes
and subject to the terms and conditions of the CPF award. Program income must also be
included in the calculation of Obligations and Expenditures reported for these projects. Program
income includes but is not limited to income from fees for services performed, or the use or
rental or real or personal property acquired under the CPF award. For more information on what
constitutes “Program Income,” see 2 CFR 200.1.

e. Project Status: The Recipient will be asked to report on Project status each reporting period
   in five categories:

         •   Not Started
         •   Completed less than 50 percent
         •   Completed 50 percent or more
         •   Completed
         •   Cancelled

f.    Narrative Response: Please describe any significant successes or challenges experienced
      related to the CPF grant.
g. Early Closeout Interest: Recipients that report the full expenditure of its CPF award
   allocation in the 2026 CPF Annual Report due July 31, 2026 will see a pop-up box after
   submitting their report. The pop-up box will prompt the Recipient to indicate “yes” or “no”
   whether it is interested in closing out its CPF award prior to the end of the period of
   performance (December 31, 2026).

       The response supplied will only indicate to Treasury that the Recipient is or is not interested
       in pursuing early closeout. The response does not, by itself, constitute a request for or
       approval of award closeout.

       Remember: All Recipients will be required to complete a final Closeout report. Closeout
       guidance is forthcoming.

h. Required Performance Indicators and Project Data:
   The following programmatic data is required for each corresponding specified use. Note that
   not all data elements will be required in each Annual Report and that the frequency of

     Coronavirus Capital Projects Fund Compliance and Reporting Guidance for Tribal Entities
                                                    5
    submission will vary depending on the data element, the Project status, and other
    components.


Broadband Infrastructure Projects – (Installation or enhancement of
broadband infrastructure meeting minimum service standards)

The Recipient must provide Project-level data for the categories below.

   Note: A consortium reporting on behalf of multiple Tribes must provide the following data for
   each Broadband Infrastructure Project funded by each Tribe.
     • Project technology type(s) (Planned/Actual)
            o Fiber
            o Coaxial Cable
            o Terrestrial Fixed Wireless
            o Other (specify)
     • Total number of locations served (Planned/Actual)
            o Total number of locations served, broken out by speeds:
                    Pre-CPF Investment:
                      • Number receiving 25/3 Mbps or below
                      • Number receiving between 25/3 Mbps and 100/20 Mbps
                    Post-CPF Investment (Planned/Actual):
                      • Number receiving minimum 100/100 Mbps
                      • Number receiving minimum 100/20 Mbps and scalable to 100/100
                          Mbps
            o Total number of funded locations served, broken out by type (Planned/Actual):
                    Residential
                      • Total Housing Units
                    Business
                    Community anchor institution (Example: fire station, police station,
                       school, library, social services, or other Tribal government building)
     • Speed tiers offered and corresponding non-promotional prices, including associated
         fees, for each speed tier of broadband service.

   For each location served by a Project, the Recipient must submit the following information to
   Treasury using a predetermined file format that will be provided by Treasury on the CPF
   website; in most cases, the internet service provider (ISP), should collect this information
   and provide it to the Recipient for submission to Treasury:
     • Latitude/longitude at the structure where service will be installed
     • Technology used to offer service at the location
     • Location Type
            o Residential
                    If Residential, Number of Housing Units
            o Business
            o Community anchor institution
     • Speed tier at the location pre-CPF investment
            o Below 25/3 Mbps
            o 25/3 Mbps or greater but less than 100/20 Mbps

 Coronavirus Capital Projects Fund Compliance and Reporting Guidance for Tribal Entities
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     •   Speed and latency at the location post-CPF investment
            o Maximum download speed offered
            o Maximum download speed delivered
            o Maximum upload speed offered
            o Maximum upload speed delivered
            o Latency
     •   Standardized FCC Identifiers
            o Fabric ID # (Broadband Serviceable Fabric Locations)
            o FCC Issued Provider ID #

Digital Connectivity Technology Projects – (Deployment of digital
connectivity technologies (e.g., public Wi-Fi) to be owned by the Recipient)

   Note: A consortium reporting on behalf of multiple Tribes must provide the following data for
   each Digital Connectivity Technology Project funded by each Tribe.

     •   Describe where the digital connectivity technology will be distributed or installed (in the
         case of public Wi-Fi equipment) or other location information as appropriate.
     •   Device type (Select all that apply)
           o Public Wi-Fi Equipment
           o Other
     •   For each selected device type, provide: (Planned/Actual)
           o Total number of devices purchased (Planned/Actual)
           o Total Expenditure per device type (Planned/Actual)
     •   Total number of individuals utilizing new digital connectivity technology
         (Planned/Actual)

Purchasing Devices – (Purchasing devices to be owned by the Recipient and
utilized by or distributed to households, businesses, or other organizations to facilitate
internet access)

   Note: A consortium reporting on behalf of multiple Tribes must provide the following data for
   each Purchasing Devices Project funded by each Tribe.
     • Describe where the devices will be distributed or installed (in the case of public Wi-Fi
         equipment) or other location information as appropriate.
     • Whether the Recipient maintains ownership of the equipment purchased.
     • Device type (Select all that apply)
         o Laptops
         o Tablets
         o Desktop Computers
         o Other
     • For each selected device type, provide:
           o Total number of devices purchased (Planned/Actual)
           o Total Expenditure per device type (Planned/Actual)
     • Total number of individuals using devices (Planned/Actual)
     • If applicable, a brief narrative explaining the number and types of digital literacy
         trainings and other support services provided to enable use of the devices, including

 Coronavirus Capital Projects Fund Compliance and Reporting Guidance for Tribal Entities
                                                 7
         the number of individuals who attend or make use of the trainings and support
         services (Planned/Actual)


Multi-Purpose Community Facility Projects – (Projects to construct or
improve buildings that are designed to jointly and directly enable work, education, and
health monitoring)

   Note: A consortium reporting on behalf of multiple Tribes must provide the following data for
   each Multi-Purpose Community Facility Project funded by each Tribe

     •   Physical location (example street address, latitude/longitude) of each Multi-Purpose
         Community Facility funded in whole or in part by CPF (Planned and Actual)
     •   Investment type
            o New construction, to include acquisition of property for development
            o Renovation/expansion of existing structure, to include acquisition of an existing
                structures for renovation/expansion
     •   What does the Multi-Purpose Community Facility provide (Check all that apply)
            o Classroom/Educational Facility
            o Computer Lab
            o Multi-purpose Space
            o Telemedicine Room
            o Other (with explanation)
     •   Estimated total number of individuals using the capital asset (Actual)


Case-by-Case Reviews

For Projects submitted for Case-by-Case Review, Treasury will work with the Recipient to
develop metrics and performance measures for the associated Projects. As one component of
their submission, Recipients will be asked to provide performance measures for review by
Treasury. Performance indicators proposed should include both output and outcome measures.




 Coronavirus Capital Projects Fund Compliance and Reporting Guidance for Tribal Entities
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Part 3: General Guidance
This section is an overview of Recipients’ compliance responsibilities under the Capital Projects
Fund.

It is the Recipient’s responsibility to ensure that its CPF award funds are used in compliance
with all applicable statutes, regulations, and guidance published by Treasury, and the
requirements of any other funding sources used in conjunction with CPF award funds.
Recipients must maintain proper documentation supporting determinations of allowable costs
and proper internal controls.

A. Compliance Requirements
All Recipients of federal funds must complete financial, performance, and compliance reporting
as required by the Grant Agreement, 2 CFR 200.328, 2 CFR 200.329, and as outlined in Part 2
of this guidance. Expenditures may be reported on a cash or accrual basis as long as the
methodology is disclosed and consistently applied. Recipients must maintain accounting records
for compiling and reporting accurate financial data in accordance with appropriate accounting
standards and principles.

B. Uniform Administrative Requirements
CPF awards are subject to the requirements set forth in the Uniform Guidance at 2 CFR Part
200 as in effect on the date of the Grant Agreement, except as otherwise provided by Treasury
guidance. Recipients should review the Uniform Guidance requirements applicable to their use
of Capital Projects Fund grant funds and Capital Projects.
The following sections provide a general summary of Recipients’ compliance responsibilities
under applicable statutes and regulations, including the Uniform Guidance. Note that the
descriptions below are only general summaries. All Recipients and Subrecipients should
carefully review the Uniform Guidance requirements, the Grant Agreement, and all other
regulatory and statutory requirements applicable to CPF.
1. Internal Controls
Per 2 CFR 200.303, and the definition of internal controls in the Uniform Guidance at 2 CFR
200.1, Recipients must establish and maintain effective internal controls to manage their CPF
award in compliance with Federal statutes, regulations, and the Grant Agreement. Recipients
should review program requirements, the Grant Agreement, and the approved Projects to
determine and record eligible uses of CPF grant funds.
2. Allowable Costs/Cost Principles
Recipient may only use award funds for Program Administrative Costs and costs to carry out the
Projects described in the Recipient’s approved Application, subject to the Capital Projects Fund
Guidance for Tribal Governments, and the requirements of the cost principles provided in 2 CFR
Part 200, Subpart E. As outlined in the Uniform Guidance at 2 CFR Part 200, Subpart E
regarding Cost Principles, allowable costs must meet the following criteria: (1) be allowable,
necessary, reasonable, and allocable for the performance of the Federal award, (2) be accorded
consistent treatment as either a direct cost or indirect cost (and as either a Project cost or
administrative cost), and (3) be adequately documented. Recipients are responsible for the
effective administration of Federal awards, application of sound management practices, and
administration of Federal funds in a manner consistent with the program objectives and terms
and conditions of the award.

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                                                9
3. Cash Management
Tribal awards are generally paid as single lump-sum payments to Tribal recipients or their
designated consortia. Tribal recipients must expend CPF funds by the end of the period of
performance, December 31, 2026. (Unlike in the case of some other grant programs, CPF
recipients will not have the ability to liquidate financial obligations after the end date of the
period of performance.) Any grant funds that are not used by the end of the period of
performance must be returned to Treasury as part of the closeout process pursuant to 2 CFR
200.344(d). Treasury will issue additional closeout instructions at a later date.
Treasury has made the determination that if a Tribal recipient fully disburses award funds before
the end of the period of performance, the timing and amount of advance payments from
Treasury are as close as is administratively feasible to the actual disbursements by a Tribal
recipient, and are therefore in compliance with 2 CFR 200.305(b)(1).

4. Earned Interest
Tribal government recipients should track the amount of interest earned on total Federal awards
per year received from all Federal awarding agencies. If the amount of interest earned per year
is $500 or less, a Tribal government recipient may keep the interest earned for administrative
expenses. If the amount of interest earned in one year is more than $500, a Tribal government
recipient must return the additional interest according to the instructions found at 2 C.F.R.
200.305(b)(9).
If a recipient receives $250,000 or more in total Federal awards per year, it must maintain those
funds in interest-bearing accounts, unless certain conditions apply. Please consult 2 C.F.R.
200.305(b)(8) for further detail.
5. Period of performance and Pre-Award Costs
The period of performance for the CPF grant begins on the date that Treasury countersigns the
Grant Agreement (the period of performance start date) and ends on December 31, 2026,
unless otherwise indicated. 3 Recipients may use CPF funds to pay for certain eligible costs
incurred after March 15, 2021, but before the period of performance start date (Pre-Award
Costs) subject to certain conditions. Any Pre-Award Costs must be disclosed, explained, and
submitted along with corresponding application materials to be reviewed and approved by
Treasury. 4 For pre-award costs incurred after March 15, 2021, but prior to execution of the
Grant Agreement, Recipients are required to provide reasonable assurance that the costs were
incurred pursuant to the negotiation of and in anticipation of the Capital Projects Fund award
and are necessary for the efficient and timely performance of the Project. Such costs are
allowable only to the extent they would have been allowable if incurred after the date of the
Capital Projects Fund award and only with the written approval of Treasury. All funds must be
used for costs incurred during the period of performance or for Pre-Award Costs.
6. Program Income
Other than for program income generated by broadband infrastructure projects, Recipients must
add program income to their CPF award pursuant to 2 CFR 200.307. Any program income


3 Treasury may, in its sole discretion, grant extensions to the period of performance upon request from CPF recipients
4 Recipients should refer to the Grant Agreement for additional information about Pre-Award Costs.



 Coronavirus Capital Projects Fund Compliance and Reporting Guidance for Tribal Entities
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generated from CPF funds must be used for the purposes and under the conditions of CPF.
Treasury requires that program income be utilized and applied to benefit the same project from
which it was generated. Program income includes but is not limited to income from fees for
services performed or fees from the use or rental of real or personal property acquired under
federal awards. Interest earned on advances of federal funds is not program income. For more
information on what constitutes “Program Income,” see 2 CFR 200.1.
Recipients not using CPF funds for a broadband infrastructure project should calculate,
document, and record their program income. Treasury additionally encourages Recipients to
implement written policies that explicitly identify appropriate allocation methods, accounting
standards and principles, compliance monitoring checks for program income calculations, and
records.
Treasury’s SLFRF and CPF Supplementary Broadband Guidance for Tribal Governments,
published on January 31, 2024, provides guidance on program income generated by broadband
infrastructure projects.
7. Use of Authorized Representatives, Subrecipients, and Contractors
Tribal governments may delegate to an authorized representative such as a Tribal consortium
the authority to apply for and receive funds on behalf of the Tribe. In some cases, the
consortium or another entity may also serve as a subrecipient by carrying out the project on
behalf of the Tribe.

Regardless of whether or not a Tribal government delegates authority to an authorized
representative or subawards funds to a consortium or another entity, the Tribal government is
the Recipient and is ultimately responsible for ensuring compliance with reporting and other
program requirements. If a Tribal government issues a subaward or uses a contractor, the Tribal
government is responsible for complying with the provision of the Uniform Guidance governing
subrecipient monitoring and oversight of contractors, including reporting requirements.
Subrecipients have 90 days to submit their final reports to the Recipient, having the remaining
30 days to submit their final report to Treasury. See 2 CFR 200.331 regarding the differences
between a subrecipient and a contractor and 2 CFR 200.332 regarding Recipient responsibilities
for subrecipient monitoring.

8. Other Compliance Obligations
Recipients must ensure that they remain in compliance with the Grant Agreement. These
obligations include the following items in addition to those described above:

a. Recordkeeping Requirements. Recipients must maintain records and financial documents
   for five years after all CPF funds have been expended or returned to Treasury. Wherever
   practicable, such records should be collected, transmitted, and stored in open and machine-
   readable formats.

   Recipients must agree to provide or make available such records to Treasury upon request,
   and to any authorized oversight body, including but not limited to the
   Government Accountability Office (GAO), Treasury’s Office of Inspector General (OIG), and
   the Pandemic Relief Accountability Committee (PRAC).

b. Single Audit Requirements. Recipients and Subrecipients that expend $750,000 or more
   in Federal awards during their fiscal year – or, for fiscal years that start on or after October


 Coronavirus Capital Projects Fund Compliance and Reporting Guidance for Tribal Entities
                                                 11
    1, 2024, that expend more than $1,000,000 in Federal awards during their fiscal year - will
    be subject to an audit under the Single Audit Act and its implementing regulation at 2 CFR
    Part 200, Subpart F. 5 If a Tribal government does not spend more than $750,000 in Federal
    funds in their fiscal year – or, for fiscal years that start on or after October 1, 2024, does not
    spend more than $1,000,000 in Federal funds in their fiscal year, it can disregard the single
    audit requirement for that year.

    Recipients are responsible for procuring or otherwise arranging for audits required as part of
    their CPF award and ensuring the auditor has the necessary experience to perform a Single
    Audit. Information with instructions for how auditors must perform these audits can be found
    in the Uniform Guidance at 2 CFR 200.514 through 200.520 and the section on CPF in the
    annual Compliance Supplement issued by the Office of Management and Budget.
    Recipients may use the administrative costs category of the CPF to pay for the proportion of
    the Single Audit costs attributable to CPF. CPF requires these costs to be expended before
    the end of the period of performance.




5 This threshold takes into consideration all federal award funds, not limited to the CPF award.



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Appendix 1: Definitions
     Treasury will apply the following definitions for purposes of this reporting guidance. Terms
not defined herein shall have the definitions contained in Uniform Guidance.

    a. “Annual Report” has the meaning set forth in Part 2.
    b. “Broadband Infrastructure Project” has the meaning set forth in Section I.C.a of the
         Guidance for the Coronavirus Capital Projects Fund for Tribal Governments
    c. “Capital Project” or “Project” has the meaning set forth in Section I.C of the
         Guidance for the Coronavirus Capital Projects Fund for Tribal Governments
    d. “Capital Projects Fund Statute” means Section 604 of the Social Security Act, as added
       by section 9901 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2 (Mar. 11,
       2021), codified as 42 U.S.C. § 804.
    e. “Consortium” means an association of two or more Tribal governments.
    f.   “Contractor” is an entity that receives a contract by which a CPF Recipient or
         Subrecipient purchases property or services needed to carry out a CPF Project or
         Program. See 2 CFR 200.1; 200.331
    g. “Digital Connectivity Technology Project” has the meaning set forth in Section I.C.a of
       the Guidance for the Coronavirus Capital Projects Fund for Tribal Governments.
    h. “Expenditure” is the amount that has been incurred as a liability of the entity (the service
       has been rendered or the good has been delivered to the entity).
    i.   “Grant Agreement” means the agreement executed between the Recipient’s authorized
         representative and Treasury that state the terms and conditions of the funds, reporting
         and recordkeeping, and other requirements.
    j.   “Grant Closeout” means the process whereby a grant’s final report and accounts are
         reconciled upon completion of the Project or the end of the period of performance.
    k. “Multi-Purpose Community Facility Project” has the meaning set forth in Section I.C.a of
       the Guidance for the Coronavirus Capital Projects Fund for Tribal Governments.
    l.   “Obligations” are orders placed for property and services, contracts and subawards
         made, and similar transactions that require payment.
    m. “Output” is a quantity of a product or service delivered by a program.
    n. “Performance Indicator” or “Indicator” is a measurable value that indicates the state or
       level of something. “Program Administrative Costs” are defined for purposes of this
       Grant Agreement as (i) costs associated with completing the Application and (ii) costs
       related to complying with grant administration and audit requirements including both
       direct and indirect administrative costs.
    o. “Period Covered” is the set amount of time for which an Annual Report requests
       information.
    p. “Pre-Award Costs” has the meaning set forth in Part 3. Section B.5.




 Coronavirus Capital Projects Fund Compliance and Reporting Guidance for Tribal Entities
                                                13
       q. “Project” is the construction, purchase, and installation of, and/or improvements to
          capital assets that are designed to directly enable work, education, and health
          monitoring
       r. “Recipient” is a Tribal government that receives a CPF award from Treasury. The term
          Recipient does not include Subrecipients or individuals that are beneficiaries of the
          award.
       s. “Subrecipient” is an entity that receives a subaward from a CPF Recipient to carry out a
          capital project on behalf of a CPF Recipient. Subrecipients may include, but are not
          limited to, other levels or units of government, non-profits, or private entities. See 2 CFR
          200.1; 200.331.
       t.   “Treasury” means the U.S. Department of the Treasury.
       u. "Reporting Portal” refers to the online portal that will be used to submit reports to
          Treasury.
       v. “Uniform Guidance” means the Uniform Administrative Requirements, Cost Principles,
          and Audit Requirements for Federal Awards, located in Title 2 of the Code of Federal
          Regulations (2 CFR Part 200).


Revision log
 Version         Date Published         Summary of Changes
 1.0             May 4, 2023            Initial Publication
 1.3             June 7, 2023            • Pg 9, added FCC standardized identifier
                                              requirements.
 1.4             July 17, 2026           • Pg 3, added information on requesting an
                                              amendment to an approved CPF application
                                         • Pg 5, added information on reporting program
                                              income in the annual report
                                         • Pg 5, added information on indicating early
                                              closeout interest
                                         • Pg 9, added note that the Uniform Guidance in
                                              effect on the date of the Grant Agreement is
                                              applicable
                                         • Pg 11, added information on program income
                                              and reference to the SLFRF and CPF
                                              Supplementary Broadband Guidance for Tribal
                                              Governments
                                         • Pg 12, added increase to Single Audit threshold
                                              for fiscal years beginning on or after October 1,
                                              2024




 Coronavirus Capital Projects Fund Compliance and Reporting Guidance for Tribal Entities
                                                   14


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