- Deadline approaching: Coronavirus Relief Fund (CRF) recipients must submit a detailed quarterly report on September 21, 2020.
- Expenditures need to be classified according to one of 18 predefined categories.
- CARES Act tribal funds must be used by December 30, 2020.
New updates on reporting requirements
As tribal entities reconcile the costs associated with responding to the COVID-19 public health emergency, they need to stay mindful of the reporting requirements.
While we’ve previously addressed the basics of CARES Act tribal funds, reporting requirements has been an evolving concern. The U.S. Treasury Office of Inspector General (OIG) released a July 2, 2020 memorandum that outlined reporting and record-keeping requirements that the OIG planned to apply to CRF fund recipients, and July 30 guidance further clarified those rules.
The requirements apply to all tribal governments (and other entities) that received CRF allocation. Because of the varied scope and scale of tribal governments, meeting those reporting requirements may be particularly burdensome.
September 21 deadline requirements
By September 21, each prime recipient is responsible for reporting costs incurred during the period March 1 through June 30, 2020.
Current guidance indicates that expenditures should be grouped by project, i.e., a grouping of related activities that together are intended to achieve a specific goal. For example, tribes may group food security activities, such as weekly food baskets or prepared meal delivery into one project.
The constraints of the reporting tool mean that every expenditure must be assigned a “project.” Certain relief efforts may not fit with a group of related efforts, and that’s okay. But those expenditures will still have to be defined as a “project,” even if they are a standalone effort.
For every project, the prime recipient will be required to enter the project name, identification number, description, and status of completion. So you can see how appropriate project groupings can streamline your reporting efforts and reduce workload.
Once a project is entered into the GrantSolutions portal (expected to be live by September 1), the prime recipient will be able to report on the project’s expenditures. You will need to select the specific expenditure category from the available options from a dropdown menu:
- Administrative expenses
- Budgeted personnel and services diverted to a substantially different use
- COVID-19 testing and contact tracing
- Economic support (other than small business, housing and food assistance)
- Expenses associated with the issuance of tax anticipation notes
- Facilitating distance learning
- Food programs
- Housing support
- Improve telework capabilities of public employees
- Medical expenses
- Nursing home assistance
- Payroll for public health and safety employees
- Personal protective equipment
- Public health expenses
- Small business assistance
- Unemployment benefits
- Workers’ compensation
- Items not listed above - to include other eligible expenses that are not captured in the available expenditure categories
Each prime recipient shall also provide detailed obligation and expenditure information for any contracts and grants awarded, loans issued, transfers made to other government entities, and direct payments made by the prime recipient that are greater than or equal to $50,000.
First quarter report most labor intensive
CRF fund organizers should plan on putting extra time and attention into developing the first quarterly report due on September 21. That report will require descriptions of each project or activity funded via the CRF. Justifications may be required around how much money was applied to project costs.
CRF dollars can fuel tribal advancements – if you spend the funds before the deadline
CARES act dollars can be spent to improve technology in a number of areas – including remote work, distance learning and telehealth.
The shift to remote working and remote service delivery may have revealed gaps in how tribal employees communicate with each other and serve tribe members. The CARES Act stimulus dollars are a chance to invest in tribe and create a high-performing, modern government administration.
For questions regarding eligible uses of Coronavirus Relief Fund payments, and how to organize reporting, recipients can reach out to Wipfli’s tribal practice. Additional information, such as frequently asked questions and guidance for tribes, is also available from the Treasury site.
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