How tribes can track, report use of Coronavirus Relief Funds

With the next Coronavirus Relief Funds reporting deadline coming September 12 for the Treasury’s GrantSolutions portal, it’s critical tribes compile their data to fit Treasury requirements.

In addition, understanding the reporting requirements can help shape your strategy for spending those funds to help with the fallout from COVID-19.

The Treasury is requiring tribes to submit all expenses from March 1 to June 30, 2020 in to their GrantSolutions portal between the time it’s launched and September 12.

While the expenses are the same that you submitted July 17 in your interim report, it’s a good idea to review your expenditures and requirements.

Many of you may have had to file that interim report before you received notification of COVID-19 relief funds and guidance on eligible expenditures. The GrantSolutions portal gives you an opportunity to correct any mistakes.

In addition, organizing your data and how you plan to track it now can help ease the process for future reporting.

How to categorize expenses

The Treasury requires you to capture expenditures in 10 broad categories:

1. Amounts transferred to other governments
2. Amount spent on payroll for public health and safety employees
3. Amount spent on budgeted personnel and services diverted to a substantially different use
4. Amount spent on telework capabilities of public employees
5. Amount spent on medical expenses
6. Amount spent on public health expenses
7. Amount spent to facilitate distance learning
8. Amount spent providing economic support
9. Amount spent on expenses associated with the issuance of tax anticipation notes
10. Amount spent on items not listed above

New GrantSolutions requirements

The Treasury is also requiring the following additional data points will be required to be submitted once the GrantSolutions portal is operational:

1. The total amount of payments from the Coronavirus Relief Fund received from Treasury
2. The amount of funds received that were expended or obligated for each project or activity
3. A detailed list of all projects or activities for which funds were expended or obligated, including:
   1. The name of the project or activity
   2. A description of the project or activity
4. Detailed information on any loans issued contracts and grants awarded, transfers made to other government entities and direct payments made by the recipient that are greater than $50,000

What to do now

To ease the compilation of future reports and best ensure that the allocation is spent in accordance with the guidance, we recommend you rewrite your budgets of Coronavirus Relief Fund (CRF) expenditures to be focused on projects or activities. And make sure those projects and activities fall in one of the 10 categories.

For example, your CRF budget would be compiled in summary with at least the following information:

Then each project or activity would have a detailed budget:

This format will help in both preparing the required expenditure reports as well as provide reasonable assurance that the expenditures fall within the allowable categories.  You can find additional detailed guidance on what falls into each of the categories on the Treasury’s website.

How Wipfli can help

Our team has decades of experience working with tribal governments and agencies. Combined with our extensive knowledge regarding regulations for Coronavirus Relief Funds we can help you extend your relief dollars for lasting impact while ensuring regulatory compliance. See how we can help you today on our CARES Act Funding Allocation Guide for Tribal Governments or read these articles for additional insights from our team:

New guidance on paid administrative leave for tribal government employees

PPP eligibility expanded for entities with legal gaming revenue

Tribal-focused summary of CARES Act

4 strategies to help tribes track expenses during COVID-19