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What You Need to Know About COVID-19 Reporting and Recordkeeping

by eCivis on September 2, 2020
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COVID-19 Reporting and RecordkeepingIf you’re still wondering how to properly report on your grants from the Coronavirus Relief Fund (CRF), you’re not alone. Many other government entities are in the same boat. 

That’s why the Department of Treasury Office of Inspector General (OIG) just issued the Coronavirus Relief Fund Frequently Asked Questions Related to Reporting and Recordkeeping (OIG-CA-20-028). This report works to answer new frequently asked questions regarding how to best organize your records and follow up on reporting for any funding from the CRF under the CARES Act. 

Specifically, the document addresses and clarifies common terms for recipients and gives guidance on reporting in the GrantSolutions portal as well as addresses questions regarding the past document OIG-CA-20-021, issued on July 2, 2020, and updated OIG-CA-20-025, issued on July 31, 2020. 

Beginning September 1, 2020, the prime recipients of CRF payments will begin reporting COVID-19 related costs incurred from March 1, 2020 to December 30, 2020 in the GrantSolutions portal.

The entire document is nineteen pages of questions and answers. Fortunately, we went through and summarized some of the most important information you need to know right now. Here are some highlights of what you can find in that document. You can find our full breakdown here. 

Defining Prime Recipients and Subrecipients

A prime recipient is an entity that received a CRF payment directly from the Treasury in accordance with the CARES Act.

For purposes of reporting in the GrantSolutions portal, a subrecipient is any entity to which a prime recipient issues a contract, grant, loan, direct payment, or transfer to another government entity of $50,000 or more.

This definition is unique to CRF amounts of $50,000 or more. The 2 CFR 200 definition does not stipulate an amount. Prime recipients are to monitor and manage subrecipients as defined in 2 CFR section 200.330 through 200.332

System for Award Management Registration (SAM.gov) Registration

This section provides clarification regarding registration of subrecipients in SAM.gov. Treasury’s OIG guidance suggests all subrecipients be registered, but it is not required. However, if subrecipients are not registered, it will be the prime recipient’s responsibility to input all pertinent information for them, reducing the administrative burden on the prime if the subrecipient is registered.

For example, a state receives direct funding from the Department of Treasury. They distribute to a county, who becomes the subrecipient. If the county is not registered in SAM.gov, the state will be responsible for inputting all data elements for the subrecipient, which are:

  • Legal Name
  • Address Line 1
  • Address Line 2, if applicable
  • Address Line 3, if applicable
  • City Name
  • State Code
  •  Zip Code
  • Country Name (selection menu)
  • Organization Type (selection menu)  

This would be especially burdensome if the state distributed funding to multiple counties who were not registered.

Updated Reporting Guidance

The latest reporting guidance clarifies how a prime recipient can gather and report information in GrantSolutions. Specifically, the document provides guidance on reporting structure, timelines, and reasoning for use of the $50,000 subrecipient threshold. Here is an example of reporting structure in GrantSolutions:

Projects

Obligations of $50,000 or more and related expenditures
  • Contracts of $50,000 or more
    • Obligations (individually reported) and links to projects, if applicable
    • Related expenditures (individually reported) and link to projects, if applicable

 

Grants of $50,000 or more

  • Obligations (individually reported) and link to projects, if applicable
  • Related expenditures (individually reported) and link to projects, if applicable
Loans of $50,000 or more
  • Obligations (individually reported) and link to projects, if applicable
  • Related expenditures (individually reported) and link to projects, if applicable
Transfers to other government entities of $50,000 or more
  • Obligations (individually reported) and link to projects, if applicable
  • Related expenditures (individually reported) and link to projects, if applicable
Direct Payments of $50,000 or more
  • Obligations (individually reported) and link to projects, if applicable
  • Related expenditures (individually reported) and link to projects, if applicable

Aggregate obligations and expenditures of contracts, grants, loans, direct payments, and transfers to other government entities below $50,000 (reported in total by obligation type)

Aggregate obligations and expenditures to individuals, regardless of the amount (reported in total)

GrantSolutions Portal: Coming Soon

The GrantSolutions Portal should be available on September 1, 2020 for most users. An upload feature will be available for select high volume prime recipients. The upload feature will be available after September and timing of that schedule will be communicated to those select recipients.

The GrantSolutions portal can only sustain up to three users per prime recipient: two preparers and one authorizing official. In order to grant portal access, each user must have a unique email address and users cannot have the same email address. GrantSolutions will show a cumulative view of expenditures reported by the prime recipient.

Overview of Record Retention/Audit

The CARES Act provides that Treasury OIG is responsible for monitoring and oversight of the receipt, disbursement, and use of CRF payments. As such, all CRF payments received by the prime recipient are subject to audit. In this regard, an audit will be at the prime recipient level and may involve reviewing the prime’s subrecipients. In the event that it is determined the prime recipient failed to comply with requirements of subsection 601(d) of the Social Security Act, as amended, (42 U.S.C. 801(d)), those funds will be recouped by Treasury OIG. 

Treasury OIG may monitor subrecipients as part of their audit of the prime recipient.

The CARES Act and the Treasury guidance and FAQs will be used as criteria for allowability of costs. According to Treasury’s FAQs, provisions of the Uniform Guidance, 2 C.F.R. sec. 200.303 regarding internal controls, 2 C.F.R. sec. 200.330 through 200.332 regarding subrecipient monitoring and management, and subpart F regarding audit requirements are applicable to CRF payments. Subpart E is not applicable.

There are procedures for monitoring, reviewing, and approving prime recipient’s quarterly GrantSolutions submissions. Treasury OIG will also conduct desk reviews, for which other procedures have been developed, to further evaluate the prime recipient’s documentation supporting the reported uses of CRF proceeds, as well as, results of other audits (i.e. Single Audit), among other things

It’s also important to note that CRF payments are considered to be Federal financial assistance subject to the Single Audit Act (31 U.S.C. sec. 7501-7507). 

If you haven’t already, make sure to review the latest Uniform Grant Guidance updates

Worried about how to manage your COVID-19 reporting requirements? Schedule a free demo to see our grants management solution in action. 

 

Topics: Grant Articles & News, Grants Management Articles

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