Many tribal nations acquired CARES Act funds to assist their tribal governments and enterprises during the COVID-19 crisis. Review highlights of the Coronavirus Relief Fund reporting and recordkeeping requirements.
Key insights
- Tribal governments must report coronavirus-related costs incurred from March 1, 2020, through December 30, 2020, beginning September 1, 2020. Start by registering on SAM.gov.
- The first quarterly report is due September 21, 2020, for the quarter ended June 30, 2020. Thereafter, quarterly reporting is due no later than 10 days after the end of each calendar quarter.
- The Treasury Office of Inspector General (OIG) developed a portal with GrantSolutions for data reporting.
- Review the Treasury OIG’s list of reporting and recordkeeping requirements.
The Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law on March 27, 2020, bringing relief to Indian Country and the rest of the United States during the growing pandemic. Since becoming law, tribal governments have had numerous questions about how the $8 billion appropriation could be allocated and used.
Need assistance with CRF reporting and recordkeeping?
On July 31, 2020, the Treasury Office of Inspector General (Treasury OIG) released its Coronavirus Relief Fund Reporting Requirements Update OIG-CA-20-025, which provides guidance about quarterly reporting requirements.
Let’s review the reporting requirements, timelines, and record retention guidelines.
Reporting requirements
The Treasury OIG reporting requirements are broken into nine areas:
- Projects
- Obligations and expenditures
- Grants greater than or equal to $50,000
- Loans greater than or equal to $50,000
- Contracts greater than or equal to $50,000
- Direct payments greater than or equal to $50,000
- Transfers greater than or equal to $50,000
- Aggregate reporting below $50,000
- Aggregate reporting on payments to individuals
Each tribal government must assign two preparers and one authorizing official. The preparers will enter data into the GrantSolutions portal and then validate the data entered. The authorizing official must review and certify the data prior to submission in the portal.
Reporting timelines
The reporting timelines as listed in the Treasury OIG’s guidance are as follows:
| Reporting Cycle | Reporting Period | Reporting Due Date | OIG Review Period | Data Extract to PRAC |
|---|---|---|---|---|
| Cycle 1 | 3/1/2020 – 6/30/2020 | 9/21/2020 | 9/22/2020 – 9/29/2020 | 9/30/2020 |
| Cycle 2 | 7/1/2020 – 9/30/2020 | 10/13/2020 | 10/14/2020 – 10/20/2020 | 10/21/2020 |
| Cycle 3 | 10/1/2020 – 12/31/2020 | 1/11/2021 | 1/12/2021 – 1/20/2021 | 1/21/2021 |
| Cycle 4 | 1/1/2021 – 3/31/2021 | 4/12/2021 | 4/13/2021 – 4/20/2021 | 4/21/2021 |
| Cycle 5 | 4/1/2021 – 6/30/2021 | 7/12/2021 | 7/13/2021 – 7/20/2021 | 7/21/2021 |
| Cycle 6 | 7/1/2021 – 9/30/2021 | 10/12/2021 | 10/13/2021 – 10/20/2021 | 10/21/2021 |
Source: https://www.oversight.gov/sites/default/files/oig-reports/OIG-CA-20-025.pdf
Record retention requirements
- Tribal governments, as prime recipients of Coronavirus Relief Fund (CRF) payments, shall maintain and make available to Treasury OIG all financial records and documents sufficient to comply with subsection 601(d) of the Social Security Act, as amended, (42 U.S.C. 801(d)), which requires that CRF payments are used to cover costs that:
- Are necessary expenditures incurred due to the public health emergency with respect to COVID-19;
- Were not accounted for in the budget most recently approved as of the date of enactment of this section for the state or government; and
- Were incurred during the period that begins on March 1, 2020, and ends on December 30, 2020
- Records to supplement compliance may include, but are not limited to:
- General ledger and subsidiary ledgers used to account for (a) the receipt of Coronavirus Relief Fund payments and (b) the disbursements from such payments to meet eligible expenses related to the public health emergency due to COVID-19;
- Budget records for 2019 and 2020;
- Payroll, time records, human resource records to support costs incurred for payroll expenses related to addressing the public health emergency due to COVID-19;
- Receipts of purchases made related to addressing the public health emergency due to COVID-19;
- Contracts and subcontracts entered into using Coronavirus Relief Fund payments and all documents related to such contracts;
- Grant agreements and grant subaward agreements entered into using Coronavirus Relief Fund payments and all documents related to such awards;
- All documentation of reports, audits, and other monitoring of contractors, including subcontractors, and grant recipient and subrecipients;
- All documentation supporting the performance outcomes of contracts, subcontracts, grant awards, and grant recipient subawards;
- All internal and external email/electronic communications related to use of Coronavirus Relief Fund payments; and
- All investigative files and inquiry reports involving Coronavirus Relief Fund payments.
- Records must be maintained for five years after the final payment is made using CRF funds. This requirement is applicable to all tribal governments as prime recipients and the subgrant recipients and grantees, contractors, and other levels of government that received transfers of CRF payments from the tribal government.
How we can help
Though the CARES Act has provided some relief to Indian Country, tribal nations must now employ the proper recordkeeping and reporting processes and internal controls to submit timely and accurate reporting. Our CLA tribal services team can help. Get in touch if you have any questions on funding usage or additional needs.