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Posted: September 3, 2020

Department of Treasury OIG Issues FAQs Related to CRF Reporting and Recordkeeping

On August 28, 2020, the Department of the Treasury Office of Inspector General (Treasury OIG) issued Coronavirus Relief Fund Frequently Asked Questions Related to Reporting and Recordkeeping (OIG-CA-20-028). These FAQs are in response to questions asked via email, the CARES Hotline, and various stakeholder outreach sessions including the August 5, 2020 NAFOA sponsored webinar Understanding Coronavirus Relief Fund Reporting Requirements with Treasury OIG.

These FAQs supplements Treasury OIG’s memorandums Coronavirus Relief Fund Recipient Reporting and Record Retention Requirements (OIG-CA-20-021), issued on July 2, 2020, and Coronavirus Relief Fund Reporting Requirements Update (OIG-CA-20-025), issued on July 31, 2020.

NAFOA urges Indian Tribal Governments to confirm they have submitted their relevant designee information to Treasury OIG to access the GrantSolutions portal. Beginning September 1, 2020 the Prime Recipients, i.e. Indian Tribal Governments, will begin reporting their first detailed quarterly report of related costs incurred from March 1, 2020 to June 30, 2020 which is due by September 21, 2020. For a complete timeline see Coronavirus Relief Fund Reporting Requirements Update (OIG-CA-20-025) for more information.

Download Department of Treasury OIG CRF FAQs

Selected Topics from FAQs:

5. If the prime recipient distributes funds to an agency or department within the prime recipient’s government, is the agency or department considered the prime recipient or a sub-recipient when funds obligated are $50,000 or more?
The agency or department is considered part of the prime recipient as they are all part of the same legal entity that received a direct CRF payment from Treasury. Obligations and expenditures that the agency or department incurs with the CRF proceeds must be collected by and reported in the GrantSolutions portal by the prime recipient as if they were obligated or expended by the prime recipient.

18. Is an individual that a prime recipient obligates a contract, grant, loan, or direct payment recommended to register in
No. Detailed information of an individual that the prime recipient obligates any amount to will not be reported in the GrantSolutions portal; the obligations and related expenditure(s) to individuals will be reported in the aggregate.

25. What is a transfer to another government entity?
A transfer to another government entity is a disbursement or payment to a government entity that is legally distinct from the prime recipient. See the list of government entities in Question 26 below.

26. For transfers to another government entity, what type of entity is considered another government entity?
The following organization types are considered another government entity:
• State government
• County government
• City/Township Government
• Special District Government
• US Territory or Possession
• Indian/Native American Tribal Government (Federally Recognized)
• Indian/Native American Tribal Designated Organization

68. How does the CRF audit relate to Single Audit?
CRF payments are considered to be Federal financial assistance subject to the Single Audit Act (31 U.S.C. sec. 7501-7507). The related provisions of the Uniform Guidance, 2 C.F.R. sec. 200.303 regarding internal controls, sec. 200.330 through 200.332 regarding sub-recipient monitoring and management, and subpart F regarding audit requirements provides detailed information. The results of a prime recipient’s Single Audit will be evaluated as part of the Treasury OIG’s desk reviews and any audits initiated.

For a complete understanding NAFOA encourages you to review the Treasury OIG CRF FAQs in their entirety.

Role of the Department of the Treasury Office of Inspector General

The Department of the Treasury Office of Inspector General is responsible for monitoring and oversight of the receipt, disbursement, and use of Coronavirus Relief Fund (CRF) payments as authorized by Title VI of the Social Security Act, as amended by Title V of Division A of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). Treasury OIG was also assigned authority to recover funds in the event that it is determined a recipient of a CRF payment failed to comply with requirements of subsection 601(d) of the Social Security Act, as amended, (42 U.S.C. 801(d)). Recipient reporting and record retention requirements are essential for the exercise of these responsibilities, including our conduct of audits and investigations.
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