Coronavirus Relief Fund Prime Recipient Desk Review Procedures Released

Thoughtware Alert Nov 02, 2020
Government

The U.S. Department of the Treasury (Treasury) Office of Inspector General (OIG) released the “Coronavirus Relief Fund Prime Recipient Desk Review Procedures” on October 26, 2020, outlining the Treasury OIG’s compliance monitoring procedures. Prime recipients are organizations that have directly received the federal Coronavirus Relief Fund (CRF) proceeds and are financially accountable for their use and disbursement. This guide provides the desk review criteria used by the Treasury OIG to evaluate the prime recipient’s documentation supporting the uses of CRF proceeds and assess risk of unallowable use of funds.

Prime recipient documentation is compared to the CRF reporting requirements as outlined by the “Coronavirus Relief Fund Reporting Requirements Update” released July 31, 2020, and the “Coronavirus Relief Fund: Prime Recipient Quarterly GrantSolutions Submissions Monitoring and Review Procedures Guide” released August 31, 2020.

The September 21, 2020, Treasury frequently asked questions document also offers some helpful information on reporting and record-keeping.

If it is determined a prime recipient failed to comply with requirements, the Treasury OIG has the authority to recoup CRF proceeds. For experienced prime grant recipients, the desk review procedures hold may seem familiar, but for agencies new to grants administration and disbursement, it could cause some anxiety.

According to the desk review procedures released by the OIG’s office on October 26, 2020, the selection of a prime recipient for review will include consideration of the following:

  • Exhibiting a high degree of difficulty in the quarterly reporting process
  • Submitting one or more late quarterly reports
  • Triggering a noncompliance status in one or more quarterly reports

Prime recipients can use this document as a guide to evaluate their documentation processes and use of CFR proceeds and make adjustments to proactively prepare in the event a desk review occurs. The review may include reviewing results of Single Audit(s) and other audits, data analytics of the prime recipient’s GrantSolutions data, and samples of payment types and individual transactions for review, among other things.

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