OFFICE OF 

INSPECTOR GENERAL 

U.S.DEPARTMENT OF THE INTERIOR 

CARES Act Flash Report 

The Office of Insular Affairs Took 

Appropriate Action With CARES Act Funds 

On March 27, 2020, the President signed into law the Coronavirus Aid, 

Relief, and Economic Security Act (CARES Act), which provided the 

U.S. Department of the Interior (DOI) with $756 million to support the 

needs of DOI programs, bureaus, Indian Country, and the Insular Areas. 

We have reviewed the Office of Insular Affairs’ (OIA’s) oversight of 

the CARES Act funds to the Insular Area governments to date and 

provide this summary report as a snapshot. We found that the OIA has 

taken prompt and immediate action in its allocation of CARES Act 

funds to Insular Area governments. 

The U.S. Congress appropriated $55 million for the OIA to distribute 

among the seven Insular Area governments to assist them in their 

preparation for, response to, and prevention measures for the COVID19 pandemic. The OIA’s responsibilities include grant distribution, 

award administration, and oversight of the Insular Area governments’ 

expenditure of funds. 

The Insular Areas of the United States 

American Samoa 

Commonwealth of the Northern Mariana Islands 

Federated States of Micronesia 

Guam 

Republic of the Marshall Islands 

Republic of Palau 

U.S. Virgin Islands 

The DOI received 

$756 million 

under the CARES Act to 

respond to impacts from 

the coronavirus: 

• $453 million for the 

Bureau of Indian Affairs 

• $157.4 million for DOI 

operations (Office of the 

Secretary) 

• $69 million for the 

Bureau of Indian 

Education 

• $55 million for the 

Office of Insular Affairs 

• $12 million for the 

Bureau of Reclamation 

(BOR)–water resources 

• $8.1 million for the 

BOR–policy and 

administration 

• $1 million for the Office 

of Inspector General 

• $500,000 for the BOR– 

Central Utah Project 

Completion Act 

We reviewed the OIA’s actions related to its CARES Act grant 

funding allocations, including the information on its website, how it 

allocated the funding amongst the Insular Area governments, its 

policies and procedures for the funding, and its communication to the 

governments. We also reviewed the grant requirements and the 

requirements specific to each Insular Area government. 

CARES Act Flash Report • No. 2020-WR-041 • Issued June 25, 2020 1 
 

The OIA Took 

Immediate 

Action 

Shortly after the passage 

of the CARES Act, the OIA 

had: 

• Updated its website to 

make its allocated 

funding transparent 

• Developed a formula for 

allocating the funding 

amongst Insular Area 

governments 

• Issued announcement 

memoranda to all seven 

Insular Area 

governments to notify 

them of the funding 

available and to provide 

guidance 

 

 

 

 

 

 

 

 

The OIA received

The OIA’s Actions 

Shortly after the passage of the CARES Act—the OIA (1) updated its 

website to include the funding allocated to the OIA, (2) developed a 

formula and distribution method to allocate $41.25 million to Insular 

Area governments ($13.75 million went into a reserve fund), and (3) 

issued official announcement memoranda to all seven governments to 

indicate funding that was available for immediate use and to provide 

tools and guidance. 

OIA Website 

The OIA promptly supplemented its official website with information 

on the CARES Act funding appropriated by Congress; its allocation of 

those funds; and instructions for the use of funds for preparation for, 

response to, and prevention measures for the COVID-19 pandemic. 

The OIA demonstrated a commendable level of transparency 

when it posted grant award allocations and distribution, grant 

award memoranda, and allocation data on its website. 

Allocation Formula and Distribution Method 

Of the $55 million it received in CARES Act funding, the OIA 

allocated $41.25 million to seven Insular Area governments and 

established a reserve fund for the remaining $13.75 million. The 

approach used to determine the funding allocations was a fair and 

equitable process, based on each Insular Area’s population percentage 

of the overall Insular Area population. The funds were made available 

for immediate action and must be expended by September 30, 2021. 

The OIA will withhold the established reserve funds for any further 

emergency needs or requests from nonprofit organizations in the 

Insular Areas and for partnership interagency agreements if they are 

needed. As of May 20, 2020, no claims had been submitted for the 

obligated funds, and $151,550 had been awarded from the funds held 

in reserve to Mañe’lu, a nonprofit organization located on Guam. 

The distribution of the $41.25 million in funds allocated is shown in 

Figure 1. 

CARES Act Flash Report • No. 2020-WR-041 • Issued June 25, 2020 2 
 

The OIA received 

$55 million 

under the CARES Act to 

respond to impacts from 

the coronavirus and has 

allocated $41.25 million: 

• $12,039,565 for Guam 

• $7,863,776 for the 

U.S. Virgin Islands 

• $7,737,390 for the 

Federated States of 

Micronesia 

• $4,079,020 for 

American Samoa 

• $4,042,585 for the 

Commonwealth of the 

Northern Mariana Islands 

• $3,894,720 for the 

Republic of the Marshall 

Islands 

• $1,592,945 for the 

Republic of Palau 

Figure 1: $41.25 Million of $55 Million Allocated by 

Population as of May 2020 

Percentage of Allocation 

Insular Area Population* Population† ($)‡ 

Guam 164,229 29.2 12,039,565 

U.S. Virgins 107,268 19.1 Islands 7,863,776 

Federated 

States of 105,544 18.8 7,737,390 

Micronesia 

American 55,641 9.9 4,079,020 Samoa 

Commonwealth 

of the Northern 55,144 9.8 4,042,585 

Mariana Islands 

Republic of the 53,127 9.4 3,894,720 Marshall Islands 

Republic of 21,729 3.9 1,592,945 Palau 

Totals 562,682 100% $41,250,000 

* The OIA provided the population totals; we did not verify them. 

† Population percentages arerounded. 

‡ Total is rounded. 

 

 

 

 

 

 

 

By creating a formula based on population percentages, the OIA 

used a fair approach to allocation of funds. 

Announcement Memoranda and Guidance 

The OIA’s official announcement memoranda included guidance for 

requesting drawdowns when applying for the funds. To expedite 

funding, the OIA did not require a detailed budget at the time of 

application, although supporting documentation is required before the 

drawdowns are processed. Along with its official announcement 

memorandum to each Insular Area government, the OIA provided the 

grant agreement, grant terms and conditions, and contact information 

should governments have any questions or concerns. 

We found the OIA’s process for distributing, awarding, and 

administering the funds; the memoranda; and the guidance provided to 

the governments clearly stipulated the application, documentation, and 

CARES Act Flash Report • No. 2020-WR-041 • Issued June 25, 2020 3 
 

OIA Guidance 

to Insular 

Area 

Governments 

The OIA instructed 

Insular Area 

governments that in 

using the allocated funds, 

they must: 

• Avoid conflicts of interest 

• Require approval for use 

of funds 

• Provide supporting 

documentation, such as a 

budget, that supports 

Insular Area government 

pandemic plans and 

U.S. Centers for Disease 

Control and Prevention 

guidance 

• Report on a prescribed 

quarterly schedule 

• Comply with applicable 

laws and regulations 

• Observe all applicable 

grant terms and 

conditions 

 

 

 

 

 

 

 

 

 

g

Sharing Lessons Learned

insular reporting requirements for grant recipients and provide crucial 

internal controls (see sidebar). These controls will help the OIA 

safeguard its assets, minimize risk, and encourage adherence to 

internal policies and procedures. The controls will also help the Insular 

Area governments more easily release funds for use to accomplish 

their mission. 

By providing clear processes and guidance to the Insular Area 

governments, the OIA is reducing risk to CARES Acts funds and 

helping the governments more easily use the funds to respond 

to their COVID-19 pandemic-related needs. 

Grant Terms and Conditions for the 

Insular Area Governments 

The grants terms and conditions set the rules and guidelines that 

Insular Area governments must follow so that grant funds are used as 

intended and in an efficient manner. The DOI’s and the OIA’s terms 

and conditions are summarized below. 

Recipient Responsibilities: The recipient must comply with the laws 

and regulations governing the use of Federal grant funds. Instances of 

noncompliance, or belief of noncompliance, should be reported to the 

OIA. 

Procurement of Goods and Services With Grant Funds and 

Record Retention: All grant awards and subawards must comply with 

the applicable regulations and all congressional directives and 

guidance for the use or reprogramming of appropriated funds. All 

records related to this award must be retained and made accessible in 

accordance with applicable regulations. 

Limitations on the Use of Grant Funds: Grant funds are not to be 

used for any purpose other than that for which they are offered unless 

the OIA provides prior approval. Any change in the approved scope of 

work or project budget must be submitted to the grant manager for 

written approval. 

Scope of Work Requirements: Costs associated with the 

administration of OIA grant projects and programs are to be charged 

against the grant funds only as approved in the project budget in the 

scope of work. Any substantial change to the scope of work must be 

approved by the OIA grant manager. 

CARES Act Flash Report • No. 2020-WR-041 • Issued June 25, 2020 4 
 

We will reach out to the 

Insular Area public 

auditors to remind them of 

the common hazards and 

issues to remember when 

auditing grant funds and 

to offer best practices we 

have collected from past 

audit work, such as: 

• Ensuring sufficient 

workforce capacity 

• Ensuring use of the 

appropriate award vehicle 

• Maximizing competition in 

the source selection 

process 

• Ensuring background 

research and risk 

assessments of potential 

recipients 

• Monitoring documentation 

and use of funds by 

recipients 

• Reviewing recipient’s 

performance and financial 

reports 

Our Lessons Learned for 

CARES Act Awards report 

(https://www.doioig.gov/site 

s/doioig.gov/files/DOIOIG_C 

ARESActLessonsLearned_05 

2020.pdf) presents these 

lessons in greater detail. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Conflicts of Interest: Non-Federal entities and their employees must 

avoid conflicts of interest in the procurement of supplies, equipment, 

construction, and services by recipients and by sub-recipients. Internal 

controls must be established that include, at a minimum, procedures to 

identify, disclose, and mitigate or eliminate identified conflicts of interest. 

Data Availability: The Federal Government has the right to obtain, 

reproduce, publish, or otherwise use the data produced under a Federal 

award as well as authorize others to receive, reproduce, publish, or 

otherwise use such data for Federal purposes. 

Grant Fund Payment and Drawdown Requirements: Grantees 

must submit a completed Request for Advance or Reimbursement 

(SF-270), along with supporting documentation, to the OIA grant 

manager to draw down funds. 

Reporting Requirements: Grantees must submit a Federal Financial 

Report (SF-425) and a narrative project status report on a calendar 

year quarterly basis to its designated OIA grant manager as directed in 

the guidance. 

Marketing and Branding: The OIA stipulates how graphics and 

prescribed language should be displayed on all signs intended to 

identify the project and funders. 

Special Terms and Conditions for This Grant: Each drawdown 

request must include a detailed budget that shows how the funds were 

used, indicate how it supported the government’s pandemic plan, and 

include a copy of the pandemic plan. The OIA will approve advances 

if the required information is submitted. The OIA should be notified 

before to the expiration of the grant if the recipient does not require the 

full amount awarded. 

The DOI’s Standard Terms and Conditions: Recipients are to 

follow the DOI’s terms and conditions, such as acceptable payment 

systems; general provisions for following administrative requirements, 

cost principles, and single audit requirements; statutory and national 

policy requirements; and requirements related to environmental and 

construction projects. The full terms and conditions are available here: 

https://www.doi.gov/sites/doi.gov/files/migrated/doi-standard-awardterms-and-conditions-effective-december-2-2019.pdf 

The OIA has taken prompt and immediate action in its allocation 

of CARES Act funds to Insular Area governments. 

We commend the OIA for the actions it has taken to help the 

Insular Areas prepare for and respond to the numerous and 

unprecedented challenges that this pandemic has presented. 

CARES Act Flash Report • No. 2020-WR-041 • Issued June 25, 2020 5