OFFICE OF

INSPECTOR GENERAL

DEPARTMENT OF THE TREASURY

WASHINGTON, D.C. 20220

1 

July 2, 2020

OIG-CA-20-021

MEMORANDUM FOR CORONAVIRUS RELIEF FUND RECIPIENTS

FROM: Richard K. Delmar /s/

Deputy Inspector General 

SUBJECT: Coronavirus Relief Fund Reporting and Record Retention 

Requirements

Title VI of the Social Security Act, as amended by Title V of Division A of the 

Coronavirus Aid, Relief, and Economic Security Act (Public Law 115-136), provides 

that the Department of the Treasury (Treasury) Office of Inspector General (OIG) is 

responsible for monitoring and oversight of the receipt, disbursement, and use of 

Coronavirus Relief Fund payments. Treasury OIG also has authority to recover 

funds in the event that it is determined a recipient of a Coronavirus Relief Fund 

payment failed to comply with requirements of subsection 601(d) of the Social 

Security Act, as amended, (42 U.S.C. 801(d)). Accordingly, we are providing 

recipient reporting and record retention requirements that are essential for the 

exercise of these responsibilities, including our conduct of audits and 

investigations. 

Reporting Requirements and Timelines

Each prime recipient of Coronavirus Relief Fund payments1

1 Prime recipients include all 50 States, Units of Local Governments, the District of Columbia, U.S. 

Territories, and Tribal Governments that received a direct payment from Treasury in accordance 

with Title V.

 shall report Coronavirus 

Disease 2019 (COVID-19) related “costs incurred” during the “covered period”2

2 Refer to Treasury’s guidance dated June 30, 2020 for more information on costs incurred and the 

covered period.

(the period beginning on March 1, 2020 and ending on December 30, 2020), in the 

manner of and according to the timelines outlined in this memorandum. As 

described below, each prime recipient shall report interim and quarterly data and 

other recipient data according to these requirements. Treasury OIG is working on 

development of a portal with GrantSolutions3

3 A grant management service provider under the U.S. Department of Health and Human Services. 

that is expected to be operational on

 
2 

September 1, 2020, for recipients to report data on a quarterly basis. Until the 

GrantSolutions portal is operational, each prime recipient shall follow the interim 

reporting requirements. Treasury OIG will notify each prime recipient when 

GrantSolutions is operational or of any changes to the expected September 1, 2020 

start date. 

Interim Reporting for the period March 1 through June 30, 2020

By no later than July 17, 2020, each prime recipient is responsible for reporting costs 

incurred during the period March 1 through June 30, 2020. For this interim report, prime 

recipients need only report totals by the following broad categories:

a. Amount transferred to other governments; 

b. Amount spent on payroll for public health and safety employees; 

c. Amount spent on budgeted personnel and services diverted to a substantially 

different use; 

d. Amount spent to improve telework capabilities of public employees; 

e. Amount spent on medical expenses; 

f. Amount spent on public health expenses; 

g. Amount spent to facilitate distance learning; 

h. Amount spent providing economic support; 

i. Amount spent on expenses associated with the issuance of tax anticipation notes; 

and

j. Amount spent on items not listed above. 

Recipients should consult Treasury’s guidance and Frequently Asked Questions in 

reporting costs incurred during the period March 1 through June 30, 2020. The total of 

all categories must equal the total of all costs incurred during that period. A spreadsheet 

is attached for your use in providing the data. As discussed below, the prime recipient 

will be required to report information for the period March 1 through June 30, 2020 into 

GrantSolutions once it is operational.

Quarterly Reporting 

Each prime recipient of Coronavirus Relief Fund payments shall report COVID-19 related 

costs into the GrantSolutions portal. Data required to be reported includes, but is not 

limited to, the following: 

1. the total amount of payments from the Coronavirus Relief Fund received from 

Treasury; 

2. the amount of funds received that were expended or obligated for each project or 

activity; 

3. a detailed list of all projects or activities for which funds were expended or 

obligated, including:

a. the name of the project or activity; 

b. a description of the project or activity; and
3 

4. detailed information on any loans issued; contracts and grants awarded; transfers 

made to other government entities; and direct payments made by the recipient

that are greater than $50,000. 

The prime recipient is responsible for reporting into the GrantSolutions portal information 

on uses of Coronavirus Relief Fund payments. 

Recipient Portal Access: For future quarterly reporting, each prime recipient will have 

GrantSolutions portal access for three (3) individuals: two (2) designees (preparers) to 

input quarterly data and one (1) official authorized to certify that the data is true, 

accurate, and complete.4

4 The certifying official is an authorized representative of the recipient organization with the legal authority

to give assurances, make commitments, enter into contracts, and execute such documents on behalf of 

the recipient.

By no later than July 17, 2020, please provide the name, title, 

email address, phone number, and postal address of these individuals so that portal 

access can be granted. After this information is received, guidance on the 

GrantSolutions portal access and data submission instructions will be issued separately. 

Reporting timeline

By no later than September 21, 2020, recipients shall submit via the portal the first 

detailed quarterly report, which shall cover the period March 1 through June 30, 2020. 

Thereafter, quarterly reporting will be due no later than 10 days after each calendar 

quarter. For example, the period July 1 through September 30, 2020, must be reported

no later than October 13, 2020 (Tuesday after the 10th day of October and the 

Columbus Day Holiday). Reporting shall end with either the calendar quarter after the 

COVID-19 related costs and expenditures have been liquidated and paid or the calendar 

quarter ending September 30, 2021, whichever comes first. 

Record Retention Requirements

Recipients of Coronavirus Relief Fund payments shall maintain and make available to the 

Treasury OIG upon request all documents and financial records sufficient to establish 

compliance with subsection 601(d) of the Social Security Act, as amended, (42 U.S.C. 

801(d)), which provides:

(d) USE OF FUNDS.—A State, Tribal government, and unit of local government shall use 

the funds provided under a payment made under this section to cover only those costs 

of the State, Tribal government, or unit of local government that— 

1. are necessary expenditures incurred due to the public health emergency 

with respect to COVID-19;

2. 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

 
4 

3. were incurred5

5 Refer to Treasury’s guidance dated June 30, 2020 for more information on the definition of costs 

incurred.

during the period that begins on March 1, 2020, and 

ends on December 30, 2020.

Records to support compliance with subsection 601(d) may include, but are not 

limited to, copies of the following:

1. 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; 

2. budget records for 2019 and 2020;

3. payroll, time records, human resource records to support costs 

incurred for payroll expenses related to addressing the public health 

emergency due to COVID-19;

4. receipts of purchases made related to addressing the public health 

emergency due to COVID-19;

5. contracts and subcontracts entered into using Coronavirus Relief Fund 

payments and all documents related to such contracts; 

6. grant agreements and grant subaward agreements entered into using

Coronavirus Relief Fund payments and all documents related to such

awards; 

7. all documentation of reports, audits, and other monitoring of 

contractors, including subcontractors, and grant recipient and 

subrecipients; 

8. all documentation supporting the performance outcomes of contracts, 

subcontracts, grant awards, and grant recipient subawards; 

9. all internal and external email/electronic communications related to use 

of Coronavirus Relief Fund payments; and

10. all investigative files and inquiry reports involving Coronavirus Relief 

Fund payments.

Records shall be maintained for a period of five (5) years after final payment is 

made using Coronavirus Relief Fund monies. These record retention requirements 

are applicable to all prime recipients and their grantees and subgrant recipients, 

contractors, and other levels of government that received transfers of Coronavirus 

Relief Fund payments from prime recipients. 

Thank you and we appreciate your assistance.