2023 Emergency Rental Assistance Program Treasury 

DEPARTMENT OF THE TREASURY 

ASSISTANCE LISTING 21.023 EMERGENCY RENTAL ASSISTANCE PROGRAM 

I. PROGRAM OBJECTIVES

Note: This program is considered a “higher risk” program for 2023, pursuant to 2 CFR section 

200.519(c)(2). Refer to the “Programs with Higher Risk Designation” section of Part 8, 

Appendix IV, Internal Reference Tables, for a discussion of the impact of the “higher risk” 

designation on the major program determination process. 

Two pieces of legislation authorized funding for Emergency Rental Assistance. The 

authorizations include some different legal requirements. Therefore, this Compliance 

Supplement addresses the requirements as “ERA 1” and “ERA 2.” ERA 1 was authorized by 

Division N, Title V, Section 501 of the Consolidated Appropriations Act, 2021 (the Act), Pub. L. 

No. 116-260 (December 27, 2020), codified at 15 USC 9058a. ERA 2 was authorized by Title 

III, Subtitle B, Section 3201 of the American Rescue Plan Act (ARPA), 2021, Pub. L. No. 117-2 

(March 11, 2021), codified at 15 USC 9058c. Both ERA 1 and ERA 2 funding is defined as 

“other financial assistance” per 2 CFR Part 200.1 and both ERA 1 and ERA 2 are administered 

by Treasury as direct payments for specified use. 

The purpose of ERA is to provide direct payments to eligible entities to assist eligible 

households with financial assistance and to provide housing stability services and, in the case of 

ERA 2 as applicable, to cover the costs for other affordable rental housing and eviction 

prevention activities. ERA grantees may provide assistance directly to eligible landlords and 

utility providers on behalf of an eligible household or directly to an eligible household (See 15 

USC 9058a(c)(2)(C)(i) and FAQ 12 for more detail on landlords and utility provider 

participation in the program). Financial assistance for eligible households may include payment 

of rent, rental arrears, utilities and home energy costs, utilities and home energy costs arrears, 

and other expenses related to housing. ERA grantees may also use funds to provide housing 

stability services as authorized by the respective statutes. 

II. PROGRAM PROCEDURES

A. Overview

ERA 1 provided $25 billion for the US Department of the Treasury (Treasury) to make 

payments to States (defined to include the District of Columbia), US territories (Puerto 

Rico, US Virgin Islands, Guam, Northern Mariana Islands, and American Samoa), Indian 

tribes or their tribally designated housing entities, as applicable, the Department of 

Hawaiian Home Lands, and certain local governments with more than 200,000 residents. 

These entities are collectively referred to as “eligible grantees” or “ERA 1 grantees.” 

ERA 1 award funds may be used to provide financial assistance and housing stability 

services to eligible households. All ERA 1 grantees that submitted the requested 

documentation to Treasury and executed a financial assistance agreement received their 

total ERA 1 award funds in one payment. 

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ERA 2 provided $21.55 billion for Treasury to make payments to States (defined to 

include the District of Columbia), US Territories (Puerto Rico, US Virgin Islands, Guam, 

Northern Mariana Islands, and American Samoa), and local governments with more than 

200,000 residents. These entities are collectively referred to as “eligible grantees” or 

“ERA 2 grantees.” ERA 2 award funds may be used to assist eligible households with 

financial assistance and to provide housing stability services and, as applicable, to cover 

the costs for other affordable rental housing and eviction prevention activities. 

Pursuant to 15 USC 9058c (c)(1), Treasury made initial payments of 40 percent of an 

eligible grantee’s total award amount to each grantee under ERA 2 that submitted the 

required documentation and executed the financial assistance agreement. Through 

February 2022, Treasury made payments of the remaining 60 percent of ERA 2 grantees’ 

award funds after they certified that at least 75 percent of the initial ERA 2 payment had 

been obligated pursuant to 15 USC 9058c(c)(2). Beginning in February 2022, Treasury 

altered its ERA 2 payment tranche policy to allow grantees to receive the remainder of 

their ERA 2 award funds in two payments (half of the remaining balance, followed by the 

remaining balance), subject to potential reductions resulting from the implementation of a 

statutory reallocation requirement with each tranche payment only made after grantees 

certified that they have obligated at least 75 percent of the funds already disbursed 

pursuant to 15 USC 9058c(c)(2). 

Additional information on statutory differences between ERA 1 and ERA 2 are described 

in the Emergency Rental Assistance Frequently Asked Questions (FAQs) posted at: 

https://home.treasury.gov/policy-issues/coronavirus/assistance-for-state-local-and-tribalgovernments/emergency-rental-assistance-program/faqs. 

15 USC 9058a(b)(1)(A) directs Treasury to use US Census Bureau data for the most 

recent year for which data is available for population calculations for determining the 

populations of state and local governments. Funds are distributed via a per capita formula 

allocation detailed on Treasury.gov that considers the minimum allocation of $200 

million for states and the District of Columbia. Allocation amounts can be found via the 

following link: https://home.treasury.gov/policy-issues/coronavirus/assistance-for-statelocal-and-tribal-governments/emergency-rental-assistance-program/allocations-andpayments. 

Source of Governing Requirements 

Emergency Rental Assistance (“ERA 1”), Division N, Title V, Section 501 of the Consolidated 

appropriations Act, 2021, Pub. L. No. 116-260 (December 27, 2020) and codified as 15 USC 

9058a. 

Emergency Rental Assistance (“ERA 2”), Title III, Subtitle B, Section 3201 of the American 

Rescue Plan Act, 2021, Pub. L. No. 117-2 (March 11, 2021) codified as 15 USC 9058c. 

Section 15011 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act (Pub. L. 

No. 116-136), codified by 15 USC 9058a, as amended by Title VIII, Section 801(b) of 

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the Consolidated Appropriations Act, 2021 (Pub. L. No. 116-260), codified at 15 USC 9058c, on 

December 27, 2020. 

Treasury’s Frequently Asked Questions (FAQs) and related guidance available on Treasury.gov, 

including important version changes over time that can be found on the ERA website. 

Availability of Other Program Information 

1. General information for ERA is available on Treasury’s website at 

www.treasury.gov/ERA. Information includes the following documents: 

a. ERA 1 authorizing statute: https://www.govinfo.gov/content/pkg/PLAW116publ260/pdf/PLAW-116publ260.pdf (See pages 889 - 899) 

This document details information that is contained in the authorizing 

statute including funds appropriated for ERA 1. 

b. ERA 2 authorizing statute: https://www.govinfo.gov/content/pkg/PLAW117publ2/pdf/PLAW-117publ2.pdf (See pages 52 - 56) 

This document details information that is contained in the authorizing 

statute including funds appropriated for ERA 2. 

c. 15 USC 9058a(g)(1) regarding ERA 1 reporting: 

https://www.govinfo.gov/content/pkg/PLAW-116publ136/pdf/PLAW116publ136.pdf (See pages 260 - 262) 

This document provides information on grantee reporting the use of funds. 

d. ERA 1 Award Terms template: 

https://home.treasury.gov/system/files/136/Emergency-rental-assistanceterms-FINAL.pdf (See pages 1 - 5) 

This document provides award terms as a condition to the receipt of 

payment from Treasury for ERA 1. 

e. ERA 2 Award Terms template: 

https://home.treasury.gov/system/files/136/ERA2_Grantee_Award_Terms_ 

572021.pdf (See pages 1 - 5) 

This document provides award terms as a condition to the receipt of 

payment from Treasury for ERA 2. 

f. Treasury’s ERA Frequently Asked Questions (FAQs) and guidance are 

available at: https://home.treasury.gov/system/files?file=136/ERA-FAQ7.27.22.pdf (See pages 1-18) 

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Treasury released FAQs as guidance regarding ERA 1 and ERA 2 except 

where differences are specifically noted. 

g. Treasury’s ERA 1 Reallocation guidance: 

https://home.treasury.gov/system/files/136/UpdatedERA1ReallocationGui 

danceSep6.pdf (See pages 1 - 8) 

The ERA 1 statute requires Treasury to identify “excess funds” for 

reallocation from amounts Grantees have “not obligated” from their initial 

ERA 1 allocations. 

h. Treasury’s ERA 2 Reallocation guidance: 

https://home.treasury.gov/system/files/136/ERA2-Reallocation-GuidanceMarch-30-2022.pdf (See pages 1 - 6) 

The ERA 2 statute requires Treasury to identify funds for reallocation 

from amounts allocated to eligible Grantees, but not yet paid out to them. 

i. ERA Compliance and Reporting guidance: 

https://home.treasury.gov/policy-issues/coronavirus/assistance-for-statelocal-and-tribal-governments/emergency-rental-assistanceprogram/reporting (See web page) 

Treasury instituted a webpage that provides information and guidance on 

quarterly reporting and compliance. 

j. Guidance from the Treasury Office of Inspector General (OIG) related to 

the reporting of ERA fraud, waste, and abuse and any future monitoring of 

funds requirements (where applicable): https://home.treasury.gov/policyissues/coronavirus/assistance-for-state-local-and-tribalgovernments/emergency-rental-assistance-program/fraud (See web page) 

Treasury OIG provided guidance to grantees on what to do if they suspect 

fraud, waste, and abuse. 

a. ERA Promising Practices guidance: https://home.treasury.gov/policyissues/coronavirus/assistance-for-state-local-and-tribalgovernments/emergency-rental-assistance-program/promising-practices 

(See web page) 

2. Treasury has engaged with ERA grantees across the country to identify program 

strategies that promise to speed up program implementation, more efficiently 

deliver program benefits, enhance program integrity, and improve tenant and 

landlord access to programs. 

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2023 Emergency Rental Assistance Program Treasury 

a. ERA Program and Service Design guidance: 

https://home.treasury.gov/policy-issues/coronavirus/assistance-for-statelocal-and-tribal-governments/emergency-rental-assistanceprogram/service-design (See web page) 

Treasury provided guidance on consideration for good program design and 

delivery. 

III. COMPLIANCE REQUIREMENTS 

In developing the audit procedures to test compliance with the requirements for this federal 

program, the auditor must determine, from the following summary (also included in Part 2, 

“Matrix of Compliance Requirements”), which of the 12 types of compliance requirements have 

been identified as subject to the audit (noted with a “Y” in the summary matrix below), and then 

determine which of the compliance requirements that are subject to the audit are likely to have a 

direct and material effect on the federal program at the auditee. For each such compliance 

requirement subject to the audit, the auditor must use Part 3 (which includes generic details about 

each compliance requirement other than Special Tests and Provisions) and this program 

supplement (which includes any program-specific requirements) to perform the audit. When a 

compliance requirement is shown in the summary below as “N,” it has been identified as not 

being subject to the audit. Auditors are not expected to test requirements that have been noted 

with an “N.” See the Safe Harbor Status discussion in Part 1 for additional information. 

A B C E F G H I J L M N 

ActivitiesAllowed orUnallowedAllowableCosts/CostPrinciplesCashManagementEligibilityEquipment andReal PropertyManagementMatching,Level of Effort,EarmarkingPeriodOfPerformanceProcurement and Suspension and DebarmentProgramIncomeReportingSubrecipientMonitoringSpecialTests andProvisions 

Y Y N Y N N Y N N Y Y Y 

A. Activities Allowed or Unallowed 

1. Activities Allowed 

a. ERA 1 and ERA 2 funds may be used for administrative expenses, 

housing stability services, and financial assistance on behalf of an eligible 

household, as defined in the Treasury guidance. In the case of ERA 2, 

after October 2022, grantees that have obligated 75 percent of their 

allocations may choose to use up to 25 percent of their allocation for, 

“other affordable rental housing and eviction prevention purposes, as 

defined by the Secretary, serving very low-income families.” Treasury 

released guidance for these additional uses as FAQ 46 in July 2022. 

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b. 

c. 

d. 

Where applicable, the final ERA 1 payment amount distributed by 

Treasury to the ERA 1 grantee through an ERA 1 “redirect” and/or 

“reallocation” process, pursuant to Treasury’s Reallocation Guidance, is 

described on Treasury.gov. If a grantee receives redirected or reallocated 

funds, the funds are subject to the same requirements under the ERA 1 

Award Terms previously accepted by the grantee in connection with their 

ERA 1 award with the addition that grantees receiving reallocated ERA 1 

funds may request from Treasury an extension of their final obligation 

date from September 30, 2022, to December 29, 2022. Please see the ERA 

page at Treasury.gov and ERA FAQs for the latest guidance regarding 

eligible uses under ERA 1 and ERA 2. (See FAQs 1, 4-7, 16-20, 26-28, 35 

and 39-42) 

Administrative Expenses: The revised Award Terms for ERA 1 and ERA 

2 awards issued by Treasury permits ERA grantees to use award funds 

provided to cover both direct and indirect administrative costs. The cost of 

a grantee contacting a landlord to encourage their participation and 

acceptance of ERA assistance is one of many examples of an eligible 

administrative cost. Under ERA 1, a grantee may use up to 10 percent of 

the total award amount for direct and indirect administrative costs and 

may use up to 10 percent of the total award amount for housing stability 

services. Under ERA 2, a grantee may use up to 15 percent of the total 

award amount for direct and indirect administrative costs and may use up 

to 10 percent of the total award amount for housing stability services as 

described below (See also FAQ 29). 

Housing Stability Services: Under ERA 1, housing stability services 

includes case management and other services related to the COVID-19 

outbreak intended to help keep households stably housed. Under ERA 2, 

housing stability services do not have to be related to the COVID-19 

outbreak. For ERA 1 and ERA 2, housing stability services include those 

that enable households to maintain or obtain housing. Such services may 

include, among other things, eviction prevention and eviction diversion 

programs; mediation between landlords and tenants; housing counseling; 

fair housing counseling; housing navigators or promotors that help 

households access programs or find housing; case management related to 

housing stability; housing-related services for survivors of domestic abuse 

or human trafficking; legal services or attorney’s fees related to eviction 

proceedings and maintaining housing stability; and specialized services for 

individuals with disabilities or seniors that support their ability to access 

or maintain housing (See FAQ 23). 

Financial Assistance: Financial assistance to households includes payment 

of rent, rental arrears, utilities and home energy costs, utility and home 

energy costs arrears, and other expenses related to housing pursuant to 15 

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e. 

USC 9058a(c)(2)(A). Please note that under the ERA 1 program, award 

funds used for “other expenses” must be related to housing and “incurred 

due, directly or indirectly, to the novel coronavirus disease (COVID-19) 

outbreak” (See 15 USC 9058a(c)(2)(A)(v). However, the ERA 2 statute 

requires that “other expenses” be “related to housing” but does not require 

that they be incurred due to the COVID-19 outbreak (See 15 USC 

9058a(d)(1)(A)(V)). The amount of financial assistance for prospective 

rent cannot exceed three months under a single household application (See 

FAQ 10). There is no maximum dollar amount for the cumulative 

financial assistance that may be provided on behalf of an eligible 

household beyond the requirements set forth in the ERA FAQs. These 

requirements include that amounts paid be based on documentation of 

household income, leases, and equivalent forms (or for applicants unable 

to present adequate documentation, a written attestation from the applicant 

up to a monthly maximum of 100 percent of the greater of the Fair Market 

Rent or the Small Area Fair Market Rent for the area in which the 

applicant resides) and that the amount of assistance provided to any 

household under ERA 1 and ERA 2, including assistance provided by 

other ERA 1 and ERA 2 grantees cannot exceed 18 months (See FAQ 10). 

Financial assistance arrears may only cover household expenses accrued 

on or after March 13, 2020, up to a maximum of 15 months for ERA 1 and 

a maximum of 18 months, under ERA 1 and ERA 2 combined. For 

prospective rent assistance greater than three months up to the statutory 

maximum of 18 months under ERA 1 and ERA 2, the household must 

apply to the program again and the grantee must have sufficient funds. 

Households may receive up to 12 months of assistance under ERA 1 and 

an additional three months if necessary to ensure housing stability for the 

household for a total of three months. This means that for ERA 1, the 

maximum rental arrears monthly coverage period, where applicable, is 15 

months where necessary for housing stability and households may only 

receive up to three months of prospective rent, where applicable and 

qualifying (See FAQ 10). 

Examples of other costs for both ERA 1 and ERA 2 include relocation 

expenses (including prospective relocation expenses), rental security 

deposits, rental fees including application and screening fees, reasonable 

accrued late fees, Internet service to a given rental unit, and rental bonds 

where necessary to avoid an eviction order, as provided in the Treasury 

guidance and subject to certain conditions (for example, that Internet 

service expenses are eligible only if grantees establish policies governing 

the appropriate of use for this purpose). 

Other Affordable Rental Housing and Eviction Prevention Purposes: 

Treasury released FAQ 46 on July 2022 to define these uses. 

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B. Allowable Costs / Cost Principles 

The cost principles in 2 CFR Part 200, Subpart E (Cost Principles) except the 2 CFR 

200.418 and 2 CFR 200.419 apply to ERA 1 and ERA 2. Under ERA 1, a grantee may 

use up to 10 percent of the total award amount for direct and indirect administrative costs. 

Under ERA 2, a grantee may use up to 15 percent of the total award amount for direct 

and indirect administrative costs (See FAQ 29). 

E. Eligibility 

1. Eligibility for Individuals 

To ensure eligibility requirements are met, household eligibility should be tested 

to focus on whether grantees established and adhered to reasonable policies for 

evaluating household applications within Treasury’s framework providing for the 

use of self-attestation, categorical eligibility, and fact-specific proxies in 

qualifying circumstances. Specific eligibility requirement can be found in FAQ 1 

at https://home.treasury.gov/system/files?file=136/ERA-FAQ-7.27.22.pdf. 

This approach to eligibility was implemented in accordance with 15 USC 9058a, 

for ERA 1 in 15 USC 9058a(c)(2)(C)(ii) concerning documentation of payments 

to households, 15 USC 9058a(f)(2)(A) and (B) of the Act concerning signature 

requirements for applications and documentation required for tenants, 15 USC 

9058a (k)(1) concerning area median income determinations, and 15 USC 9058a 

(k)(3)(A)(I) and (II) concerning eligible household determinations and attestation 

requirements. This treatment is further explained in the ERA FAQs; 15 USC 

9058a; and the Treasury, Department of Justice and Department of Housing and 

Urban Development joint letter issued August 27, 2021 

(https://home.treasury.gov/system/files/136/Eviction-Moratorium-JointLetter.pdf). 

To the extent that a grantee has established and consistently followed its own 

reasonable procedures for implementing an eligibility determination process, 

consistent with Treasury’s guidance, it is not Treasury’s expectation that grantees 

should seek additional documentation from a beneficiary after the initial 

determination of eligibility has been completed, including for those determined to 

be eligible using self-attestation, categorical eligibility, or fact-specific proxies in 

qualifying circumstances. Testing of individual household eligibility-related 

documentation should be limited to material already collected by the grantee 

during application as much as possible to avoid imposing undue burden on 

households that remain at risk of housing instability. 

Treasury guidance related to determining where an applicant lives and the amount 

that they owe can be found in FAQ 5 

https://home.treasury.gov/system/files?file=136/ERA-FAQ-7.27.22.pdf. Grantees 

must obtain, if available, a current lease, signed by the applicant and the landlord 

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or sublessor, that identifies the unit where the applicant resides and establishes the 

rental payment amount. If a household does not have a signed lease, 

documentation of residence may include evidence of paying utilities for the 

residential unit, an attestation by a landlord who can be identified as the verified 

owner or management agent of the unit, or other reasonable documentation as 

determined by the grantee. In the absence of a signed lease, evidence of the 

amount of a rental payment may include bank statements, check stubs, or other 

documentation that reasonably establishes a pattern of paying rent, a written 

attestation by a landlord who can be verified as the legitimate owner or 

management agent of the unit, or other reasonable documentation as defined by 

the grantee in its policies and procedures. 

Additional Treasury guidance related to income determination can be found in 

FAQ 4 and related guidance ( 

https://home.treasury.gov/system/files?file=136/ERA-FAQ-7.27.22.pdf). ERA 2 

builds on the eligibility criteria in ERA 1 and permits additional flexibilities. 

The ERA FAQs document the full eligibility considerations for grantees to extend 

emergency assistance to vulnerable populations without imposing undue 

documentation burdens. As described, given the challenges presented by the 

COVID-19 pandemic, grantees may be flexible as to the particular form of 

documentation they require, including by permitting photocopies or digital 

photographs of documents, e-mails, or attestations from employers, landlords, 

caseworkers, or others with knowledge of the household’s circumstances. 

Grantees must require all applications for assistance to include an attestation from 

the applicant household that all information included is correct and complete. In 

all cases, grantees must document their policies and procedures for determining 

household eligibility to include policies and procedures for determining the 

prioritization of households in compliance with the statute and maintain records 

of their determinations. 

Grantees may rely on a written attestation without further documentation of 

household income from the applicant under three approaches: 

a. Self-attestation Alone – In order to provide assistance rapidly during the 

public health emergency related to COVID-19, the grantee may rely on a 

self-attestation of household income, financial hardship, and/or risk of 

homelessness and housing instability without further verification if the 

applicant confirms in their application or other document that they are 

unable to provide documentation, provided the other requirements detailed 

in Treasury guidance are satisfied. If an applicant is able to provide 

satisfactory evidence of residence but is unable to present adequate 

documentation of the amount of the rental obligation, grantees may accept 

a written attestation from the applicant to support the payment of 

assistance up to a monthly maximum of 100 percent of the greater of the 

Fair Market Rent or the Small Area Fair Market Rent for the area in which 

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the applicant resides, as most recently determined by HUD and made 

available at https://www.huduser.gov/portal/datasets/fmr.html; 

b. Categorical Eligibility – If an applicant household income has been 

verified to be at or below 80 percent of the area median income (for ERA 

1) or if an applicant household has been verified as a low-income family 

as defined in Section 3(b) of the United States Housing Act of 1937 (42 

USC 1437a(b)) (for ERA 2) in connection with another local, state, or 

federal government assistance program, grantees are permitted to rely on a 

determination letter from the government agency that verified the 

applicant’s household income or status as a low-income family, provided 

that the determination for such program was made on or after January 1, 

2020; and/or 

c. Fact-specific proxy – A grantee may rely on a written attestation from the 

applicant household as to household income if the grantee also uses any 

reasonable fact-specific proxy for household income, such as reliance on 

data regarding average incomes in the household’s geographic area. 

Grantees also have discretion to provide waivers or exceptions to this 

documentation requirement to accommodate disabilities, extenuating 

circumstances related to the pandemic, or a lack of technological access. 

In these cases, the grantee is still responsible for making the required 

determination regarding the applicant’s household income and 

documenting that determination. 

Grantees have discretion to provide waivers or exceptions to certain 

documentation requirements to accommodate disabilities, extenuating 

circumstances related to the pandemic, or a lack of technological access. In these 

cases, the grantee is still responsible for making the required determination 

regarding the applicant’s household income and documenting that determination. 

Pursuant to 15 USC 9058a(k)(3)(B), and 2 CFR 200.403, when providing ERA 1 

assistance, the grantee must review the household’s income and sources of 

assistance to confirm that the ERA 1 assistance does not duplicate any other 

assistance, including federal, state, or local assistance provided for the same costs. 

Grantees may rely on an attestation from the applicant regarding non-duplication 

with other government assistance, and the duplication requirement does not apply 

to ERA 2; however, to maximize program efficacy, Treasury encourages grantees 

to minimize the provision of duplicative assistance. 

Treasury strongly encourages grantees to rely on the self-certification of 

applicants with regard to whether their financial hardship meet statutory eligibility 

requirements. Similarly, with respect to determining whether one or more 

individuals within the household can demonstrate a risk of experiencing 

homelessness or housing instability, Treasury indicates that a grantee may rely on 

a past due utility or rent notice or eviction notice, evidence of unsafe or unhealthy 

living conditions (which may include overcrowding) or any other evidence of 

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risk, as determined by the grantee. Treasury clearly indicates that a grantee may 

rely on an applicant’s self-certification identifying the applicable risk factor or 

factors, without further documentation, if other documentation is not immediately 

available. 

After October 2022, grantees that have obligated 75 percent of their allocations 

may choose to use up to 25 percent of their allocation for, “other affordable rental 

housing and eviction prevention purposes, as defined by the Secretary, serving 

very low-income families.” Treasury released guidance for these additional uses 

as FAQ 46 in July 2022 -

Seehttps://home.treasury.gov/system/files?file=136/ERA-FAQ-7.27.22.pdf. In 

summary, eviction prevention purposes are those previously defined as housing 

stability uses. For affordable housing, the eligible uses include operation or 

development of affordable housing that utilizes another federal grant program for 

affordable housing development and has a 20 year affordability covenant. 

2. Eligibility for Groups of Individuals or Area of Service Delivery 

Not Applicable 

3. Eligibility for Subrecipients 

Not Applicable 

H. Period of Performance 

Under 15 USC 9058a(e)(1), the period of performance for ERA 1 awards began on the date that 

the grantee executed the ERA 1 Award Terms and ended on December 31, 2021. 15 USC 

9058a(h) extended the award period of performance from December 31, 2021, to September 30, 

2022. Pursuant to 15 USC 9058a(e)(2), Treasury extended the award period of performance to 

end on December 29, 2022 for ERA 1 grantees that receive reallocated funds. 

Under 15 USC 9058c(g), the period of performance for ERA 2 awards begins on the date that 

Treasury and the grantee executed the ERA 2 Award Terms and ends on September 30, 2025. 

All award funds not obligated or expended by the end of the period of performance date for ERA 

1 and ERA 2 awards must be returned to Treasury as part of the award closeout process pursuant 

to 2 CFR 200.344(d), including amounts distributed through redirection and reallocation. See 

also the ERA 1 Closeout Resource at 

https://home.treasury.gov/system/files/136/ERACloseoutResource_Final_9.16.22.pdf. 

L. Reporting 

1. Financial Reporting 

a. SF-270, Request for Advance or Reimbursement – Not Applicable 

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2. 

b. SF-271, Outlay Report and Request for Reimbursement for Construction 

Programs – Not Applicable 

c. SF-425, Federal Financial Report – Applicable 

Performance Reporting 

Title of Report: ERA Compliance Report 

PRA Number: 1505-0266 (ERA 1) and 1505-0270 (ERA 2) 

Reporting Cycle: Quarterly 

Authoritative Requirement: 15 USC 9058c; 2 CFR 200.328 (Financial report); 

and 2 CFR 200.329 (Performance report) 

Blank Copy of the Report: https://home.treasury.gov/system/files/136/ERATreasury-Portal-User-Guide-v2.pdf (see figures 3-7 for screenshots of user guide) 

Report Instructions: https://home.treasury.gov/policyissues/coronavirus/assistance-for-state-local-and-tribal-governments/emergencyrental-assistance-program/reporting 

Report Corrections: The Office of Recovery Program’s (ORP) reporting portal 

has built-in functionality to reopen a report and allow recipients to make edits 

after the reporting deadline. However, it is ORP’s policy that recipients may only 

make revisions if authorized by Treasury staff for a period of up to 60 days after 

the reporting deadline. After the revision period ends, the report is final. A 

resubmitted report becomes a recipient’s final report within ORP’s reporting 

portal. Recipients can generate PDFs of these reports at any time. 

Key Line Items1. Administrative Costs Ratio- Quantifiable Objective Criteria: Total 

obligations and/or expenditures for administrative costs does not exceed 

the relevant threshold of total allocation (10% across the prime and all 

subrecipients for ERA 1, not to exceed 15% for ERA 2 across the prime 

and all subrecipients) 

(See ERA Reporting Guidance, Appendix 7, Applicable Limitations on 

Administrative Expenses, page 52) 

2. Housing Stability Services Ratio- Quantifiable Objective Criteria: Total 

obligations and/or expenditures for housing stability services is not greater 

than 10% of the total amount allocated (See ERA Reporting Guidance, 

Appendix 7, Applicable Limitations on Administrative Expenses, page 

52). Examples of these services can be found as item 23 on ages 12 and 

13 of the July 27, 2022 FAQs located at 

https://home.treasury.gov/system/files?file=136/ERA-FAQ-7.27.22.pdf. 

3. System for Prioritizing Assistance- Quantifiable Objective Criteria: The 

number of households with less than 50% Area Median Income (AMI) 

receiving financial assistance is greater than the number of households 

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with greater than 50% AMI receiving assistance (See ERA Reporting 

Guidance, Section E, Number of Unique Participant Households at Certain 

Income Levels, page 27) 

4. Participant Households at Certain Income Levels Eligibility- Quantifiable 

Objective Criteria: The total households receiving assistance is not greater 

than the sum of Area Median Income (AMI) banded eligible households 

with a 5 to 10% margin of error to avoid false positives for medium to 

large recipients. Treasury is aware of some limited temporary income data 

availability and reporting lag due to waterfall distribution models required 

within the statutory design framework and related administrative 

processing delays, as well as the use of fact-based proxies or assistance 

based on participation in other programs. Does not apply to tribal 

recipients exempt from income reporting according to Treasury guidance 

and policy (See ERA Reporting Guidance, Section E, Number of Unique 

Participant Households at Certain Income Levels, page 27) 

3. Special Reporting 

Not applicable 

4. Special Reporting for Federal Funding Accountability and Transparency Act 

Although reporting on subaward information is applicable to ERA grantees 

pursuant to the award term set forth in Appendix A to 2 CFR Part 170, which is 

incorporated by reference in the ERA 1 and ERA 2 Award Terms, ERA grantees’ 

compliance with these reporting requirements is not subject to audit. 

M. Subrecipient Monitoring 

See Part 3, Section M, “Subrecipient Monitoring” for a general description of the 

compliance requirements, the related audit objectives, and suggested audit procedures. 

N. Special Tests and Provisions 

1. ERA 1 Funds Redirection 

Compliance Requirements 

Pursuant to 15 USC 9058a(b)(1)(A) and Treasury’s implementing instructions to 

requesting grantees, grantees are permitted to redirect ERA 1 funds when a locality 

receives an ERA 1 award and subsequently transfers 100 percent of the ERA 1 award 

funds received from Treasury to its eligible state and Treasury approves the transaction. 

The redirection of award funds is finalized when the locality has submitted the relevant 

redirection documentation to Treasury and Treasury has provided confirmation of 

acceptance. At that time, the locality’s ERA 1 award is cancelled, and the locality has no 

further legal obligation to Treasury under the ERA 1 award. 

Compliance Supplement 2023 4-21.023-13 
 

 

 

 

 

 

 

2023 Emergency Rental Assistance Program Treasury 

Audit Objectives 

The state’s ERA 1 award is modified by the amount of the funds transferred from the 

local government to the state and the state is responsible as the grantee for reporting on 

the use of the transferred award funds that become subject to the requirements set forth in 

the Award Terms previously accepted by the state in connection with its ERA 1 award. A 

local government that has redirected 100 percent of its ERA 1 award funds to its state but 

has not submitted the relevant redirection documentation to Treasury or is still awaiting 

confirmation of acceptance of submitted documentation by Treasury, is still responsible 

for complying with the ERA 1 Award Terms, including submitting Monthly and 

Quarterly reports until their redirection forms were submitted and accepted by Treasury. 

Suggested Audit Procedures 

(1) All voluntarily redirected ERA 1 award funds were approved by the 

grantee’s authorizing official in accordance with Treasury guidance; 

(2) All redirected ERA 1 award funds were deposited to the official, 

authorized bank account of the receiving grantee, as approved by 

Treasury; and 

(3) All ERA 1 award funds received through the redirection process are used 

in accordance with the ERA 1 Award Terms. 

2. ERA Funds Reallocation 

Compliance Requirements 

Pursuant to 15 USC 9058a(d), Treasury is required to reallocate “excess” ERA 1 award 

funds. Treasury’s objective in reallocations is to ensure ERA 1 award funds remain 

available to grantees in accordance with their jurisdictional needs and demonstrated 

capacity to deliver assistance while the ERA appropriations remain available. Treasury’s 

ERA 1 reallocation guidance on Treasury.gov and previewed here describes how grantees 

that have expenditure ratios below designated thresholds as of September 30, 2021, were 

subject to involuntary recapture, in the absence of mitigating actions, requiring the 

grantee to return funds to Treasury within the provided timeframes. Treasury continues to 

periodically assess expenditures using escalating expenditure benchmarks to identify 

excess funds. For the first assessment using data as of September 30, 2021, grantees 

could mitigate the impact of recapture by submitting a certification that the grantee’s 

financial assistance activity had since increased to a level beyond the minimum threshold, 

committing to a voluntary reallocation, or by providing a Performance Improvement 

Plan. Treasury’s reallocation guidance on Treasury.gov will continue to detail specific 

ERA reallocation timelines. The guidance also describes the voluntary reallocation 

process through which a grantee may request that Treasury reallocate its ERA 1 award 

funds to other ERA 1 grantees in the same state. Treasury is not recapturing funds from 

Compliance Supplement 2023 4-21.023-14 
 

 

 

 

 

2023 Emergency Rental Assistance Program Treasury 

Indian Tribes or Tribally Designated Housing Entities (TDHEs) prior to the end of the 

second quarter of 2022, except where a Tribal grantee, its TDHE, or housing authority 

voluntarily return funds to Treasury. Auditors should refer to the ERA 1 reallocation 

guidance at www.treasury.gov/era. Guidance for ERA 2 reallocation can also be found on 

this site. 

Updated information regarding ERA 2 reallocation was posted as an update to 

Reallocation Guidance in March 2022. 

Audit Objectives 

The reallocation expenditure ratio determines whether the grantee is subject to 

involuntary reallocation due to an insufficient ratio and the amount of excess funds 

subject to recapture by Treasury. Auditors should confirm the amounts reported as 

expended and obligated accurately capture the grantee’s housing activity at the time of 

submission, as reflected in a grantee’s award and/or financial systems, and that grantees 

receiving reallocated funds met the Treasury criteria. 

Suggested Audit Procedures 

a. Confirm that financial information certified by grantees used by Treasury to make

reallocation determinations is accurate and that excess funds that are subject to

involuntary recapture are returned to Treasury in accordance with Treasury’s

confirmation letter.

b. Financial information certified as part of reallocation includes monthly

expenditure and cumulative obligations levels, as described in the Treasury

reallocation guidance.

c. ERA 1 expenditures reported monthly by the grantee are inputs to Treasury’s

reallocation expenditure ratio.

d. ERA 1 obligations certified in the Request for Reallocated Funds form (1505-

0266), including in the Request for Voluntarily Reallocated Funds, are inputs into

determining eligibility to receive reallocated funds.

e. ERA 2 expenditures and obligations reported in quarterly reports by the grantee

are inputs to Treasury’s ERA 2 reallocation expenditure and obligation ratios.

Compliance Supplement 2023 4-21.023-15
 

 

 

May 2023 Federal Agency Single Audit, Key Management Liaison, and Program Contacts 

APPENDIX III 

FEDERAL AGENCY SINGLE AUDIT, KEY MANAGEMENT LIAISON, AND 

PROGRAM CONTACTS 

This appendix provides federal agency single audit contacts (starts on page 8-III-2), key 

management liaisons (starts on page 8-III-10), and program contacts (starts on page 8-III-11) for 

each program/cluster included in the Supplement. For the single audit contacts a table is provided 

for each federal agency identifying who can answer technical audit questions. The table includes 

contact information and the geographical area each federal contact is responsible for overseeing. 

A list of key management liaisons, who are the contacts for questions related to the administrative 

requirements applicable to an agency program(s), and their e-mail addresses follows the single 

audit contact information. Last, program contacts, who can answer programmatic questions, and 

their contact information, are listed by agency and Assistance Listing number. 

Agency Page 

United States Department of Agriculture 8-3-2

Department of Commerce 8-3-2

Department of Defense 8-3-2

Department of Education 8-3-2

Department of Energy 8-3-3

Department of Health and Human Services 8-3-3

Department of Homeland Security 8-3-3

Department of Housing and Urban Development 8-3-3

Department of the Interior 8-3-4

Department of Justice 8-3-4

Department of Labor 8-3-4

Department of State 8-3-4

Department of Transportation 8-3-5

Department of the Treasury 8-3-5

Department of Veterans Affairs 8-3-5

Agency for International Development 8-3-5

Appalachian Regional Commission 8-3-6

Corporation for National and Community Service 8-3-6

Environmental Protection Agency 8-3-6

Federal Communications Commission 8-3-6

General Services Administration 8-3-7

Gulf Coast Ecosystem Restoration Council 8-3-7

National Aeronautics and Space Administration 8-3-7

National Archives and Records Administration 8-3-7

National Endowment for the Arts 8-3-8

National Endowment for the Humanities 8-3-8

National Science Foundation 8-3-8

Nuclear Regulatory Commission 8-3-8

Social Security Administration 8-3-8

Tennessee Valley Authority 8-3-9

US Small Business Administration 8-3-9

Federal Agency Key Management Liaisons 8-3-10

Federal Agency Program Contacts 8-3-11

Compliance Supplement 2023 8-III-1 Appendix III 
 

 

 

 

May 2023 Federal Agency Single Audit, Key Management Liaison, and Program Contacts 

Federal Agency Single Audit Contacts 

Agency Type of Audit 

Department of Transportation 

US Department of Transportation 

Office of Inspector General 

Attn: National Single Audit Coordinator 

101 W. Lombard Street, Suite 2516 

Baltimore, MD 21201 

Phone: Voice (443) 825-1510 

Additional Contact: Matthew Straw 

singleauditrequest@oig.dot.gov 

Department of the Treasury 

Department of the Treasury 

Office of Inspector General 

Deputy Assistant Inspector General for Audit 

875 15th Street NW, Suite 300 

Washington, DC 20050 

Phone: Voice 202-927-5784 

Fax: 202-927-5379 

All audits 

Department of Veterans Affairs 

Director 

Office of Inspector General 

Financial Statement Audit Division (52CF) 

Department of Veterans Affairs 

810 Vermont Ave. NW 

Washington, DC 20420 

Phone: Voice 202-565-7013 

Fax: 202-565-7771 

All audits 

Agency for International Development 

USAID 

Attn: OIG/A/FA 

Room 8.10-10 

1300 Pennsylvania Avenue, NW 

Washington, DC 20523-7802 

Phone: Voice 202-712-4902 

Fax: 202-216-3598 

E-Mail: faudit@usaid.gov

Web site:

U.S. Agency for International Development (usaid.gov)

For audits of all US based 

not-for-profit organizations 

Compliance Supplement 2023 8-III-5 Appendix III 
 

 

 

May 2023 Federal Agency Single Audit, Key Management Liaison, and Program Contacts 

Federal Agency Key 

Agency Name E-Mail Address

Department of Agriculture Samantha Coles 

Seanne Weekes 

Samantha.cole@usda.gov 

Seanne.weekes@usda.gov 

Department of Commerce John P. Geisen JGeisen@doc.gov 

Department of Defense Jason Day jason.o.day.civ@mail.mil 

Department of Education Lihong Guo Lihong.Guo@ed.gov 

Department of Energy Joel Gonzalez Joel.Gonzalez@hq.doe.gov 

Department of Health and Human 

Services 

Robin Aldridge 

Leticia Adu 

Robin.Aldridge@hhs.gov 

Leticia.Adu@hhs.gov 

Department of Homeland Security Michael Pellegrino Michael.Pellegrino@HQ.DHS.GOV 

Department of Housing and Urban 

Development 

Shannon E. Steinbauer Shannon.E.Steinbauer@hud.gov 

Department of the Interior Eunice Pierre eunice_pierre@ios.doi.gov 

Department of Justice Linda Taylor 

Jeff A. Haley 

Linda.Taylor2@usdoj.gov 

Jeff.Haley@usdoj.gov 

Department of Labor Anita Robinson 

Latonya Torrence 

Robinson.Anita@dol.gov 

Torrence.Latonya@dol.gov 

Department of State Thomas Kodiak Kodiakt@state.gov 

Department of the Treasury Siporah Jackson Siporah.Jackson@treasury.gov 

Department of Transportation Willie Smith willie.smith@dot.gov 

Department of Veterans Affairs Kevin Cone Kevin.Cone@va.gov 

Corporation for National and 

Community Service 

Edris Shah eshah@cns.gov 

Denali Commission Beth Flowers bflowers@denali.gov 

Environmental Protection Agency Kysha Holliday Holliday.Kysha@epa.gov 

Federal Communications Commission Sheela Kailasanath Sheela.Kailasanath@fcc.gov 

Gulf Coast Ecosystem Restoration 

Council 

Steve Sigler Steve.sigler@restorethegulf.gov 

Institute for Museum and Library 

Services 

Connie Cox Bodner CBodner@imls.gov 

National Aeronautics and Space 

Administration 

Antanese Crank antanese.n.crank@nasa.gov 

National Archives and Records 

Administration 

Christopher Eck Christopher.Eck@nara.gov 

National Endowment for the Arts Breanna Berger bergerb@arts.gov 

National Endowment for the 

Humanities 

Laura Davis ldavis@neh.gov 

National Science Foundation Rochelle D. Ray rray@nsf.gov 

Office of National Drug Control Policy Lisa Newton Lisa_E_Newton@ondcp.eop.gov 

Social Security Administration Trae Sommer Audit.Correspondence@ssa.gov 

DCO.AUDIT@ssa.gov 

DCO.ODD.AUDIT@ssa.gov 

OIG.audit.kansascity@ssa.gov 

Frank.Biro@ssa.gov 

US Agency for International 

Development 

David McNeil dmcneil@usaid.gov 

US Small Business Administration Kimberly Butler Kimberly.Butler@sba.gov 

Compliance Supplement 2023 8-III-10 Appendix III 
 

 

May 2023 Federal Agency Single Audit, Key Management Liaison, and Program Contacts 

Federal Agency Program 

Contacts 

Assistance 

Listing 

Agency Contact(s) E-Mail Address Telephone 

Number 

Maritime Administration 

(MARAD) 

John Desch 

Senior Contract Specialist, 

(MARAD) 

John.Desch@dot.gov 

202-366-4356

21 Department of the Treasury 

(TREAS) 

21.015 

21.020 

Troyling Harris 

Chief Compliance Officer 

troyling.harris@treasury.gov 202-927-8096

21.016 Siporah Jackson Siporah.Jackson@treasury.gov 202-374-1813

21.019 Nasr Fahmy, Single Audit 

Advisor 

Nasr.Fahmy@treasury.gov (202) 527-4036

21.023 Nasr Fahmy, Single Audit 

Advisor 

Nasr.Fahmy@treasury.gov (202) 527-4036

21.026 Nasr Fahmy, Single Audit 

Advisor 

Nasr.Fahmy@treasury.gov (202) 527-4036

21.027 Nasr Fahmy, Single Audit 

Advisor 

Nasr.Fahmy@treasury.gov (202) 527-4036

21.029 Nasr Fahmy, Single Audit 

Advisor 

Nasr.Fahmy@treasury.gov (202) 527-4036

21.032 Nasr Fahmy, Single Audit 

Advisor 

Nasr.Fahmy@treasury.gov (202) 527-4036

32 Federal Communications 

Commission 

32.006 

32.009 

Sheela Kailasanath Sheela.Kailasanath@fcc.gov 202-418-0938

45 National Endowment for the 

Humanities (NEH) 

45.129 Karen Kenton 

Director 

kkenton@neh.gov 202-606-8307

Compliance Supplement 2023 8-III-19 Appendix III 
 

 

 

 

May 2023 Internal Reference Tables 

APPENDIX IV 

INTERNAL REFERENCE TABLES 

INTRODUCTION 

This Appendix includes a listing of programs with a “higher risk” designation and describes how 

that designation impacts the major program determination process. It also includes a list of 

programs in Part 4, which have requirements defined in IV, Other Information. 

PROGRAMS WITH “HIGHER RISK” DESIGNATION 

Uniform Guidance section 200.519(c)(2) states that “Federal agencies, with the concurrence of 

OMB, may identify Federal programs that are higher risk. It also states that OMB will provide 

this identification in the Compliance Supplement.” 

As a result of the COVID-19 pandemic, many new federal programs were established and 

funding was added to existing federal programs from the following Acts: 

• Coronavirus Preparedness and Response Supplemental Appropriations Act

• Families First Coronavirus Response Act

• Coronavirus Aid, Relief, and Economic Security Act (CARES Act)

• Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA)

• American Rescue Plan Act (ARP)

Funding arising from these sources is referred to as “COVID-19 funding,” or “COVID-19 

programs”. 

On November 15, 2021, the Infrastructure Investment and Jobs Act (IIJA) was signed into law. 

It established new programs and provided additional funding for existing programs. Funding 

arising from the IIJA is referred to as “IIJA funding” or “IIJA program”. The 2023 higher risk 

list includes one program that includes IIJA funding. 

The following table includes a complete list of programs that have been identified as “higher 

risk” for audits subject to the 2023 Compliance Supplement either because of COVID-19 

funding, IIJA funding, or because a Federal agency has identified the program to be higher risk. 

Agency Assistance Listing (CFDA) 

Number 

Title 

Education* 84.425 Education Stabilization Fund 

HHS* 93.498 Provider Relief Fund and American Rescue 

Plan (ARP) Rural Distribution 

HHS** 93.778/93.777/93.775 Medicaid Cluster 

Treasury* 21.023 Emergency Rental Assistance 

Compliance Supplement 2023 8-IV-1 Appendix IV 
 

 

 

 

 

 

 

 

 

 

 

 

 

May 2023 Internal Reference Tables 

Treasury* 21.026 Homeowner Assistance Fund 

Treasury* 21.027 Coronavirus State and Local Fiscal 

Recovery Funds 

Treasury* 21.029 Coronavirus Capital Projects Fund 

Interior ** 15.252 Abandoned Mine Land Reclamation 

(AMLR) 

Social Security 96.001/96.006 Disability Insurance/Supplemental Security 

Income 

Note: 

* These programs were created by one of the laws cited at the beginning of this section and are

thus considered 100% COVID-19 funding.

** These programs were existing programs that received additional COVID-19 funding from one

or more of the laws cited at the beginning of this section or IIJA funding.

Impact of “Higher Risk” Status on Major Program Determination 

Type A Program Considerations 

A “higher risk” designation will often result in a Type A program or other cluster being audited 

as a major program. However, an auditor is not precluded from determining that a “higher risk” 

Type A program or other cluster qualifies as a low risk Type A program if both of the following 

criteria are met: 

1. the program otherwise meets the criteria for a low risk Type A program in section

200.518 of the Uniform Guidance; and

2. the percentage of COVID-19 funding or IIJA funding in the program or other cluster

during the non-federal entity’s fiscal year is not material to the program or other cluster

as a whole. For example, a recipient’s schedule of expenditures of federal awards may

include the Medicaid Cluster but the expenditures relevant to COVID-19 funding

included in the program during the June 30, 2023, fiscal year end is not material.

Alternatively, a recipient’s schedule of expenditures of federal awards may include

Education Stabilization Fund expenditures for the June 30, 2023, fiscal year end, which

would be considered material because COVID-19 funding comprises the entire program.

Note that the inclusion of COVID-19 funding or IIJA funding within the Research & 

Development (R&D) cluster does not create a “higher risk” designation for the R&D cluster. 

Auditors should prepare audit documentation supporting the risk considerations and conclusions 

for “higher risk” programs. 

Type B Program Considerations 

Under section 200.518 of the Uniform Guidance, in certain circumstances the auditor must 

identify Type B programs that are high risk using professional judgment and the criteria in 

section 200.519 of the Uniform Guidance, which includes consideration of whether a program 

has been identified as “higher risk” by a Federal agency with the concurrence of OMB. Thus, 

Compliance Supplement 2023 8-IV-2 Appendix IV 
 

 

 

 

 

 

May 2023 Internal Reference Tables 

there are no changes to the normal risk assessment process for Type B programs identified as 

“higher risk.” That is, the “higher risk” identification must be considered with the other factors in 

section 200.519. 

Further, the auditor is not required to prioritize the assessment of risk for “higher risk” Type B 

programs over other Type B programs. 

PROGRAMS WITH “OTHER INFORMATION” IN PART 4 

The following is a list of programs in Part 4 that have requirements defined in IV, “Other 

Information.” Other Information sections are included to communicate additional information 

concerning the program. For example, when a program allows funds to be transferred to another 

program, the “Other Information” section provides guidance on how those funds are to be treated 

on the Schedule of Expenditures of Federal Awards and in major program determinations. Note 

that if the listing is a cluster, all program numbers are shown, but only the primary program 

name is presented. 

10.551/10.561 Supplemental Nutrition Assistance Program (SNAP) 

10.553/10.555/10.556/10.559 School Breakfast Program (SBP) 

10.557 Special Supplemental Nutrition Program for Women, Infants, 

and Children (WIC) 

10.558 Child and Adult Care Food Program (CACFP) 

10.760 Water and Waste Disposal Systems for Rural Communities 

10.766/10.780 Community Facilities Loans and Grants 

11.300/11.307 Investments for Public Works and Economic Development 

14.157 Supportive Housing for the Elderly (Section 202) 

14.181 Supportive Housing for Persons with Disabilities (Section 811) 

14.218/14.225 Community Development Block Grants/Entitlement Grants and 

Non-Entitlement Counties in Hawaii 

14.228 Community Development Block Grants/State’s Program and 

Non-Entitlement Grants in Hawaii 

14.239 Home Investment Partnerships Program 

14.256 Neighborhood Stabilization Program (Recovery Act Funded) 

14.850 Public and Indian Housing 

14.862 Indian Community Development Block Grant Program 

14.867 Indian Housing Block Grants 

14.871/14.879 Section 8 Housing Choice Vouchers 

14.872 Public Housing Capital Fund (CFP) 

14.873 Native Hawaiian Housing Block Grant 

14.881 Moving to Work Demonstration Program 

14.888 Lead-based Paint Capital Fund Program and Housing-Related 

Hazards Capital Fund 

15.022 Tribal Self-Governance 

15.025/15.026/15.113/ 

15.114/15.130 Services to Indian Children, Elderly and Families (477 Cluster) 

16.710 Public Safety Partnership and Community Policing Grants 

Compliance Supplement 2023 8-IV-3 Appendix IV 
 

 

 

 

 

May 2023 Internal Reference Tables 

17.225 

17.265 

20.106 

20.223 

21.012 

21.016 

21.020 

21.027 

66.458/66.482 

66.468/66.483 

81.041 

84.000 

84.002 

84.010 

84.011 

84.027/84.173 

84.032-G 

84.032-L 

84.041 

84.042/84.044/84.047/ 

84.066/84.217 

84.048 

84.181 

84.282 

84.287 

84.367 

84.424 

84.938 

93.044/93.045/93.053 

93.095/93.096 

93.268 

93.461 

93.498 

93.499 

93.545 

93.558 

93.566 

93.569 

Unemployment Insurance (UI) 

Native American Employment and Training 

Airport Improvement Program 

Transportation Infrastructure Finance and Innovation Act 

(TIFIA) Program 

Native Initiatives (New) 

Equitable Sharing Program 

Community Development Financial Institutions Program 

Coronavirus State and Local Fiscal Recovery Funds 

Capitalization Grants for Clean Water State Revolving Funds 

Capitalization Grants for Drinking Water State Revolving Funds 

State Energy Program 

Cross-Cutting Section 

Adult Education-Basic Grants to States 

Title I Grants to Local Educational Agencies 

Migrant Education -State Grant Program (Title I, Part C of 

ESEA) 

Special Education-Grants to States (IDEA, Part B) 

Federal Family Education Loans-(Guaranty Agencies) 

Federal Family Education Loans-(Lenders) 

Impact Aid (Title VII of ESEA) 

Student Support Services 

Career and Technical Education-Basic Grants to States (Perkins 

IV) 

Special Education-Grants for Infants and Families 

Charter Schools 

Twenty-First Century Community Learning Centers 

Supporting Effective Instruction State Grants (formerly 

Improving Teacher Quality State Grants) 

Student Support and Academic Enrichment Program 

Hurricane Education Recovery 

Special Programs for the Aging-Title III, Part B-Grants for 

Supportive Services and Senior Centers and CARES Act for 

Supportive Services Under Title III-B of the Older Americans 

Act 

HHS Programs for Disaster Relief Appropriations Act-NonConstruction 

Immunization Cooperative Agreements 

HRSA COVID-19 Uninsured Program 

Provider Relief Fund 

Low-Income Household Water Assistance Program 

Consumer Operated and Oriented Plan (CO-OP) Program 

Temporary Assistance for Needy Families (TANF) 

Refugee and Entrant Assistance—State-Administered Programs 

Community Services Block Grant 

Compliance Supplement 2023 8-IV-4 Appendix IV 
 

 

 

 

 

 

 

May 2023 Internal Reference Tables 

93.575/93.596/93.489 Child Care and Development Block Grant 

93.600/93.356 Head Start 

93.667 Social Services Block Grant 

93.778/775/777 Medical Assistance Program (Medicaid; Title XIX) 

93.959 Block Grants for Prevention and Treatment of Substance Abuse 

93.994 Maternal and Child Health Services Block Grant to the States 

97.036 Disaster Grants-Public Assistance (Presidentially Declared 

Disasters) 

97.039 Hazard Mitigation Grant Program (HMGP) 

97.067 Homeland Security Grant Program (HSGP) 

Part 5.3 also has requirements defined in IV, “Other Information.” 

Compliance Supplement 2023 8-IV-5 Appendix IV 
 

 

 

 

 

 

 

 

 

 

 

 

May 2023 List of Changes for the 2022 Compliance Supplement 

APPENDIX V 

LIST OF CHANGES FOR THE 2023 COMPLIANCE SUPPLEMENT 

This appendix provides a list of changes from the 2023 Supplement dated May 2023. Please note 

that changes in the Matrix of Compliance Requirements are reflected in Part 2 of this supplement 

and are not reflected in this appendix. 

Table of Contents 

The Table of Contents has been updated to show additions and deletions. 

Part 1 – Background, Purpose, and Applicability 

• Updated for the effective date of Supplement, streamlined language in

Background, Purpose, Applicability and How to Obtain Additional Guidance

sections, included information on the FAC transition and Single Audit Extensions

within the Other Audit Advisories section.

Part 2 – Matrix of Compliance Requirements 

• Matrix of Compliance changes and corrections were made for 2023. Changes are

shown in yellow highlights.

Part 3 – Compliance Requirements 

• Updated Introduction for the effective date of the Supplement, updated Cash

Management, and included BABAA requirement to Procurement and Suspension

and Debarment.

Part 4 – Agency Program Requirements 

Changes were made to the following programs and clusters: 

• 10.512-Agriculture Extension at 1890 Land-Grant Institutions Program

• 10.515-Renewable Resources Extension Act (RREA) and National Focus Funds

(RREA-NFF)

• 10.551/10.561-Supplemental Nutrition Assistance Program (SNAP) Cluster

• 10.553/10.555/10.566/10.559/10.582-Child Nutrition Cluster

• 10.606-Food for Progress Program

• 10.607-Section 416(b) Program

• 10.766/10.780-Community Facilities Loans and Grants Cluster

Compliance Supplement 2023 8-V-1 Appendix V 
 

 

 

 

 

 

 

 

 

May 2023 List of Changes for the 2022 Compliance Supplement 

• 11.300/11.307- Economic Development Cluster

• 11.611-Hollings Manufacturing Extension Partnership (NIST)

• 14.157-Supportive Housing for the Elderly (Section 202)

• 14.182/14.195/14.249/14.856-Section 8 Project-Based Cluster

• 14.269/14.272- Community Development Block Grant-Disaster Recovery Grant

(CDBG-DR) Cluster

• 14.866/14.889- HOPE VI Cluster

• 14.867-Indian Housing Block Grants

• 14.871/14.879- Housing Voucher Cluster

• 14.872-Public Housing Capital Fund (CFP)

• 14.873-Native Hawaiian Housing Block Grant

• 14.881-Moving to Work Demonstration Program

• 14.888-Lead-Based Paint & Housing-Related Hazards

• 15.252-Abandoned Mine Land Reclamation

• 15.605/15.611/15.626-Fish and Wildlife Cluster

• 16.034-Coronavirus Emergency Supplemental Funding

• 16.710-Public Safety Partnership and Community Policing Grants

• 16.738-Edward Byrne Memorial Justice Assistance Grant Program

• 16.922-Equitable Sharing Program

• 17.207/17.801-Employment Service Cluster

• 17.225-Unemployment Insurance (UI)

• 17.235-Senior Community Service Employment Program

• 17.245-Trade Adjustment Assistance

• 17.258/17.259/17.278-WIOA Cluster

• 17.264-National Farmworker Jobs Program

Compliance Supplement 2023 8-V-2 Appendix V 
 

 

 

 

 

May 2023 List of Changes for the 2022 Compliance Supplement 

• 17.265-Native American Employment and Training

• 20.001-Wage Rate Requirements Cross-Cutting Section

• 20.205-Highway Planning and Construction (Federal-Aid Highway Program)

(decoupled program)

• 20.218-Motor Carrier Safety Assistance Program

• 20.219-Recreational Trails Program (decoupled program)

• 20.223-Transportation Infrastructure Finance and Innovation Act (TIFIA)

Program

• 20.224-Federal Lands Access Program (decoupled program)

• 20.315 – National Railroad Passenger Corporation Grants

• 20.327-Railroad Crossing Elimination (new)

• 20.500/20.507/20.525/20.526-Federal Transit Cluster

• 20.509-Formula Grants for Rural Areas

• 20.532-Passenger Ferry Grant Program, Electric or Low Emitting Ferry Pilot

Program, and Ferry Service for Rural Communities Program (new)

• 20.533-All Stations Accessibility Program (new)

• 20.534-Community Project Funding Congressionally Directed Spending (new)

• 20.600/20.611/20.616- Highway Safety Cluster

• 20.708-Natural Gas Distribution Infrastructure Safety and Modernization Grant

Program(new)

• 20.816-Maritime Administration Marine Highway Grant Program

• 20.823-Maritime Administration – Port Infrastructure Development Program

• 21.011 – Capital Magnet Fund (new)

• 21.012 – Native Initiatives (new)

• 21.015-Resources and Ecosystems Sustainability, Tourist Opportunities, and

Revived Economies of the Gulf Coast States (Gulf RESTORE)

• 21.019-Coronavirus Relief Fund

Compliance Supplement 2023 8-V-3 Appendix V 
 

 

 

 

 

 

May 2023 List of Changes for the 2022 Compliance Supplement 

• 21.020-Community Development Financial Institutions Program

• 21.023 - Emergency Rental Assistance Program

• 21.024 – Rapid Response Program (new)

• 21.025 -Small Dollar Loan Program (new)

• 21.026 - Homeowner Assistance Fund

• 21.027 - Coronavirus State and Local Fiscal Recovery Funds

• 21.029 - Coronavirus Capital Projects Fund Program

• 21.032- Local Assistance and Tribal Consistency Fund (new)

• 23.003-Appalachian Development Highway System (decoupled)

• 32.006-COVID-19 Telehealth Program

• 32.009- Emergency Connectivity Fund Program

• 45.129-Promotion of the Humanities-Federal/State Partnership

• 81.041-State Energy Program

• 81.042-Weatherization Assistance for Low-Income Persons

• 84.000-Cross-Cutting Section

• 84.010-Title I Grants to Local Educational Agencies (Title I, Part A of the ESEA)

• 84.011-Migrant Education-State Grant Program (Title I, Part C of ESEA)

• 84.027/84.173- Special Education Cluster (IDEA)

• 84.041-Impact Aid (Title VII of ESEA)

• 84.048-Career and Technical Education-Basic Grants to States (Perkins V)

• 84.181-Special Education-Grants for Infants and Families

• 84.282-Charter Schools

• 84.365-English Language Acquisition State Grants

• 84.367-Supporting Effective Instruction State Grants (formerly Improving

Teacher Quality State Grants)

Compliance Supplement 2023 8-V-4 Appendix V 
 

 

 

May 2023 List of Changes for the 2022 Compliance Supplement 

• 84.425-Education Stabilization Fund (ESF)

• 93.044/93.045/93.053-Aging Cluster

• 93.090-Guardianship Assistance

• 93.153-Coordinated Services and Access to Research for Women, Infants,

Children, and Youth (Ryan White HIV/AIDS Program Part D Women, Infants,

Children and Youth WICY Program)

• 93.210-Tribal Self-Governance Program-IHS Compacts/Funding Agreements

• 93.217-Family Planning-Services

• 93.224/93.527-Health Center Program Cluster

• 93.423-Waivers for State Innovation for Section 1332 of the Patient Protection

and Affordable Care Act (PPACA)

• 93.461-HRSA COVID-19 Uninsured Program

• 93.498-Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution

• 93.499 – Low Income Household Water Assistance Program

• 93.545-Consumer Operated and Oriented Plan (CO-OP) Program

• 93.556-Promoting Safe and Stable Families

• 93.558-Temporary Assistance for Needy Families (TANF)

• 93.563-Child Support Enforcement

• 93.566-Refugee and Entrant Assistance-State-Administered Programs

• 93.568-Low-Income Home Energy Assistance

• 93.575/93.596/93.489- Child Care and Development Fund Cluster

• 93.600/93.356-Head Start Cluster

• 93.645-Stephanie Tubbs Jones Child Welfare Services Program

• 93.658-Foster Care-Title IV-E

• 93.659-Adoption Assistance-Title IV-E

• 93.667-Social Services Block Grant

Compliance Supplement 2023 8-V-5 Appendix V 
 

 

 

 

 

 

May 2023 List of Changes for the 2022 Compliance Supplement 

• 93.671-Family Violence Prevention and Services Act

• 93.686-Ending the HIV Epidemic: A Plan for America

• 93.767-Children’s Health Insurance Program (CHIP)

• 93.778/93.777/93.775-Medical Cluster

• 93.914-HIV Emergency Relief Project Grants (Ryan White HIV/AIDS Program

Part A)

• 93.917-HIV Care Formula Grants (Ryan White HIV/AIDS Program Part B)

• 93.918-Grants to Provide Outpatient Early Intervention Services with Respect to

HIV Disease (Ryan White HIV/AIDS Program Part C)

• 93.958-Block Grants for Community Mental Health Services

• 93.994-Maternal and Child Health Services Block Grant to the States

• 96.001/96.006-Disability Insurance/SSI Cluster

• 97.036-Disaster Grants-Public Assistance (Presidentially Declared Disasters)

• 97.067-Homeland Security Grant Program (HSGP)

Part 5 – Clusters of Programs 

• Part 5.1 - No Change.

• Part 5.2 – No Change.

• Part 5.3 – Updated for the effective date of Supplement, changes within Activities

Allowable/Unallowed, Cash Management, Eligibility, Reporting and Special

Tests.

• Part 5.4 – Removed the Highway Planning and Construction Cluster.

Part 6 – Internal Control 

• No Change.

Part 7 – Guidance for Auditing Programs Not Included in This Compliance Supplement 

• No Change.

Compliance Supplement 2023 8-V-6 Appendix V 
 

 

 

 

 

 

 

 

 

 

 

 

May 2023 List of Changes for the 2022 Compliance Supplement 

Part 8 – Appendixes 

Appendix I – Federal Programs Excluded from the A-102 Common Rule and Portions of 

2 CFR Part 200 

• No Change.

Appendix II – Federal Agency Codification of Governmentwide Requirements and 

Guidance for Grants and Cooperative Agreements 

• No Change.

Appendix III – Federal Agency Single Audit, Key Management Liaison, and Program 

Contacts 

• Updated for this year’s program contacts.

Appendix IV – Internal Reference Tables 

• Updated the list of programs currently designated as high risk.

• Updated the list of programs with requirements defined in IV, “Other Information.”

Appendix V – List of Changes for the 2022 Compliance Supplement 

• List updated with changes to the programs and appendixes for 2023.

Appendix VI – Program-Specific Audit Guides 

• No Changes.

Appendix VII – Other Audit Advisories 

• Updated for the effective date of the Supplement, included FAC transition information

and Single Audit Extensions.

Appendix VIII – Examinations of EBT Service Organizations 

• No Change.

Appendix IX – Compliance Supplement Core Team 

• Updated the list of team members for 2023.

Compliance Supplement 2023 8-V-7 Appendix V