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Treasury Emergency Rental Assistance (ERA)

Quarterly Reporting Special Tip 

January 24, 2022

**Attention**

Dear ERA1 and ERA2 Recipients:

Thank you for your efforts to deliver emergency housing relief and increase transparency through 

ERA quarterly reporting. As data in recent ERA monthly and quarterly reports demonstrate, many 

at risk families remain in their homes and apartments thanks, in part, to the hard work of the ERA 

Recipients.

Treasury is sharing several observations and important reporting tips below. Please take a moment 

to review. Information in this document will be useful to all ERA recipents as they prepare their

Q4 2021 Quarterly Reports and future Quarterly Reports.

This special guidance supercedes and replaces sections of the Addendum published on 

October 28, 2021.

Clarifications on Recipient Reporting on Obligations and Expenditures

• Obligation and Expenditure in Quarterly and Monthly Reporting1: To elaborate on 

existing guidance (there is no substantive change to the existing definitions of the terms), 

ERA recipients should report their Treasury ERA prime recipient award funds as obligated 

when the recipient makes a definite commitment that creates a legal liability for the 

recipient to make a payment for goods and services ordered or received, or a legal duty on 

the part of the recipient that could mature into a legal liability by virtue of actions on the 

part of the other party (for example, an applicant for rental housing assistance). Payment 

may be made immediately or in the future. Recipients incur an obligation, for example, 

when they place an order, sign a contract, award a grant, purchase a service, or take other 

actions that will require the recipient to make payments under the ERA award. In addition 

to legal obligations that have not yet been paid, Recipients must also report ERA funds 

that have been paid/expended as obligated in each Quarterly Report. Amounts reported 

as Expenditures to Treasury in ERA Monthly Reports should be similarly reported as 

Expenditures and Obligations in the associated ERA Quarterly Report. The sum of 

Expenditures in ERA Monthly Reports are expected to equal Quarterly total expenditures 

for the respective period less any necessary adjustments (for example, for returned checks). 

For recipients on a cash basis of accounting only, the amount of the ERA award obligated 

may be equal to the amount expended and paid (cash out the door). Otherwise, accrued 

liabilities for expenses incurred that have not been paid (for example, an approved rental 

housing assistance agreement or a commitment letter to pay prospective rental assistance 

in the following quarter) must also be counted as amounts obligated.

1 Consistent with the definitions in Treasury’s reporting guidance, 2 CFR Part 200 definitions, standard instructions

for the Federal Financial Report (SF-425), and definitions from the Government Accountability Office.
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• ERA1 Reallocation Guidance: Section 501(d) of the Consolidated Appropriations Act, 

2021 provided that beginning on September 30, 2021, the Secretary shall recapture excess 

funds, as determined by the Secretary, that were not obligated by a grantee and reallocate 

such amounts to eligible grantees who, at the time of such reallocation, have obligated at 

least 65 percent of the amount originally allocated to them and have a demonstrated need 

for such funds. Treasury issued ERA1 Reallocation Guidance on October 4, 2021, that sets 

forth policies and procedures for the ERA1 reallocation process, which is available here.

Please note that while the reallocation guidance allows recipients to assume 10% of the

total ERA1 award has been obligated for administrative expenses for the purposes of 

reallocation, recipients are to report actual program Administration expenses and 

obligations in Quarterly Report submissions. 

Treasury’s Reallocation Guidance did not change Treasury’s obligation definition. The 

reallocation guidance simply clarified that recipients may consider a financial assistance 

commitment letter issued to induce a landlord to enter into a rental agreement with an 

eligible household as an obligation.

Treasury expects amounts certified as obligated or expended for the purpose of reallocation 

to match previous and future Monthly and Quarterly Reporting submissions (with the 

exception of the 10% administrative expense allowance). Treasury will issue guidance on 

accounting for reallocated funds in a future update to the ERA1 reporting guidance. Note, 

however, that amounts returned to Treasury, whether excess funds or voluntary 

reallocation, should be excluded from reporting since the funds are no longer available for 

obligation or expenditure.

• Obligations and Expenditures Must Not Exceed the Federal Award Amount 

Recipients should ensure that amounts reported as obligated or expended do not exceed the

total amount of the recipient’s respective ERA1 and/or ERA2 award received from 

Treasury. Some recipients have reported obligations or expenditures that exceed the 

amount of funds awarded and paid by Treasury. While recipients may utilize other, nonTreasury ERA funds for their rental assistance programs, and are encouraged to do so

within the guidelines set forth in Treasury’s ERA Frequently Asked Questions and related 

guidance from the Office of Management and Budget in M-21-20, Promoting Public Trust 

in the Federal Government through Effective Implementation of the American Rescue Plan 

Act and Stewardship of the Taxpayer Resources, recipients should only report expenditures 

and obligations received from Treasury for their ERA1 and/or ERA2 award in their ERA 

Quarterly Reports. Recipients must also remember to report expenditures and obligations

related to their ERA1 award separately from their ERA2 award. Treasury encourages 

recipients to identify amounts and describe contributions from other federal, state, or local 

programs in a comment field in quarterly and monthly submissions.

• Obligations and Expenditures by Financial Assistance Type Must be Less than or 

Equal to the Federal Award Amount: The amount a recipient reports as obligated or 

expended by ERA financial assistance type (for example, rent, rental arrears, etc.) and for 
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administrative expenses must not exceed the total amount of the ERA1 or ERA2 award. 

This rule applies to amounts reported for a single reporting period and for cumulative 

reporting.

• Monthly and Quarterly Expenditure Reporting: Treasury expects to be able to sum a 

recipient’s monthly household expenditure reports and the monthly sum should be 

consistent with expenditures reported in the respective Quarterly Report, except for

documented adjustments for refunds and recoveries where applicable2. Amounts reported 

in monthly reports should be consistent with ERA reallocation certifications for the same 

reporting period and point in time. Please note, Treasury plans to issue additional guidance 

on procedures for making updates or corrections to previously submitted monthly and 

quarterly reports in early 2022.

• Reporting the ERA Prime Recipient’s Direct Obligations and Expenditures, and all 

Subrecipient and Contractor Expenditures: As required in section 15011 of the CARES 

Act, recipients must report all obligations, including all direct payments and all obligations 

made to subrecipients and contractors. Please reference the Uniform Guidance at 2 CFR 

200.332, Requirements for Pass-through Entities, for standards regarding when to report 

subrecipient activity as obligated or not and apply the definitions in ERA reporting 

guidance otherwise.

For example, the following Obligations and Expenditures are reportable in the 

“Expenditures” tab and the “Expenditures Associated with the ERA Recipient’s 

Subawards, Contracts, and Direct Payments Valued at $30,000 or More” of the ERA 

Quarterly Report (see ERA reporting guidance) and the associated bulk upload files with 

the relevant picklist selections included: 

1) A recipient awards and expends/pays more than $30,000 directly to a third party 

(such as a business, corporate landlord, utility provider, non-profit provider, or 

other eligible entity) that is receiving the ERA funds exclusively as a beneficiary

on behalf of a tenant. (This does not include payments to beneficiaries who are

unincorporated individual persons, for example, an individual landlord 

reporting rental income to the IRS on the Form 1040, U.S. Individual Income 

Tax Return, Schedule E, Supplemental Income and Loss, under a personal tax 

identification number such as a Social Security Number rather than an

Employer Identification Number issued by the IRS.) Please see the related 

discussion below of Subrecipient versus Beneficiary versus Individual for more 

information.

2) A recipient awards a contract with a net value of more than $30,000 to a contractor 

for a service needed to implement the objectives of the recipient’s ERA Project3

3) A recipient provides a subrecipient a subaward greater than $30,000 to carry out 

part of the prime recipient’s ERA award.

2 Note, Treasury recognizes that the number of Monthly households assisted is unlikely to sum to the total number 

of assisted households in quarterly reporting due to double counting of households receiving assistance across 

months.

3 Expenditures, regardless of amount, to a contractor with a contract with a net value of $30,000 or more should be 

reported in the “Expenditures Associated with the ERA Recipient’s Subawards, Contracts, and Direct Payments

Valued at $30,000 or More” screen on the ERA Quarterly Report.
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Clarifications on how to Record Payments to Individuals, Small Landlords 

and Other Beneficiaries on the ERA Quarterly Reports

• Reporting Payments to Individuals4: Payments of ERA Financial Assistance to 

individuals who are not incorporated – regardless of the amount – should be reported in 

the aggregate using the “Obligations and Expenditures to Individuals (Beneficiaries) ” 

screen or the associated bulk upload file without reporting the individual’s unique 

identifiers (such as the Social Security Number).

• Reporting Payments to Unincorporated Small Landlords (Individuals): 

Unincorporated small landlords (individuals) that receive ERA Financial Assistance 

payments (e.g., for rent, rent arrears, and so forth) are beneficiaries. Therefore, ERA 

Financial Assistance payments to such unincorporated small landlords – regardless of the 

amount – should be reported in the aggregate using the “Obligations and Expenditures to 

Individuals (Beneficiaries” screen or the associated bulk upload file without reporting the 

landlord’s unique identifiers (such as the Social Security Number). Unincorporated small 

landlords typically file a Form 1040 with Schedule E rental income with the IRS using a 

personal tax identification (such as a Social Security Number). 

• Reporting ERA Amounts of $30,000 or More Paid to a Beneficiary that is a Business, 

Corporation, or Non-Profit – When an ERA Recipient pays $30,000 or more in ERA 

Financial Assistance to a business, corporation, or non-profit entity that is receiving the 

payment exclusively as a beneficiary of the program (excluding unincorporated individuals 

as noted above), the ERA Recipient must create a beneficiary profile record that includes

the entity’s DUNS or Unique Entity Identifier (UEI) number (where registered), the 

Taxpayer Identification Number/Employer Identification Number (TIN/EIN, not SSN), the 

legal name, the entity type (for example, “For-profit Organization”), and the legal address 

(usually the headquarters location corresponding with the TIN/EIN reported and 

registration required for a DUNS or SAM). Until Treasury posts an updated reporting 

screen, ERA Recipients are instructed to answer “NA” to the question, “Is the subrecipient 

registered in SAM.gov?” for any non-individual beneficiaries to enable report acceptance

by Treasury’s portal and satisfy the mandatory data fields. The answer would be “NA” 

even if the entity is not registered in SAM.gov and the recipient is using a TIN/EIN for 

reporting. Treasury apologizes for this inconvenience. The ERA Recipient must then 

follow the normal procedure for setting up a Direct Payment record on the “Subawards, 

Contracts, Direct Payments” tab as outlined in the reporting guidance. In addition, the ERA 

Recipient must report all expenditures (direct payments) made to the entity either on the 

screen for reporting expenditures associated with Subawards, Contracts and Direct 

Payment of $30,000 or more or by using the associated bulk upload file.

4 This reporting requirement is similar to the Treasury CARES Act Coronavirus Relief Fund reporting in 

GrantSolutions.
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Other Clarifications

• Reporting Subaward and Executive Compensation Information. Only “First-Tier” 

subaward details are to be submitted to FSRS.gov as required by 2 CFR Part 170, Appendix 

A regarding Reporting Subaward and Executive Compensation Information. This 

requirement continues to apply in addition to the section 15011 of the CARES Act 

reporting requirement for subawards, contracts and direct payments as detailed in the ERA 

reporting guidance, including where recipients report subrecipient activity to FSRS.gov or 

where Treasury reports such information on the recipient’s behalf to FSRS.gov based on 

the subaward reporting the recipient provides to Treasury on its quarterly reports (see 2 

CFR Part 170, Appendix A section I.a.2.i.)

An entity that is strictly a beneficiary receiving a payment is NOT required to do any of 

the following: register for a DUNS number or a Unique Entity Identifier (UEI); register 

with SAM.gov or report executive compensation in SAM.gov.

(Note, if an entity is both a beneficiary and a subrecipient or a contractor and if the 

recipient’s operating norms meet the criteria specified in 2 CFR 200.331, Subrecipient and 

contractor determinations, then the entity meeting the requirements of the award term in 

appendix A 2 CFR Part 170 must register for a UEI5 at SAM.gov and report executive 

compensation6

.)

Thank you for your patience and comments as Treasury administers multiple pandemic programs. 

We welcome your ongoing feedback regarding existing requirements and the clarifications above. 

EmergencyRentalAssistance@Treasury.gov

U.S. Department of the Treasury

5 At this time, new DUNS numbers are no longer available. Federal recipients are required to register for a UEI 

number instead of the DUNS number. 6 Pursuant to the Federal Funding Accountability and Transparency Act (FFATA) and its implementing regulations 

at 2 CFR Part 170.