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Tribal and Tribally Designated Housing Entity (“TDHE”) ERA Reporting 

Webinar

April 4 and April 5, 2022

Topics Discussed 

The following topics were discussed on the ERA reporting webinars on April 4 and April 5, 

2022. The questions and answers have been modified for clarity and accuracy. 

Special Note: Each ERA Recipient must report on its uses of ERA funds. This includes reporting 

on all the Recipients’ obligations to subrecipients, contractors and beneficiaries and the 

associated expenditures on subawards, contracts and direct payments. Additional clarifying 

information and scenarios/reporting examples can be found in ERA Reporting Guidance under 

Appendix 9 -- Scenarios on Reporting an ERA Recipient’s Allocations of ERA funds to 

Subrecipients, Contractors and Beneficiaries.

Question 1: Our ERA project paid electric utility bills for 20 applicants directly to the 

utility company. Each tenant’s utility bill was for less than $30,000, but the overall 

payment made to Electric Company A for all 20 bills was more than $30,000. How should 

we report this on the quarterly report form?

Answer: This question focuses on how to report utility payments made directly to utility 

companies. Please see Question 2 below for information on reporting utility payments paid to 

households.

When the ERA Recipient makes utility payments directly to a utility company (such as an 

electric company), the company is considered a beneficiary, not a subrecipient or contractor.

Because, as outlined in the question, the electric company received more than $30,000 in 

payments, the ERA Recipient (the Tribe) must set up a record for the electric company in the 

“Subrecipients, Contractors and Beneficiaries” tab on the reporting portal. Each Recipient should

also create a record on the “Subawards, Contracts and Direct Payments” tab, to show that it has

obligated $30,000 to the electric company and associate that obligation with the company. 

Finally, the Recipient will record this payment as an expenditure in the “Expenditures” tab under 

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

Payments Valued at $30,000 or More” section.

Question 2: Our communities may all use one vendor for utilities. Are we supposed to set 

up a new tab for every amount over $30,000? For example, if we assisted 300 of our 

households all using the same utilities vendor, can we report this as one lump sum amount?

Answer: In the situation where the ERA Recipient makes utility payments to households (rather 

than making them directly to utility companies as discussed in Question 1 above), the Recipient 

should use the “Recipient Obligations and Expenditures (Payments) to Individuals 
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(Beneficiaries)” screen to report the total amount it paid (expended) to all individuals in the 

quarter for utility payments (expenditures). The Recipient should use that screen to separately 

report the total amount paid to individuals for utility payment arrears.

Question 3: If we have numerous payments in amounts less than $30,000 to different 

individual beneficiaries, do we have to complete a subaward or contract form for each of 

them?

Answer: If a Recipient makes payments to numerous individual beneficiaries and each payment 

is less than $30,000, the Recipient would need to use the “Recipient and Obligations to 

Individuals (Beneficiaries)” section of the portal to report lump sum amounts by the type of 

benefit (rent, rental arrears, utility/home energy costs or arrears, and so forth). 

Question 4: Is the $30,000 per beneficiary report threshold assessed per quarter or it is the 

cumulative amount? For example, if we make many small utility payments to an electric 

company, and over two quarters, the total amount paid reaches $30,000, must we report 

the utility company as a beneficiary receiving more than $30,000?

Answer: The $30,000 threshold is cumulative over the life of the grant. Recipients should 

consider creating a vendor report within their internal financial systems that will flag once 

payments to a specific vendor reach a specified amount (for example: ERA requirement is 

$30,000 or more). Once this threshold is reached, the Recipient is required to create a record for 

the entity under the “Subrecipients, Contractors, and Beneficiaries” tab.

Question 5: At what point do “cumulative expenditures” begin?

Answer: Cumulative expenditures are counted from the time of the award was made to the 

recipient. 

Question 6: Please clarify the difference between the two Tabs: “Subrecipients, 

Contractors and Beneficiaries” and “Recipient Subawards, Contracts and Direct 

Payments”.

Answer: Recipients use the “Subrecipients, Contractors, and Beneficiaries” tab to report basic 

information about organizations, such as subrecipients and contractors, that are assisting the 

Recipient with administering the ERA project and to which it has awarded $30,000 or more.

(Recipients also use this tab to report basic information about any business or non-profit that 

receives more than $30,000 in ERA benefits.)

Recipients use the “ Subawards, Contracts, and Beneficiaries” tab to provide more detailed 

information about the subawards, contracts or direct payment(s) made to the entities listed in the 

previous tab. The additional required details include the amount obligated to the entity, the place 
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of performance, and the period of performance timeframes.

Question 7: Is the place of performance the individual tenant’s address or the vendor’s

address?

Answer: On the “Recipient Subawards, Contracts, and Direct Payments” tab, the performance 

address is the vendor address, not the individual tenant’s address.

Question 8: Would Beneficiaries mean landlords and utility companies?

Answer: Yes, a landlord or utility company that receives direct payments is considered a 

beneficiary. 

Question 9: When a TDHE is a landlord to which direct payments are made, is that TDHE 

reported as a beneficiary?

Answer: Yes, in the situation described here, the TDHE is considered a beneficiary. 

Question 10: What if I need to correct information after a report is submitted? 

Answer: To limit errors, a recommended practice is to compare the general ledger detail from 

the Recipient’s accounting software to the information entered in the portal. If an erroneous 

information is later discovered to have been reported, in lieu of submitting a corrected or 

modified report, information should be submitted that balances the error from the previous 

report. For example, if a Recipient overreported expenditures in a category by $1,500 on a Q2 

report, the next Q3 report should note the error in the appropriate narrative box and reduce 

relevant expenditure category by the same amount to correct for initial error. Additionally, at the 

end of the Performance and Financial Reporting section, there is a Recipient Comments section 

where the Recipient should include notes on the error.

Question 11: Can Treasury make a simple chart with the deadlines and place in a location 

where it is easy to find please?

Answer: Please review Table 2 on page 10 of the ERA Reporting Guidance. This document 

provides detailed information on ERA1 and ERA2 reporting requirements and reporting 

deadlines. The ERA Reporting Guidance is posted on Treasury’s ERA website at 

www.treasury.gov/era under the “reporting” section.

Question 12: Are we required to send 1099s to landlords?

Answer: Yes, ERA benefit payments paid to landlords are considered income for the landlord. 

Recipients must distribute copies of IRS Form 1099-MISC to landlords, utility companies, or 

other service providers that receive more than $600 in ERA benefit payments. 
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However, ERA benefit payments are excludable from tenants’ gross income and therefore are 

not taxable as income to the tenant. ERA Recipient should not distribute Form 1099-MISC to 

tenants who receive ERA benefit payments. For further information, please see the Internal 

Revenue Service’s Draft FAQs for Payments by Indian Tribal Governments to their Individual 

Members Under COVID-Relief Legislation and Notice of Tribal Consultation. 

Portal Functionality and Navigation

Question 13: Is there any effort being made to populate fields to simplify future reporting?

Answer: Based on helpful feedback from Tribes and TDHEs, the Treasury Department has 

updated the reporting portal. For example, previous versions of the portal required SF-425 and 

data entry of the information. Later, the Treasury Department removed the requirement for the 

SF-425. Parts of the portal does retain information for future reporting, such as profile 

information for subrecipients, contractors and beneficiaries. 

Question 14: What is the process for giving new staff access to Treasury’s portal so they 

can assist with inputting information for quarterly reports?

Answer: Please see the Accessing Treasury’s Portal section on the ERA Reporting page and the

Hints and Tips for Designating Points of Contact for ERA1 and ERA2 Reporting document. 

Question 15: If we are entering both program and financial information for the quarter, 

where do we see total (cumulative) information?

Answer: Treasury’s portal maintains each Recipient’s previously submitted financial 

information. Recipients can download their previously submitted quarterly reports to review 

information submitted in those reports. After a report is submitted, a Recipient can navigate to 

the Compliance Reports section, download the report, and print/store the report in its records.

Recipients should consider printing the reports as a preparatory measure for future audits.

In addition, when submitting new quarterly reports, Treasury’s portal allows Recipients to view 

previously submitted data such as subrecipient/contractor/beneficiary records, 

subaward/contract/direct payment obligation information and information reported under the 

“Expenditures” tab. For each of these sections, each Recipient can download an Excel file with 

cumulative information that it has submitted under that specific tab over the life of the award. 

Recipients might find it helpful to download and review previously submitted financial data 

offline to determine if any corrections are required.