The U.S. Office of Management and Budget (OMB) issued new guidance to federal agencies which describes how they should administer funds from the Coronavirus Aid, Relief, and Economic Security (CARES) Act.
Among the requests from OMB is that agencies institute frequent performance reporting requirements, describing their progress at least quarterly. Agencies must report monthly on “large covered funds,” including loans and loan guarantees, to OMB. In order to gather this information, it is likely that federal agencies like the U.S. Department of Education (ED) will ask its own grantees for frequent reports on spending.
The guidance emphasizes the need to get funds out quickly, but to balance that financial need of grantees with the need for accountability and mitigation of the risk of fraud, waste, abuse, and improper payments. It asks Offices of Inspectors General to develop and document plans to leverage new resources to prevent and detect fraud, waste, and abuse in the use of CARES Act funds, identifying intended outcomes and “key risk areas.” OMB suggests that funds go to “evidence-based programs whenever possible.” Still, OMB requests that some grantees get flexibility, and that agencies assess and establish adjustments to existing reporting and audit deadlines using a risk-based framework.
OMB instructs federal agencies to use a unique accounting code for disaster relief and other CARES Act funds in order to properly track the expenditure of those funds, including the date of expenditure. Federal organizations that use Purchase Cards (commonly known as “P-Cards”) must also identify relevant transactions with a COVID identifier. Agencies must comply with DATA Act requirements when it comes to tracking and reporting on expenditures and those activities.
While OMB memos like this are intended to apply to federal agencies and not State or local grantees, they do guide what is expected of grantees and provide some insight into what processes ED may adopt.
The new OMB memo is available here.
Author: JCM
