Setting standard processes is critical to maintaining compliance. After the passage of the Digital Accountability and Transparency Act, (DATA Act) in 2014, the Office of Management and Budget’s (OMB) Uniform Grant Guidance (UGG), and the Grant Reporting Efficiency and Agreements Transparency (GREAT) Act of 2019, all organizations receiving Federal funds are required to report their spending data using government-wide data standards.
When it comes to compliance, UGG requires standard reporting to ensure good controls are in place during an audit; however, what those standard reporting processes must entail is not very prescriptive, so your organization will have to answer questions when deciding what these processes can, or should, look like. Such as:

•     How can you create standard processes that drive best practices?
•     How can you help maintain your organization’s existing effective workflows, or create new workflows?
•     How can you maintain compliance?

The processes that your organization may choose to implement, or already follow, can include additional steps that are not specifically required by any key legislation, and may include the addition of departmental specifics, people, and additional data collection practices. This blog post aims to provide some best practices for both grant seekers and grant makers that you can implement in your organization to drive best practices, maintain compliance, and maximize your outcomes.

Data Management & Systemization

According to paragraph 4(c)(2) of the DATA Act, organizations must, to the extent that it is reasonable and practical, “incorporate widely accepted common data elements,” and/or “incorporate a widely accepted, nonproprietary, searchable, platform-independent computer-readable format.” A common interpretation of this language is your processes should revolve around the standardization and systemization of data. Collecting key data in a systematized manner will also allow for multiple form completions and can help expand the capacity of your resources. A grant management software can assist you with centralization and standardization.

Personnel Identification and Sign-Off Procedures

To drive best practices as a grant seeker or grant maker, you must identify the key personnel that will need to sign-off on the pursuit of, awarding of, or monitoring of funds. While the personnel involved from award to award may change, the implementation of a specific level or role of sign-off will help maintain compliance and minimize audit struggles. A process that requires internal sign-off further ensures agreement across key programs and departments. In addition, standard operating procedures regarding authorization will further increase transparency, which will provide financial visibility into the status and health of various programs or awards.

Application

Grant Seeker

Creating a standard process for tracking the grants you apply for holds both your team members and your organization accountable for the success of your grant portfolio. Maintaining these application records in a centralized location will help ensure that your team members will not apply to competing, or the same, funding opportunities as their colleagues, as well as be able to track your success rate.

Grant Maker

Standardizing your grant application will ensure a fair and equal application process for all applicants. By creating a standard application, you can effectively evaluate which programs are best suited for your organization’s mission using the same criteria, which will help you distribute funds in an inclusive and equitable way. By creating a concise application that is accessible online, or through an applicant portal in your grant management software, you can further ensure that the application process will be both accessible and standardized for your applicants.

Application scoring is a critical internal function of making awards; and standardizing a review and scoring process ensures that each application is reviewed in the same way by the correct reviewers at the appropriate time. Creating a review process and workflow for application scoring creates internal visibility into the status of the overall applicant portfolio for your organization. It can also help you begin to determine what kinds of monitoring may be required for your pool of recipients.

Reporting Structures

Grant Seeker

Establishing standard reporting structures once a grant is awarded will provide financial oversight and can help your organization adhere to a timeline with milestones that can be used for benchmarking. While you may already have a specific form in use for different funding streams, you can create a process that keeps the structure of reporting similar from award to award to provide consistency in reporting within your organization.

Grant Maker

In order to monitor the performance of your recipients, you’ll want to create a process that requires standard reporting structures at regular intervals. Your process for reporting should drive standard reporting structures that include benchmarking milestones to a timeline, so you can gain insight into your recipient’s project performance.  While there might be specific data elements in use for different funding streams, the structure of the reporting process itself can be similar.

Achieving Compliance

Due to the importance of creating standard processes, the need for centralization, and to drive the creation of accurate, systematized reports, your organization may choose to implement a grants management system (GMS) to help maintain compliance, implement effective and efficient processes, and drive accountability.

Whether you are a grant seeker, a grant maker, or both, the creation of processes to collect standard data is critical for maintaining compliance.

It goes without saying that 2020 has presented some serious challenges for state and local governments.

Never before have governments had to navigate the magnitude of funding–over $150 billion from the Coronavirus Relief Fund under the CARES Act– and distribute it in such a short amount of time.

Unlike the typical grants process, where you prepare a plan, indicate how you’re going to spend the money, do the work, and then get reimbursed, the urgent nature of the pandemic has forced governments to account for their spending in the aftermath.

So how can governments efficiently and transparently navigate this unchartered territory?

Learn more in our first-ever Hero Highlight (where we share how inspiring grants leaders and their associated governments innovatively managed their grant funding and delivered incredible impact to their communities).

Through a deliberate and careful process of strategic planning, Cheryl Harrison-Lee, Interim Executive Director of the Recovery Office (and our heroine of this hero highlight) helped the state of Kansas manage over $1.043 billion in CARES Act funding and established a framework that served as a financial reporting template for benchmarks and metrics. Cheryl shares the state of Kansas’ lessons learned and what other governments can do to ensure similar successes of their own.

Establish Community Priorities First

One of the most significant challenges for governments has been determining how and where to spend funding as effectively and efficiently as possible. During her tenure, Cheryl and her team focused on developing strategic priorities revolving around the biggest impacts of the pandemic: health, education, connectivity,  and the economy. Once they analyzed the major impacts of COVID-19, they were able to quickly delineate priorities at the state level and outline priorities at the county level as well.

Having served at the local, city, county, and state level, it was easy for Cheryl to apply her strategic planning and priority-based budgeting expertise that spoke to the needs of a wide variety of communities. Ultimately, the funding addressed healthcare (i.e. more testing) and helping small businesses reopen safely (i.e. PPE and business continuity). The most important distribution method for Cheryl and her team was using the reliable “tier method.”

“We implemented a tier system where the state distributes to the county and the county distributes to the cities,” Cheryl said. “This allows local governments to directly receive their money and work within their communities. Kansas has 103 counties so by staying at the county level, it allowed us to be efficient and expedient.”

This helped save significantly on the timeline of deciding who would get the funding, which would have been exacerbated if Cheryl and her team had to work with every single city and county within Kansas.

Avoid the “Government-Alone” Approach

Given the ever-narrowing timeframe that governments have to incur their CARES Act funding (Dec. 30th being the deadline), the state of Kansas would not have been able to navigate on its own. For Cheryl, bringing in the perspective and voices of stakeholders in the form of a steering committee (which served as a planning advisory committee) and executive committee (which functioned as the recommending body to the Governor and State Finance Council) was crucial.

She and her team sought input from a wide range of public and private-sector stakeholders, including representatives from health, businesses, education, construction, and banking/finance communities. It was especially important that these stakeholders represented many voices. For example, one of the executive board members was the president of the Kansas Hospital Association. Cheryl expressed that without these voices, she and her team would not have been able to access all the ideas that they could as well as ensure everyone had their needs met. For the state of Kansas, it was all hands on deck.

“In a moment of crisis, there’s a heavy lift and that load requires everyone lifting all at once, instead of a government alone approach,” Cheryl said.

Ultimately, by including a diverse group of stakeholders from the beginning, Cheryl and the stakeholder committees were able to help the state get $700 million approved and $400 million of that amount was disbursed within 60 days.

What Governments Need to Do Now Before December 30th

According to Cheryl, it’s especially important that state governments do their utmost now to ensure subrecipient success. She advises that governments take the following steps before the big December deadline:

• Return funding to the state if you cannot meet the deadline. If counties or local governments have to return any funding, they can return it to states, which can then be added to an unemployment compensation pool or redistribute to entities that have unmet needs. It’s important to send any funding back to states to expand programs they already have in place in alignment with the CARES Act, especially if you are unable to determine where you’re spending funds by the Dec. 30th deadline.
• Engage your audit firm in advance. Make sure you have your auditors walk through every stage of the grants process with you. This way, as you establish priorities, distribute, and manage funding you know you’re going to meet all your audit requirements in advance. Also, it’s important to document EVERYTHING as you go and have electronic files available.
• Establish a paper trail with your legal unit. With so many gray areas in the CARES Act, the state of Kansas set up a code interpretation unit with legal counsel so they could track and answer questions as they came up. This also ensured a paper trail was created which showed what decisions were made and how the government arrived at such decisions. Counties could also gain more clarity by being able to ask states about those gray areas and get legal interpretations of eligible expenditures, better ensuring they could justify their spending down the road.

More information > 

On March 19, the White House Office of Management and Budget (OMB) issued a memorandum for the heads of executive departments and federal agencies (M-21-20).

This memo was released to give guidance to federal agencies to foster accountability and public trust by delivering effective and equitable relief, while implementing sound financial management of the resources funding that relief. This will include working with the Pandemic Response Accountability Committee (PRAC) and agency Inspector Generals to strengthen payment integrity so governments can minimize the risk of waste, fraud, and abuse. Additionally, the guidance aims to help governments improve the overall award and administration of financial assistance programs with an increased focus on human-centered program and service design to achieve more equitable results.

Reducing Administrative Burden on Funding Recipients

In an attempt to help governments receive and distribute funding faster amidst the urgency of the pandemic, Appendix 3 of the OMB memo gives guidance to agencies on how they can reduce administrative burden on recipients’ performance and deliverables. The guidance applies not only to COVID-19 related awards, but also non-COVID-19 related awards.

The guidance is directed to the executive department and federal agencies by OMB in accordance with Uniform Guidance 2 CFR 200. Agencies may allow these exceptions as they deem appropriate and to the extent permitted by law.

Here are six of the 12 areas of guidance given to federal awarding agencies that will affect recipient awards:

1. Flexibility with SAM/recertification

Federal awarding agencies may relax the timing of the requirement for active SAM registration at time of application to expeditiously issue funding. At the time of award, the requirements of 2 CFR § 200.206, the federal awarding agency’s review of risk posed by applicants continue to apply. Current registrants in SAM with active registrations expiring between April 1, 2021 and September 30, 2021 will automatically be afforded a one-time extension of 180 days.

2. Waiver for Notice of Funding Opportunity (NOFO) Publication

Awarding agencies may publish emergency and competitive NOFOs for grants and cooperative agreements for less than 30 days without separately justifying shortening the timeframe for each NOFO. Recipients, however, will need to monitor funding opportunities and be prepared to compile an application in a shortened amount of time.

3. No-cost extensions on expiring awards

To the extent permitted by law, awarding agencies may extend awards that were active as of March 31, 2021 and scheduled to expire prior or up to December 31, 2021–automatically at no cost for a period of up to 12 months. This will allow time for recipient assessments, the resumption of many individual projects, and a report on program progress and financial status to agency staff. Project-specific financial and performance reports will be due 90 days following the end date of the extension. Awarding agencies will examine the need to extend other project reporting as the need arises. Recipients should contact their awarding agencies for information.

4. Abbreviated non-competitive continuation requests

For non-competitive continuation requests scheduled between April 1, 2021 and December 31, 2021, awarding agencies may accept a brief statement from recipients to verify that they are in a position to: (i) resume or restore their project activities and (ii) accept a planned continuation award. Agencies must post any specific instructions on their website as well as examine the need to extend this approach on subsequent continuation award start dates as recipients have an opportunity to assess the situation.

5. Extension of Single Audit submission

Awarding agencies, in their capacity as cognizant or oversight agencies for audit, should allow recipients and subrecipients that have not yet filed their single audits with the Federal Audit Clearinghouse as of the date of the issuance of this memorandum that have fiscal year-ends through June 30, 2021, to delay the completion and submission of the Single Audit reporting package, as required under Subpart F of 2 CFR § 200.501 to six months beyond the normal due date. Recipients and subrecipients taking advantage of this extension would still qualify as a “low-risk auditee” under the criteria of 2 CFR § 200.520.

Recipients with fiscal year-ends through June 30, 2021, will receive a six-month extension beyond the normal due date to submit to the Federal Audit Clearinghouse. Findings within the six-months after normal due date will not cause the entity to lose their ‘low-risk auditee’ designation.

6. Flexibility with application deadlines

Awarding agencies may provide flexibility with regard to the submission of competing applications in response to specific announcements, as well as unsolicited applications, presuming these exceptions do not negatively impact underserved communities. As appropriate, agencies should list specific guidance on their websites and provide a point of contact for an agency program official.

More information > 

Everyone in your organization agrees that you need to begin centralizing your grant management processes. Now the question is, who is responsible for driving and overseeing this shift?

Assembling a Central Grants Office with key roles is one of the first steps leadership needs to take to centralize funding management. The main goals of a Central Grants Office are to provide organizational leadership and oversight over grant policy, evaluation, and training as well as to provide expertise on grant management systems and to streamline processes. That is why you need to rely on those who can make and drive central decisions.

While it may vary by organization, some key personnel from your organization who should be leading your centralization include:

1. Grants Coordinator

The role of grants coordinator is crucial in the Central Grants Office because this individual will essentially be running the office by leading the push for standards, transparency, and compliance around grants. This role will own all grants-related tasks and activities, both in and out of the Office, and will ensure everyone involved is effectively collaborating and communicating.

2. Grants Accountant

To achieve full centralization, there needs to be communication and transparency between the Finance Office and the Central Grants Office. Consider including the grant accountant in the Central Grants Office to facilitate this interaction. This person will also work on financial reports.

3. An expert on ERP and Data

To truly centralize grant management processes, all vital data points need to be connected. That is why an expert on Enterprise Resource Planning (ERP) and data should sit in the Central Grants Office so they can provide key leadership on existing financial tracking and integrations.

Further, the ERP expert will carry out decision-making across and between elements of the organization that rely on the ERP for implementing and tracking information related to Federal grant regulations.

4. Representatives from the key grant making agencies

Organizations need people in the Central Grants Office who can speak to current funding patterns, values, and risk – representatives from key grant making agencies.

This ownership is vital if an organization wants to achieve buy-in for their centralization plan.

5.  Representative from political or executive leadership

Despite how critical it is, an organization can only achieve centralization, as is the case with most big organizational pushes, if there is buy-in and expertise from leadership. Therefore, a representative from political or executive leadership who can advocate for and expedite initiatives is needed in the Central Grants Office.

After team members have agreed to play a role in the Central Grants Office, it’s time to begin centralization practices. To start off on the right foot, the Grants Coordinator should consider it priority number one to develop and disseminate a set of grant management standards to your organization.

Want to learn the two other pillars for centralizing your grant management processes? Check out AmpliFund’s ultimate guide to Grant Management Centralization.

The recent introductions and updates of new Federal grant regulations are focusing on themes such as transparency, performance, and compliance. To succeed in all these efforts, experts in the grants space are suggesting organizations focus on the more overarching concept of centralization.

This has led to organizations evaluating if and how they should invest in centralizing their grant processes to increase transparency, monitor performance, and maintain compliance.

Specifically, the debate of ad hoc processes versus formal centralization has emerged.

What Are Ad Hoc Grant Management Processes?

Ad hoc processes, or the management of grants on a case-by-case basis, may have been the primary grant management method in the past, but now, only a select few organizations can continue this practice without risking non-compliance.

Ad hoc processes could suffice for your organization if you:

a. Have very few awards to manage

b. Have a limited amount of funding complexity

c. Have one or fewer Federal awards in your grant portfolio

How Can an Organization Formalize Grant Management Centralization?

For most organizations, taking the time to institute formal centralization processes will be necessary to improve outcomes and comply with regulations.

In general, there are three main pillars that set the stage for formal centralization processes. Organizations who require formal processes should focus on:

1. Building out a Central Grants Office
2. Designing and disseminating an organization-wide set of grant standards
3. Ensuring all proper systems for tracking and monitoring awards are in place

Formalizing centralization also extends further than just implementing internal processes and adopting tools. If organizations want to fully formalize centralization, they must also:

• Be mindful of Federal legislation throughout the grant lifecycle
• Keep up to date on policy statements
• Have access to and the ability to post in public portals

Performance measurement is one of the practices your organization will need to centralize if you take the formal approach. To learn more about effective performance management, read AmpliFund’s latest blog on the topic.

The American Rescue Plan of 2021 (ARP) was signed into law on March 11, 2021. The $1.9 trillion stimulus is perhaps best known for the $1,400 stimulus checks which are already being distributed. In addition to providing immediate relief to workers, the ARP has ambitious policy goals, including safely re-opening schools, supporting the national vaccination program, reducing child poverty, and containing COVID-19.

What’s not making headlines is the grant funding packaged within this bill — grant funding that will make a difference in the lives of millions of Americans. The list below is just a sampling of grant funds to be obligated under ARP.

• The Department of Education receives $128 billion to fund grants to local educational agencies, plus $39 billion in grants to higher education institutions.
• The Department of Health and Human Services receives nearly $15 billion for the Child Care & Development Block Grant Program to help support childcare facilities; more than $3 billion to fund grants for mental health care and the prevention and treatment of substance abuse.
• The Small Business Administration receives $25 billion for a new grant program for restaurants and other food and drinking establishments, with an additional $1.25 billion allocated for the Shuttered Venue Operators Grant Program.
• The Department of Housing and Urban Development receives $25 billion for emergency rental assistance, including emergency housing vouchers for people experiencing homelessness, survivors of domestic violence, and victims of human trafficking.
• The United States Department of Agriculture receives more than $1.5 billion to fund Emergency Rural Development Grants for Rural Health Care and the Supplemental Nutrition Assistance Program (SNAP).
• The National Endowment for the Arts and the National Endowment for the Humanities each receives $135 million for grants to state art and humanities councils and regional organizations.

The legislation compels agencies to move quickly to obligate funds — often within thirty days. This may be a challenge for some agencies, as these additional funds greatly increase the amount of money and number of recipients they will be responsible for.

The administration is clearly aware of the impact the ARP will have to grant-making agencies. On March 19, 2021, OMB issued M-21-20 Promoting Public Trust in the Federal Government Through Effective Implementation of the American Rescue Plan Act and Stewardship of Taxpayer Resources.

This memorandum outlines steps the administration plans to take to support the implementation of the ARP, including working with the Pandemic Response Accountability Committee (PRAC) (previously established under the CARES Act) and agency inspector generals with the goals of minimizing the risk of waste, fraud, and abuse and improving overall award administration “with an increased focus on human-centered program and service design to achieve more equitable results.”

The memo also outlines the responsibilities agencies have — including applying Title 2 of the Code of Federal Regulations (CFR) Grants and Agreements — to the maximum extent authorized by law to all recipients — including for-profits, with limited exceptions. It details measures to take to achieve more equity-oriented results for federal financial assistance and ensure robust and transparent reporting of ARP funds. These points of emphasis align with longstanding grants initiatives, including the DATA Act and the Foundations for Evidence-Based Policymaking Act of 2018, and also align with recent executive orders and memorandums, including Advancing Racial Equity and Support for Underserved Communities Through the Federal Government,  Restoring Trust in Government Through Scientific Integrity and Evidence-Based Policy Making. and  M-20-21 Implementation Guidance for Supplemental Funding Provided in Response to the Coronavirus Disease 2019 (COVID-19).

The memorandum also includes three appendices that provide further guidance on management and oversight of ARP programs and awards:

• Management of Payment Integrity Risks – outlines additional risk factors to be considered as agencies conduct improper payment risk assessments for programs receiving ARP funding and recommends existing resources for agencies to leverage, and recommends that agencies work with their OIGs to identify other areas of potential risk and support needs.
• Achieving More Equity-Oriented Results for Financial Assistance – which stresses that agencies are required to administer programs “in a manner that promotes fair and equitable administration of financial assistance and takes a risk-based, data-driven approach that balances compliance requirements with demonstrating successful results.” This appendix is provided to remind agencies of requirements of importance for administering ARP funds and notes that “agencies should apply the requirements of 2 CFR part 200 to all types of financial assistance awards funded through the ARP.”
• Disaster Relief Flexibilities to Reduce Burden for Financial Assistance – which provides agencies with authority to grant certain exceptions to recipients affected by the pandemic, including flexibility with SAM registration, allowance of pre-award costs, no-cost extensions on expiring awards, waivers for prior approvals, and extensions on financial reporting, single audit submission, and closeout as needed. Agencies are required to maintain records of all exceptions provided.

The ARP represents a huge step forward in facilitating recovery from the pandemic. Effective distribution and oversight of the funding are critical. Agencies should review M-21-20 and plan to work with OMB to effectively steward their funds while providing transparency into what the funds are being used for and working to limit waste, fraud, and abuse.

GAO Seeks Action on 66 COVID-Related Recommendations

The Government Accountability Office (GAO) recently issued 28 new recommendations ― several of which are aimed at financial assistance programs impacted by the COVID-19 pandemic ― and called for action on 38 still-to-be-implemented recommendations previously mentioned in other COVID-related GAO reports that federal agencies can take as an effective response to the public health and fiscal emergency.

Noting that the pandemic continues to result in “catastrophic loss of life and substantial damage to the global economy, stability and security,” GAO cited actions taken by Congress, including enacting the Coronavirus Aid, Relief, and Economic Security (CARES) Act (Pub. L. 116-136), along with other relief packages, “to protect the health and well-being of Americans.” A provision in the CARES Act required GAO to report bimonthly on its federal efforts related to the pandemic, and it has issued six reports to date containing 44 recommendations. However, only six of these recommendations have been fully implemented.

GAO is now urging agencies to take “swift action” on its other 38 prior recommendations. In addition, a March 31 report added 28 new recommendations. “These recommendations are tailored to specific federal programs and initiatives, and, if implemented, will strengthen the efficiency, effectiveness and accountability of federal efforts,” GAO said. “We will continue to monitor the status of these recommendations as part of our ongoing oversight of the federal government’s COVID-19 response and recovery efforts.”

New Recommendations

Among the recommendations GAO included it its recent report are some specific key concerns. For example, the U.S. Department of Agriculture (USDA) administers several federal nutrition assistance programs to vulnerable populations, but had released minimal data about participation in these programs since the pandemic started, and had not publicly shared sufficient information about data quality. Therefore, according to GAO, stakeholders and the public could not access sufficient information about and were not given appropriate context in which to interpret key program data and understand the effects of the pandemic on the programs.

GAO recommended that USDA: (1) provide sufficient context to help stakeholders and the public understand and interpret data on federal nutrition assistance programs during the pandemic, and (2) disclose potential sources or errors that may affect data quality during the pandemic, such as manual processing.

Although the Federal Emergency Management Agency (FEMA) administers Disaster Relief Fund monies, tribal governments told GAO that FEMA did not have staff to assist them when they requested technical assistance related to disaster activities. GAO recommended that FEMA provide timely and consistent technical assistance to support tribal governments’ efforts to request and receive public assistance as direct recipients, including providing additional personnel, if necessary, to ensure that tribal nations are able to effectively respond to COVID-19.

The Department of Education (ED) provided COVID-19 assistance dollars through the Education Stabilization Fund for states’ and territories’ education needs, but did not maintain complete data on how these funds were used. GAO recommended that ED regularly collect and publicly report information on school districts’ financial commitments (obligations), as well as outlays (expenditures) to more completely reflect the status of their use of federal COVID-19 relief funds. For example, the agency could modify its annual report on state and school district spending data to include obligations data in subsequent reporting cycles.

Concerning the Department of Labor’s (DOL) Pandemic Unemployment Assistance (PUA) program, GAO continued to have concerns about overpayments and fraud. As of March 15, DOL reported that states identified more than $3.6 billion in PUA overpayments from March 2020 through February 2021. GAO recommended that DOL collect data from states on the amount of overpayments flagged in the PUA program to effectively monitor the recovery of overpayments.

Concerning the Economic Injury Disaster Loan (EIDL) program, GAO said the Small Business Administration should: (1) conduct and document a fraud risk assessment for the program; (2) develop a strategy that outlines specific actions to address assessed fraud risks in the program on a continuous basis; and (3) implement a comprehensive oversight plan to identify and respond to risks in the program to help ensure program integrity, achieve program effectiveness and address potential fraud.

Another key suggestion GAO provided under the 28 new recommendations called for the Office of Management and Budget (OMB) to work in consultation with federal agencies and the audit community (e.g., agency offices of ) (e.g., agency offices of inspector general; National Association of State Auditors, Comptrollers, and Treasurers; and American Institute of Certified Public Accountants) to incorporate appropriate measures in OMB’s process for preparing single audit guidance, including the annual OMB Compliance Supplement, to better ensure that such guidance is issued in a timely manner and is responsive to users’ input and needs.

Previous Recommendations

Among some of its previous recommendations involving COVID pandemic funding, GAO recommended that as the Department of Health and Human Services redesigns its performance management approach to improve its ability to assess whether the Community Services Block Grant program is meeting the national program goals to reduce poverty, promote self-sufficiency and revitalize low-income communities, the agency should include information on how its national performance measures and state outcome measures align with national program goals and include a written plan for how it will assess data reliability. This recommendation remains open.

Another open recommendation is GAO’s request that OMB develop and issue guidance directing agencies to include as part of their improper payment estimation methodologies COVID-19 relief funding with associated key risks, such as provisions contained in the CARES Act and other relief legislation that potentially increase the risk of improper payments or changes to existing program eligibility rules, as part of their improper payment estimation methodologies. This should be required especially for existing federal programs that received a substantial infusion of COVID-19 relief funding, GAO added.

For More Information

The GAO report, “COVID-19: Sustained Federal Action is Crucial as Pandemic Enters its Second Year,” (GAO-21-387) is available at https://www.gao.gov/assets/gao-21-387.pdf.