President Trump Signs CARES Act Into Law, Recovery Act-Like Reporting Required
Section: Washington Update

Congress has passed and the President has signed into law a third bill providing aid to those affected by COVID-19. Referred to as the Coronavirus Aid, Relief and Economic Security (CARES) Act, the legislation contains over 2.2 trillion dollars in economic relief to individuals and other affected entities including state and local governments.

CARES would expand unemployment insurance and extend UI benefits for 13 weeks beyond the normal 26 weeks allotted. Additionally, there is a one-time cash payment to individuals, up to $1,200 depending on your income, and up to $1,200 per adult and $500 per child for families. Small businesses are also provided financial relief, as are other major industries that are impacted, such as airlines.
Of note for states is a $150 billion Coronavirus Relief Fund for state, local and tribal governments to be used for expenditures incurred due to COVID-19 during the period that begins March 1, 2020 and ends December 30, 2020. Also provided is an allocation from the U.S. Treasury directed toward investment of municipal securities in the secondary market.

NASACT members who worked tirelessly during the American Recovery and Reinvestment Act implementation will recognize provisions establishing a Pandemic Response Accountability Commission (PRAC) and quarterly reporting similar to that required during ARRA. A new office of Inspector General for Pandemic Recovery is also established.

PRAC is charged with preventing and detect fraud, waste, abuse and mismanagement, and further to work to mitigate major risks that cut across program and agency boundaries. PRAC will be led by members of the IG community and will have an executive director and additional staff to coordinate activities. Activities will be similar to those carried out by the Recovery Board during ARRA including maintaining a user-friendly, public-facing website to foster greater accountability and transparency in the use of covered funds and the Coronavirus response. The website will include detailed information on federal government awards that expend Coronavirus covered funds, including data elements required under the Federal Funding Accountability and Transparency Act of 2006 (31 U.S.C. 6101 note). OMB can prescribe aggregate reporting on awards below $50,000.
The Committee will be required to coordinate its oversight activities with the comptroller general of the United States and state auditors. The committee is to terminate by September 30, 2025.
Section 15011 of the bill sets forth the reporting requirements for covered recipients providing that “no later than 10 days after the end of each calendar quarter, each covered recipient shall submit to the agency and the Committee a report that contains:
- The total amount of large covered funds received from the agency.
- The amount of large covered funds received that were expended or obligated for each project or activity.
- A detailed list of all projects or activities for which large covered funds were expended or obligated, including: 
  • The name of the project or activity.
  • A description of the project or activity.
  • The estimated number of jobs created or retained by the project or activity, where applicable.
  • Detailed information on any level of subcontracts or subgrants awarded by the covered recipient or its subcontractors or subgrantees, to include the data elements required to comply with the Federal Funding Accountability and Transparency Act of 2006 (31 U.S.C. 6101 note) allowing aggregate reporting on awards below $50,000 or to individuals, as prescribed by the director of the Office of Management and Budget. 
An Office of the Special Inspector General for Pandemic Recovery is to be established within the Department of the Treasury appointed by the President with the advice and consent of the Senate. The inspector general for Pandemic Recovery is primarily responsible for conducting, supervising, and coordinating audits and investigations of the making, purchase, management, and sale of loans, loan guarantees, and other investments made by the secretary of the treasury provided for under the act.
NASACT is reaching out to our state and federal partners including the U.S. Government Accountability Office and OMB to determine impacts for NASACT members concerning audit, financial statement preparation and other issues associated with the delivery of large dollars through traditional grant delivery mechanisms. Look for future updates as we navigate implementation of this massive law.  

With the ink barely dry, Congress is beginning discussions on additional relief to address the struggling economy.