Program

COVID-19 Federal Assistance e311

Topics

Compliance & Reporting, Timing of Funds

How are reporting requirements impacted by a city’s fiscal calendar?

Reports due to the U.S. Department of the Treasury (“Treasury”) for Coronavirus State and Local Fiscal Recovery Funds (“CSLFRF”) use a calendar-year system, as well as calendar quarters.[1] The Project and Expenditure Reports require key financial grant reporting information and are due quarterly based on calendar quarter ends – March 31, June 30, September 30 and December 31.

Other federal programs related to COVID-19 recovery efforts, such as the CARES Act Provider Relief Fund, operate on a calendar-year reporting system, despite the fact that many recipients operate on a fiscal year basis that does not coincide with the calendar year.

Given these precedents, Treasury is not likely to consider accommodating reporting periods that do not align with current policy.[2]  Treasury’s Interim Final Rule, which was published in the Federal Register on May 17, 2021, solicits comments on the Rule before it is finalized.[3]  If a municipality believes that Treasury should consider amending the Interim Final Rule to address a concern about the timing of reports, the municipality has the option to submit comments to Treasury by the July 16, 2021 deadline.

Regardless of whether Treasury permits different fiscal year starts and ends, a recipient of CSLFRF may choose to track its expenditures and obligations on a monthly basis. Monthly captures of financial and programmatic data allow recipients to generate reports for both their fiscal year and annual reports for Treasury more easily. This information can be used to produce financial statements that follow a calendar year or any other fiscal year end and may prove helpful in completing CSLFRF reports for Treasury.

Last Updated: July 2, 2021

[1] Department of Treasury, “Coronavirus State and Local Fiscal Recovery Funds—Compliance and Reporting Guidance,” Version, 1.0, June 17, 2021, available at: https://home.treasury.gov/system/files/136/SLFRF-Compliance-and-Reporting-Guidance.pdf.

[2]Department of Health and Human Services, Provide Relief Funds Reporting Requirements, available at: https://www.hhs.gov/sites/default/files/provider-post-payment-notice-of-reporting-requirements-june-2021.pdf.

[3] Treas. Reg. 35 CFR 31 at page 113, available at: https://home.treasury.gov/system/files/136/FRF-Interim-Final-Rule.pdf.