Is it permissible to report expenditures incurred by a sub-recipient prior to the award date? If so, how should "term-start date" be defined?

At present and subject to future modifications, it is not permissible to report expenditures incurred by a subrecipient prior to the award date. The U.S. Department of the Treasury’s (“Treasury”) Coronavirus State and Local Fiscal Recovery Funds (“CSLFRF”) reporting portal does not presently allow recipients to enter subrecipient expenditures incurred prior to the Subaward Award Date. The “Expenditure Start Date,” as utilized in the CSLFRF reporting portal, must occur after the Subaward Award Date, or the system will reject the entry. Treasury defines the Expenditure Start Date as the “start date for the range of time when the expenditure(s) occurred.”[1] Additionally, Treasury defines the Subaward Award Date as the “date the Recipient obligated funds to a Subrecipient.”[2] These dates may not necessarily be the same date.

Last Updated: February 15, 2023