How Do I...Minimize funding clawbacks or adverse audit findings?

A curated list of Questions & Answers to help cities minimize funding clawbacks or adverse audit findings.

Compliance & Reporting, Due Diligence & Fraud Protection, American Rescue Plan Act, Infrastructure Investments and Jobs Act

Are there best practices for effective monitoring of fund usage?

Compliance & Reporting, Housing & Rental Assistance, CSLFRF

Is expenditure reporting guidance regarding housing expected to change given the new housing guidance?

Compliance & Reporting, CSLFRF

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?

Compliance & Reporting, Fund Planning & Allocation, CSLFRF

When reporting CSLFRF expenditures, how should municipalities approach small projects that do not meet the $10 million threshold?

Compliance & Reporting, Due Diligence & Fraud Protection, American Rescue Plan Act, CARES Act

How does PRAC work with municipalities prior to a program’s start to help ensure compliance with requirements for federal pandemic funding?

Compliance & Reporting, Due Diligence & Fraud Protection, American Rescue Plan Act, Infrastructure Investments and Jobs Act

What are good practices for cities in establishing data analytic oversight systems similar to the Pandemic Analytics Center of Excellence (PACE)?

Community Engagement & Local Partnerships, Compliance & Reporting, Due Diligence & Fraud Protection, Federal Funding Streams, American Rescue Plan Act, Infrastructure Investments and Jobs Act

Are there red flags that a risk assessment of a nonprofit serving as a subrecipient to a city should uncover, that if addressed might prevent fraud or at a minimum trigger greater scrutiny to prevent fraud or misappropriation of COVID relief funds?

Compliance & Reporting, Fund Planning & Allocation, Procurements, American Rescue Plan Act

Are applicants required to competitively bid ARPA award funding? What are the pass-through responsibilities for subrecipients under Treasury’s Uniform Guidance for competitive procurement?

Compliance & Reporting, American Rescue Plan Act

Is SAM.gov registration required to receive Coronavirus State and Local Fiscal Recovery Funds? How can award recipients mitigate award delays caused by Sam.gov registration backlogs?

Compliance & Reporting, Program Administration, American Rescue Plan Act, CARES Act, FEMA, HUD, Infrastructure Investments and Jobs Act

Do the provisions of 2 CFR § 200.316 apply in the case of real property purchased with a federal award, regardless of whether the city or a third party purchases the property?