CARES Act reporting: FAQs

8/12/2020
CARES Act reporting: FAQs

Here are the most frequently asked questions about the CARES Act reporting requirements – and answers you need to know.

Covered recipients who have received funds from the government under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) will need to submit regular detailed reports on their use of funds, which adds to the stress and pressure on teams that might already be taxed and running thin. We’ve compiled frequently asked questions to help you and your teams prepare for the upcoming reporting dates.

Q: Where can I find the CARES Act reporting requirement? When do I need to report?

A: Sections 15010 and 15011 of the act list the reporting requirements. Federal agencies are required to report monthly, and other covered recipients are required to report each calendar quarter.

Complete guidance is still pending by each federal agency. The Office of Management and Budget (OMB) issued memorandum M-20-21, “Implementation Guidance for Supplemental Funding Provided in Response to the Coronavirus Disease 2019 (COVID-19),” for the heads of federal departments and agencies. The memorandum states that each federal agency is required to report monthly to OMB, the U.S. Department of the Treasury, the Pandemic Response Accountability Committee (PRAC), and applicable congressional committees. However, the OMB guidance does not address the requirements that each federal agency is implementing for CARES Act and COVID-19-related reporting. Recipients of CARES Act and COVID-19-related funds need to check with the respective funding federal agencies to understand the reporting requirements.

We recommend that recipients of covered funds gather data as required by Section 15011 of the CARES Act. Therefore, no later than 10 days after the end of each calendar quarter, each covered recipient shall submit to the appropriate federal agency and the PRAC a report that contains the following information:

  • The total amount of large covered funds received from the agency
  • The amount of large covered funds 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, and the estimated number of jobs created or retained by the project or activity
  • Detailed information on any level of subcontracts or subgrants awarded by the covered recipient or its subcontractors or subgrantees

Covered recipients should keep in mind that funds received under the CARES Act or other COVID-19 funds are subject to oversight by the applicable federal agency, the Office of Inspector General, the PRAC, or other agencies and potentially under the Single Audit Act Uniform Guidance requirements. 

Q: What entities need to report? Which subrecepients? Individual departments?

A: Federal agencies and covered recipients receiving more than $150,000 in funding must report. Subrecipients and individual departments could be required to report.

Q: Things seem to be changing every day. Where do I go for the most up-to-date reporting information?

A: The Treasury website has updated information.

Q. How do I track the status of the awardees that have not reported? 

A: The act doesn’t specifically state that you need to track the status of the awardees that have not reported; however, each agency that has awardees will by default need to understand what costs have been expended or obligated, including the status of the awardees’ use of the funds.

Q: How do I attach my receipts to my submission?

A: The Crowe CARES Act Reporting Tool can serve as a gathering and repository tool where the organization uploads receipts if the grantor requires supporting receipts.

Q: How do I prevent fraud?

A: Due to the high volume of costs related to COVID-19, the risk of fraud is high. Agencies that are providing funds need to make sure that they have internal controls in place to confirm that proper checks exist over funds disbursed under the CARES Act. The best ways for organizations to understand what controls are necessary include knowing the legislation, performing risk assessments of awardees, and performing appropriate oversight of the awardees both at the time of reimbursement and after the funds have been disbursed. Also, agencies should have robust reporting and transparency to properly track funds to determine that those funds were used appropriately.

Crowe CARES Act Reporting Tool

Fortunately, we have a solution that can help make this process simpler and easier. The Crowe CARES Act Reporting Tool is designed to relieve some of your stress quickly – getting you up and running on an intuitive system within a few weeks. Right away, you’ll be able to import data and consolidate it using Microsoft Dynamics™ CRM functionality hosted in a secure cloud environment. By automating the tracking process, you and your team can start saving time while managing all of the required reporting on one secure platform.

These are significant features of this tool:

Track and organize all awards and subawards. Replace your disparate data sources and spreadsheets with one tool that gathers and correlates data, making it easy to see how money is being spent and who’s spending it.

Easily track nonreporting at all levels. Spend less time figuring out who is and isn’t reporting. With data in one place, you can make faster and better decisions about how you communicate and manage reporting at all levels of your organization.

Collect and report securely. Reporting is made accessible yet secure through a private reporting portal set up just for you. Anyone in your organization can report independently – even at the subawardee level.

Automatically upload reports. Through integration with the federal reporting site, this tool allows you to automatically generate an XML file to be directly uploaded at the touch of a button.

Where to start

Start here. We’re ready and willing to discuss any or all of these and other questions you might have about the Crowe CARES Act or to demo the CARES Act Reporting Tool. 

Want to know more about how the Crowe CARES Act Reporting Tool works? 

Interested in a 30-minute demo? Drop an email or give us a call and we’ll talk about how we can help.
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Paul Lionikis