Sneak Preview: Reporting Requirements Drafted for CPF Program

Jerry Ashworth
May 19, 2022 at 13:15:27 ET

(The following was excerpted from a recent Thompson Federal Grants Compliance Expert article.) The Department of the Treasury recently released draft reporting guidance for Coronavirus Capital Projects Fund (CPF) recipients other than tribal governments, providing details on required information for quarterly project and expenditures (P&E) reports and annual performance reports. Treasury noted that it will publish CPF reporting guidance for tribal governments in the coming weeks.

Authorized in the American Rescue Plan Act (Pub. L. 117-2), the CPF program allocates funds for eligible states, territories, freely associated states and tribal governments to carry out critical capital projects that directly enable work, education and health monitoring, including remote options, in response to the COVID-19 public health emergency. In addition, it promotes equity by prioritizing investments in unserved and underserved communities. Recipients may use CPF grant funds to cover costs incurred beginning March 15, 2021, through Dec. 31, 2026 (see “CPF Allocations Provided for Grant Planning Costs,” March 2022).

Recipients are responsible for reporting on approved program plans and the associated projects. Treasury defines a “program” as one or more capital projects with common characteristics. Recipients also are responsible for monitoring and overseeing subrecipients’ use of funds and other activities related to the award to ensure that subrecipients comply with the applicable statutory and regulatory requirements, and the terms and conditions of the award (§200.332).

The P&E report is a quarterly report that provides information on projects funded, obligations, expenditures, project status, outputs, performance indicators and other data. The performance report is an annual report to provide information on CPF-funded programs and to describe the outputs and outcomes of programs. According to the draft guidance, the first quarterly P&E report for the recipients covered under the guidance would be due on July 31, 2022, and would cover all use of CPF award funds from the date of award disbursement until June 30, 2022, including use of funds for approved pre-award costs. All reporting would be submitted through Treasury’s Reporting Portal.

(The full version of this story has now been made available to all for a limited time here.)

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