Sneak Preview: Treasury Dept. Updates Its ERA1 Closeout Guidance
(The following was excerpted from a recent Thompson Grants Compliance Expert article.) The Department of the Treasury recently updated its closeout guidance for recipients of Emergency Rental Assistance (ERA) program dollars that were awarded under the Consolidated Appropriations Act of 2021 (Pub. L. 116-260). The guidance aimed to clarify the differing closeout responsibilities for grantees that received only their initial allocation, and for those entities that also received reallocated funds.
Treasury provided two rounds of funding under ERA ― the initial allocation of funding, known as ERA1, on Dec. 27, 2020, under Pub. L. 116-260, and a later second wave of funding, known as ERA2, issued on March 11, 2021, under the American Rescue Plan Act (Pub. L. 117-2). ERA1 provided up to $25 billion to state, local, tribal and territorial governments to assist households that are unable to pay rent or utilities as a result of the pandemic, while ERA2 provided another $21.55 billion.
The Consolidated Appropriations Act required Treasury to begin reallocating “excess” ERA1 funds on Sept. 30, 2021, to ensure these funds remain available to grantees in accordance with their jurisdictional needs and demonstrated capacity. Treasury recaptured excess funds from states or other grantees that had not obligated (either spent or committed) at least 65% of their original allocation and reallocated those resources to high-performing jurisdictions that met this threshold.
While the period of performance end date (i.e., the last day for a grantee to obligate funds for ERA1 activities) for initially awarded ERA1 funds was Sept. 30, 2022, the period of performance for funds received through reallocation was extended for 90 days to Dec. 29, 2022. Grantees that received reallocated funds must complete and submit a quarterly report for quarter 4 of 2022 (Q4 2022) — covering Oct. 1, 2022, through Dec. 29, 2022 — before they can complete their final closeout report.
After a grantee meets its final reporting requirements, Treasury will implement closeout procedures consistent with the applicable provisions in the uniform guidance (§§200.344–346). These steps may include: (1) requesting verification of closeout information from grantees; (2) sending repayment instructions to grantees; (3) directing grantees to resolve any issues found in their final report; and/or (4) initiating or furthering applicable remediation actions. Treasury will inform each grantee when its award has been closed out and that no further action is required.
(The full version of this story has now been made available to all for a limited time here.)
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