GFOA with Big 7 Voice Concerns Regarding Contradicting CRF Guidance from the OIG

Last week, GFOA along with other state and local organizations signed and released a letter to the Department of Treasury expressing recent concerns regarding the conflicting guidance between the Treasury and the Treasury’s Office of Inspector General (OIG) over reporting requirements for the Coronavirus Relief Fund (CRF). The focus was specifically on the OIG’s August 28th memorandum’s reporting and record retention requirements contradicting the Treasury’s August 10th FAQs.

This created great concern as State and local prime recipients overseeing the distribution of the CRF predominantly followed the guidance provided in the Treasury’s August 10th FAQs, where they were clearly lead to believe that they “may presume that payroll costs for public health and public safety employees are payments for services substantially dedicated to mitigating or responding to the COVID-19 public health emergency”. However, since the OIG’s August 28th memorandum contradicted this, the letter stated “the prior presumption guidance that states and localities have already acted on to make budgeting, payroll, and employment decisions,” exacerbated regulatory burdens over recipients and generated questions regarding the extent of support by the federal government.

The letter advocated for the OIG’s August 28th memorandum to be “prospective from August 20th, 2020” as a courtesy for prime recipients to understand the requirements laid out by the OIG at the very least. Preferably, the letter requested the contradicting guidance from the OIG’s August 28th memorandum to be withdrawn completely to allow for compliance with the Treasury’s most recently updated guidance from September 2nd where the updates reiterate the presumption initially insinuated from the Treasury’s August 10th FAQs.

The full letter, the OIG’s August 28th memorandum, and the Treasury’s August 10th FAQs and September 2nd guidance can be found on GFOA’s COVID-19 Relief Fund page here.