Understanding 冠状病毒 State and Local Fiscal Recovery Funds 审计 and Reporting Requirements

州和地方财政恢复基金(SLFRF)概述.

的 SLFRF program authorized by the American Rescue Plan Act delivers $350 billion to over 30,000 recipients across the country to support their response to and recovery from the COVID-19 public health emergency. 的 Department of Treasury is still accepting requests for funding today through its submission portal. 

的 2022 Final Rule, issued on April 1, 2022, describes how recipients can use SLFRF funds to replace lost public sector revenue, 应对疫情对公共卫生和经济的负面影响, 为必要的工人提供额外的工资，并投资于水, 下水道和宽带基础设施. A 2023 Interim Final Rule, issued by Congress in September as part of an amendment to the SLFRF program through the Consolidated Appropriations Act, 为受助人使用SLFRF资金提供了额外的灵活性. 我们鼓励受奖人查阅 2022 Final Rule, Overview of the 2022 Final Rule 和 2022最终规则常见问题 协助确定资金的合理用途. 的 2022 Final Rule FAQs have been updated to address the 2023 Interim Rule. 

接受者必须履行合规和报告责任, 根据收到的资金的类型和金额而有所不同. Treasury released updated 合规及报告指引 9月27日, 2023, 提供额外的细节和澄清, 应与奖励条款及细则一并阅读, authorizing statute, 《bet9平台游戏》以及其他监管和法定要求.

审计 Requirements

Treasury has recognized that many recipients of SLFRF funds may be required to comply with Single 审计 or program-specific audit requirements for the first time. An alternative approach, available for recipients of SLFRF that would otherwise not be required to undergo an audit if it were not for SLFRF expenditures, permits eligible recipients to have a compliance examination engagement performed in accordance with the 政府 Accountability Office 政府 审计ing Standards. Eligible recipients include those entities whose total SLFRF award is at or below $10 million and other federal award funds expended are less than $750,000 during the fiscal year. 

Subrecipient vs. 受益人

It’s important for an entity receiving SLFRF funds to understand its designation as either a subrecipient or a beneficiary. This determination will result in either inclusion or exclusion of funds on the Schedule of Expenditures of Federal Awards (SEFA) and, 最终, whether the entity is required to comply with all requirements of recipients, 包括单一审计和分接收方报告要求. 

的 distinction between subrecipient and beneficiary comes down to whether the entity is receiving the funds to carry out the program or as an end user. End users are considered direct beneficiaries and are receiving SLFRF funds due to experiencing a public health or negative economic impact of the pandemic. 因此，受益人不会将SLFRF基金纳入其SEFA. Subrecipients of SLFRF funding, on the other hand, receive funds to carry out program requirements on behalf of the SLFRF recipient 和refore would include SLFRF funds on their SEFA. 

A unique situation exists under the “lost revenue” concept when considering subrecipient versus beneficiary. Recipients may use SLFRF funds to replace lost public sector revenue to provide government services. Treasury has determined that there are no subawards eligible under the “eligible use” category of lost revenue. 的 definition of subrecipient states that the subrecipient carries out the program 和 use of lost revenue funds does not give rise to a subrecipient relationship, 因此，一个实体为弥补收入损失而收到的任何资金, 除了原来的收件人, should be excluded from the SEFA. 

各实体应审查其SLFRF协议, 以及最新的合规补充, for important information regarding audit requirements and to assist in determining whether they’re a subrecipient or a beneficiary. 的y’re strongly encouraged to consult with the SLFRF funder on the determination. 

Helpful 资源:

2023 Compliance Supplement
U.S. 财政部冠状病毒州和地方财政恢复基金

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