National Association of Counties
On July 15, the U.S. Treasury Department (Treasury) issued an addendum to the first round of its Emergency Rental Assistance (ERA) Reporting Guidance, which was initially published on June 30, 2021. The addendum changes the quarterly report deadlines and requirements for state and local government ERA recipients, as requested by NACo and other stakeholder groups in a letter sent to Treasury on July 9. The changes are welcomed by counties, as they will provide additional time and resources to successfully administer the program and report full and accurate data.
All state and local governments that received an ERA award during the first round of the program (ERA1) and/or the second round of the program (ERA2) must submit a quarterly report that includes all recipient, subrecipient and contractor activities for the award. The report must also provide performance and financial information, including background information about the ERA project that is the subject of the report; participant (household, beneficiary) data; and financial information with details about obligations, expenditures, direct payments and subawards.
State and local government recipients that received both an ERA1 and an ERA2 award must submit two separate reports in each reporting period (i.e., one for each award). All reports must be submitted to Treasury’s online portal, which is the same used for reporting on the State and Local Fiscal Recovery Funds. A user guide for the portal is available here.
The addendum made significant changes to quarterly reporting requirements. Now, ERA1 and ERA2 state and local recipients are no longer required to meet all the reporting requirements for the first and second quarter of 2021 by July.
Instead, ERA1 and ERA2 recipients will be required to submit partial Q2 reports by August 6, 2021. The partial Q2 report will require information similar to that included in the Q1 Interim Report that state and local recipients submitted on May 12, 2021.
Full quarterly reporting will begin in Q3 2021. State and local recipients will be required to submit full quarterly financial and programmatic reports for Q1, Q2 and Q3 by October 15, 2021.
In addition to the quarterly reports, state and local recipients that received ERA1 and/or ERA2 awards must also submit brief monthly reports that covers the total number of participating households and the total amount of ERA funds expended. Treasury is currently requiring recipients to submit monthly reports through August 2021, but may extend this further. The addendum does not impact monthly reports, which are due on the 15th day of the month following the reporting period.
To view a chart of the reporting periods and submission deadlines for ERA1 and ERA 2 award reports please click here.
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