CHALLENGE
The Coronavirus Aid, Relief, and Economic Security (CARES) Act appropriated $150 billion to the Coronavirus Relief Fund (CRF) for States and local governments to help pay for expenditures incurred in responding to the COVID-19 public health emergency. While CRF has proven to be a significant remedy for resource-strapped local governments, applying the funds has presented considerable challenges. One of the biggest is CRF’s aggressive timeline. The law was passed in March, the funding was distributed in late May, and the funds need to be expended by the end of 2020.
As a direct recipient of $262M in CRF funding King County in Washington State faced a daunting task of managing a large community of CRF funding subrecipients – each with diverse programs and services.
The County’s COVID-19 response strategy extended beyond public health costs to broader public impact such as school closures, business disruption, unemployment and distance learning. Facing a tightly compressed program performance period – March 1 to December 30, 2020 – the County had to ensure that each subrecipient implemented a compliant program, executed an effective monitoring plan, completed required expense reporting and record retention and prepared an audit-ready closeout.
In order to effectively manage a complex portfolio of CRF programs within the mandated timeline, county leaders realized they had to streamline subrecipient program expenditure tracking and reporting. With internal resources already strained by public health related response activities, King County brought in CARES Act funding experts from Witt O’Brien’s to develop and conduct a comprehensive CRF training program for internal staff and subrecipients.
The goals for the training curriculum were to build subrecipient capacity in standing up and managing programs and create a consistent understanding of the federal requirements to program monitoring, documentation and reporting that would keep county staff, subrecipients and auditors on the same page.
SOLUTION
Witt O’Brien’s began work in June 2020 to structure the curriculum and had the program ready for delivery by September. The training workshops took place in September and October, allowing participants to use the learnings to get their programs into shape to meet the end of year spending and reporting deadline.
Witt O’Brien’s experts developed a two-part curriculum to meet varying levels of experience with Federal funding programs. Part one provided an introductory overview of CARES ACT/CRF and King County COVID-19 response ordinances to familiarize participants with the unique characteristics of CRF and how it differs from traditional federal funding sources. Part two provided detailed guidance on CRF requirements and best practices for eligibility determination, program monitoring, performance measurement, risk management. record retention, reimbursement request documentation, and audit preparation. Participants also received guidance regarding program checklists and monitoring tools.
As the participants progressed in through the training, the course shifted to more nuanced aspects of program management, including identifying and preventing potential duplication of benefits in programs that receive funding from multiple sources. Participants learned how to demonstrate the impact of their programs on COVID-19 containment and community recovery, and methods of quantifying unmet need to justify program expenditures. The training program also provided valuable compliance guardrails that helped subrecipients ensure that less conventional service programs met the Federal eligibility requirement of being a “necessary and unmet” COVID-19 related need.
RESILIENCE DELIVERED
The consensus among King County and its subrecipients is that the training program has put them in a better position to meet the CRF requirements and timeline. The County is already seeing improvements in subrecipient program monitoring and tracking and reporting.
Staff report that there has been a notable reduction in the number of report and documentation revisions and a reduction in duplication of benefits issues. Greater accuracy and efficiency have streamlined reimbursement request submissions and accelerated time to approval. There is also greater confidence that program auditing will go smoothly.