Cares Act Subrecipient Agreement

For the purposes of the audit, small businesses are the “beneficiaries” of the Cares Act funding. However, when a local government decides to award a third party the management of small business grants, the third becomes a step backwards and the local government should carefully follow the third party`s verification and recommendation process to ensure compliance with the CARES Act award criteria and that support documents are obtained prior to filing for reimbursement. When a city or county directly administers CARES Act grants to small businesses, the local government itself must put in place internal control and monitoring procedures to ensure receipt of support documents that can verify the claim for reimbursement. In other words, the city or county is the under-intentional and must document all requests for Coronavirus Assistance Funds (FIUs) to ensure compliance with federal audit requirements. The process for reviewing timely closed applications must be clear and transparent. The examination of the application can be carried out directly or by the board of directors of another jurisdiction (municipal council, committee of commissioners) through an interlocal agreement. However, the procuring entity must retain the power to approve distinctions on the basis of recommendations of the audit committee or body, in order to comply with the guidelines of the CARES Act. To meet the requirements of the Confederation, sub-shareholders of FIU funds may have to change their internal control structure, which can be a complex undertaking. From adherence to consistent guidelines to the “Integrated Internal Control Framework” of the Committee of Sponsoring Organizations of the Transport Commission (COSO), creating, implementing and documenting your system of internal control over grants requires time and manpower that you may not have during the ongoing pandemic. Local governments, which have a population of more than 500,000 people and tribal nations, can receive direct distributions from the U.S.

Treasury. The remaining funds are then transferred to the governments of the Länder, part of which is allocated by each state to local governments (sub-grants) that have not received direct funding. These facilities can use the funds to address medical needs, equipment and other services related to COVID-19. .