12/9/2022

U.S. Treasury CERTS Program Grantee Closeout Checklist
 
Closeout must be done by the 1-year anniversary of when funds first received
 
  • All Grantees must continue to comply with the requirements set forth in section 421 of Division N, Title IV, Subtitle B of the Consolidated Appropriations Act, 2021 (the CERTS Act); its CERTS Grant Agreement; all applicable laws, regulations, guidance, and procedures, including the grantee’s own internal accounting policies and internal controls throughout the closeout process.
  • Closeout for each CERTS award occurs after the Grantee has completed its final reporting requirements through Treasury’s CERTS Portal (CERTS Portal). For the majority of CERTS Grantees, the final reporting period will be the third quarter of 2022, which covers cumulative activities from the effective date of the majority of Grant Agreements through the year anniversary date of when the Grantee first received funds from Treasury.
  • If a Grantee has completed its final reporting requirements in accordance with the terms and conditions of its Grant Agreement, then Treasury will follow its own internal closeout procedures, some of which are summarized below.
  • If a Grantee has failed to complete final reporting requirements in accordance with the terms and conditions of its Grant Agreement, then Treasury expects to move forward with administrative closeout no later than 1 year after the date on which the Grantee first received funds from Treasury.
  • Questions about the CERTS Program, including questions relating to compliance requirements, can be found on the CERTS website: CERTS. Please refer to your CERTS Grant Agreement regarding CERTS compliance obligations. Your CERTS Grant Agreement is available for review by logging into your ID.me account and accessing the CERTS Portal: CERTS Portal

Closeout Activities for Each Grantee
  • After the submission of a Grantee’s final compliance report, Treasury will initiate a closeout review of the CERTS award, which may include, but is not limited to:
  • requesting verification of closeout information from the Grantee;
  • sending repayment instructions to the Grantee, if applicable;
  • engaging the Grantee to resolve any issues found in its final compliance report, if applicable; and
  • initiating or continuing remediation actions, if applicable.
  • For each of the closeout activities, Treasury expects to communicate specific instructions and deadlines to each Grantee. Treasury may engage in closeout activities in addition to those listed above with each Grantee as necessary and in accordance with the CERTS Act, the Grant Agreement, Treasury’s guidance, and otherwise applicable law.
  • After Treasury has completed its closeout activities with respect to a CERTS award, Treasury expects to send a communication to the Grantee that its award has been closed out and no further action is required subject to any conditions set forth in a closeout letter Treasury expects to send to the Grantee.
  • After the closeout letter has been sent to the Grantee, the award is closed.

Financial Closeout Requirements
  • Grantees should certify on its final compliance report that all reports submitted to the CERTS program, including its final compliance report, accurately reflect the Grantee's cumulative financial and programmatic data throughout the CERTS award period of performance.
  • Following the submission of the final compliance report, Treasury will review the report.
  • This step may not be applicable to all Grantees: If a report requires revision, Treasury will request the Grantee to revise and resubmit.
  • This step may not be applicable to all Grantees: Treasury will send repayment instructions and deadlines for payments to a Grantee if:
  • the Grantee’s final compliance report shows that the Grantee did not spend all of the CERTS Grant Funds disbursed to by the end of the period ending on the date that is 1 year after the date on which the Grantee first received funds from Treasury; or
  • the Grantee owes money to Treasury as a result of a Final Determination from Treasury related to an improper use of funds or any remedies imposed for other instances of noncompliance.

Record Retention Requirements
  • In accordance with the terms and conditions of the CERTS Grant Agreement, the Grantee must retain all records, including financial records, supporting documents, statistical records, and all other records pertinent to the Grantee’s compliance with the CERTS Grant Agreement for a period of 3 years after the expiration of the Covered Period, as defined in the CERTS Grant Agreement.

  • This step may not be applicable to all Grantees: Each Grantee may be required to provide any documents requested by Treasury or the Treasury Inspector General for an audit, examination, or evaluation of its compliance with the terms of the CERTS Grant Agreement.
Help Us Make Your CERTS Grant Tax Free
 
Obtaining a legislative fix to address the tax status of the CERTS grants remains an ABA top priority, as Congress speeds toward the end of the legislative session. We still need co-sponsors for H.R. 7477, the CERTS Tax Exemption Act. It remains critical for the industry to continue to reach out to Legislators and make clear the tax fix is still necessary. As last week, we have nearly 75 members of the House of Representatives co-sponsoring the bill. Click here to see if your House member is on list of co-sponsors.
 
Please continue to reach out and remind your House member of the issue and ask for their support. Also, if you have not yet done so, send your legislator a direct message here, urging them to cosponsor H.R. 7477. 
Thank you,
Patricia Cowley 
Executive Director 
Telephone: 717-236-9042 
Email:  director@pabus.org 
Website: www.pabus.org