ERA Quarterly Reporting: Required Data Points and Performance Measures, Study notes of Public Law

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Emergency Rental Assistance Program Reporting Guidance

i

Emergency Rental Assistance Program

Reporting Guidance

June 30, 2021

Version 1.

Emergency Rental Assistance Program

Reporting Guidance i

• Overview Table of Contents
• Section I: Reporting Process
• Section II: Reporting Periods and Deadlines
• Section III: Section-by-Section Guidance ................................................................................. - Module A: Recipient Information ................................................................................. - Module B: Project Overview and Performance Narrative............................................. - Module C: Performance Measures and Participant Demographics............................. - Module D: Participant Household Payment Data File .................................................. - Module E: Financial Reporting .................................................................................... - Module F: Annual Civil Rights Compliance and Reporting ........................................... - Module G: Official Certification .....................................................................................
  • Section IV: Appendices ..................................................................................................
    • Appendix 1 – Required Reporting Elements by ERA Recipient Type ...........................
      • Household-Level Payment Data File Templates ..................................... Appendix 2 – Data Dictionary, Data Upload Formats, and Participant
    • Appendix 3 – ERA Program Terminology .....................................................................
    • Appendix 4 – Race, Ethnicity and Gender Categories ..................................................
    • Appendix 5 – Expenditure Categories and Payee and Payment Types ........................
      • Payment Type ........................................................................................ Appendix 6 – Required Information on Expenditures and Obligations by
    • Appendix 7 – Administration and Compliance Information for ERA1 and ERA
      • Award Recipients ...................................................................................
    • Appendix 8 – Guidance on Required ERA1 and ERA2 Monthly Reports ......................
    • Appendix 9 – Applicable Limitations on Administrative Expenses ................................

Emergency Rental Assistance Program Reporting Guidance

For reporting purposes, Recipients must account for each ERA award separately. Recipients with multiple ERA awards, such as Recipients that received one ERA1 award and one ERA2 award, must submit two separate reports in each reporting period, one for each award. While Recipients may have more than one Federal Award Identification Number (FAIN) associated with their ERA or ERA2 awards, Recipients need only make one quarterly submission covering all of ERA1 and then one other submission for ERA2 covering one or more FAIN, as applicable.

In addition, for reporting purposes, each ERA award (ERA1 or ERA2) is considered one ERA Project. In keeping with this approach, an ERA Recipient that received one ERA1 award is implementing one ERA Project, while a recipient that received an ERA1 award and also received an ERA2 award is administering two separate ERA Projects. This distinction is helpful particularly for the required financial and subaward reporting outlined in Section III Module E, “Financial Reporting,” below.

Each Recipient is responsible for compiling and reporting all required information for each report. This responsibility includes compiling subrecipient and contractor information, as applicable, for each required data element for each report. Subrecipients are entities that received a subaward from an ERA1 or ERA2 Recipient for the purpose of carrying out a portion of the ERA1 or ERA Project on behalf of the Recipient. Contractors are entities that entered into a contract with an ERA1 or ERA2 Recipient for the purpose of providing goods and/or services to implement an ERA Project.

Important New Requirement for Household-Level Data: All State, Local, and Territorial Recipients must provide, as a part of each of their required Quarterly Reports, a Participant Household Payment Data File with detailed information on assistance provided to/for each participant household during the reporting period, as highlighted in Figure 1. See Section III, Module D below for more information on the required Participant Household Payment Data File. (Note: Tribe, TDHE, and the DHHL Recipients are not required to submit Participant Household Payment Data Files.)

Emergency Rental Assistance Program Reporting Guidance

What is the Platform for Submitting the Required Reports?

Each Recipient is responsible for submitting its reports via Treasury’s online Portal. ERA reporting will not occur through the GrantSolutions portal used for Coronavirus Relief Fund reporting under section 5001 of the CARES Act.

Treasury will provide a portal user guide and instructions for bulk data file uploads to all ERA Recipients in July 2021 as soon as possible. Treasury’s portal will open for Quarterly Reporting on or about July 15, 2021. In addition, the following information can be found on the Emergency Rental Assistance Program page:

• ERA Data Dictionary (draft available now)
• ERA Reporting Portal Wireframes of Treasury’s Portal screens (draft available now)
• Template and user guide for Recipients that opt to provide the required report information using the batch upload function instead of the online form available via Treasury’s Portal.
• Template and user instructions for the Participant Household Level Data File (All State, Local, and Territorial Recipients are required to submit this data file. Tribe, TDHE, and the DHHL Recipients are not required to submit the data file.).

Figure 1

Highlights of Required Participant Household Payment Data File

The Participant Household Payment Data File must provide the following data points for each payment of ERA Assistance paid under the subject ERA Project in the reporting period:

• Physical address of the participant household;
• Payee type (i.e., Tenant; Landlord or Owner; Utility/Home Energy Service Provider; Other Housing Services and Eligible Expenses Provider);
• Category of Financial Assistance provided;
• Amount of payment;
• Date of payment; and
• Date range for the period of performance the ERA Financial Assistance is intended to cover for the household (that is, the months in which household expenses are covered as documented in the participant household’s application, as appropriate).

Recipients should report multiple entries per participant household where households received multiple forms of assistance under separate agreements, as needed, taking care to avoid counting assistance twice. See Section III, Module D below for more information.

Emergency Rental Assistance Program Reporting Guidance

• Pandemic Response Accountability Committee (“PRAC”) reporting requirements per section 15011 of the CARES Act (Pub. L. No. 116-136), as amended by Title VIII, Section 801(b) of the Consolidated Appropriations Act, 2021 (Pub. L. No. 116-260); and
• Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 CFR Part 200 (hereafter, “the Uniform Guidance”).

The required reports enable Treasury and the Treasury’s Office of Inspector General (Treasury OIG) to monitor Recipient performance and compliance with ERA program requirements. Treasury will release summary results of Recipient reports to the public and oversight bodies, including the PRAC.

Special Instructions Regarding Redirected Award Funds

Any local government that received an ERA award and subsequently redirected - 100% of the award funds received from Treasury to its State or Territory is not subject to the reporting requirements described in this document provided that it submitted the relevant redirection documentation to Treasury and Treasury provided confirmation of acceptance of such documentation. The redirect of the local government’s ERA award funds to the State or Territory Recipient effectively modified the State or Territory’s ERA award. As such, the State or Territory will be responsible as the Recipient for reporting on the use of the redirected award funds, as such funds are now subject to the requirements set forth in the ERA Award Terms and Conditions previously accepted by the State or Territory in connection with its ERA award. A local government recipient that redirected 100% of its ERA award funds to its State or Territory, but did not submit the relevant redirection documentation to Treasury, is still subject to the Interim, Monthly, and Quarterly Reporting requirements under the ERA program until it submits the relevant redirection documentation to Treasury and Treasury confirms acceptance of its redirection documentation.

What is Covered in this Guidance Document?

The remaining four sections of this document provide detailed guidance and instructions on the reporting process and requirements.

Section I. Reporting Process

Section II. Reporting Periods and Deadlines

Section III. Reporting Section-by-Section Guidance

Module A. Recipient Information Module B. Project Overview and Performance Narrative Module C. Performance Measures and Participant Demographics Module D. Participant Household Payment Data File

Emergency Rental Assistance Program Reporting Guidance

Module E. Financial Reporting Module F. Annual Civil Rights Compliance and Reporting Module G. Certification

Section IV. Appendices

Additional Information or Questions?

If you have questions about ERA1 or ERA2 award administration or reporting requirements, please send an email to us via EmergencyRentalAssistance@treasury.gov.

Emergency Rental Assistance Program Reporting Guidance

On-Line System for Submitting Required Reports

All Recipients must submit required reports via Treasury’s Portal, which Recipients used to submit the necessary information to receive an ERA award from Treasury.

Treasury will provide ERA Recipients with a user guide for Treasury’s Portal and will host trainings to help Recipients prepare for and meet their ERA reporting obligations.

Allowed Formats for Providing the Required Information

All Recipients may use either of the following two methods for submitting the required report data:

• Manual Data Entry. Key-in the information to Treasury’s Portal via online fillable forms.
• Batch Upload via Excel Template. Enter the required information into Excel files provided by Treasury and then upload the files into the portal. Treasury will provide Recipients with pre-formatted Excel files for this purpose.

In addition, all State, Local, and Territorial Recipients must provide a Participant Household Payment Data File containing participant household payment information as part of their required Quarterly Reports and as described in Section III, Module D below. Note: Tribe, TDHE, and the DHHL Recipients are not required to provide Participant Household Payment Data Files.

Figure 2 (cont inued) Step 7 – Treasury staff will review the information submitted by the Recipient for Treasury’s ongoing programmatic and financial monitoring.

Step 8 – Treasury will post select information on each Recipient’s reporting on each of its ERA Project(s) (each ERA1 and ERA2 award) on Treasury.gov.

Step 9 – Each Recipient will continue to administer its ERA Project(s) and continue gathering information for the next required quarterly report. Good faith changes to prior submissions will generally be allowed with some exceptions.

Emergency Rental Assistance Program Reporting Guidance

Section II: Reporting Periods and Deadlines

Recipient reporting obligations include submissions of Monthly and Quarterly Reports. Recipients must provide all required reports on each ERA1 and ERA2 award separately without commingling funds, data, or records.

Monthly Reports. All State, Local, and Territorial Recipients that received ERA1 and/or ERA awards must submit brief Monthly Reports covering two data points only: 1) the total number of participating households, and 2) total amount of ERA funds expended. Currently, Treasury is requiring all Recipients to submit Monthly Reports for the April, May, June, July, and August 2021 reporting periods. Please see Appendix 8 for additional information about the required Monthly Reports. Note: Tribe, TDHE, and the DHHL Recipients are not required to provide monthly reports.

Please be aware that Treasury may require submission of additional Monthly Reports as needed.

Quarterly Reports. All State, Local, and Territorial Recipients and all Tribe, TDHE, and the DHHL Recipients must submit Quarterly Reports with reporting periods of one calendar quarter.

Recipients must submit the following upcoming reports:

• June Monthly Report, submission deadline of July 15, 2021

o Reporting period June 1 – June 30, 2021 (ERA1 and ERA2 State, Local, and Territorial Recipients only) Note: See Tables 1 and 2 below for timeframes and deadlines for required Monthly Reports for the months of July and August 2021. See Appendix 8 for complete guidance on the required ERA1 and ERA2 Monthly Reports.

• State, Local, and Territorial Recipients: Q1 and Q2 Quarterly Reports, submission deadline of July 29, 2021

o ERA1 Q1 2021 Quarterly Reports (reporting period of date of award – March 31, 2021) (ERA1 State, Local, and Territorial Recipients and Tribe, TDHE, and the DHHL Recipients)

o ERA1 Q2 2021 Quarterly Reports (reporting period of April 1 – June 30, 2021) (ERA1 State, Local, and Territorial Recipients and Tribe, TDHE, and the DHHL Recipients)

o ERA2 Q2 2021 Quarterly Report (reporting period of date of award – June 30, 2021) (ERA2 State, Local, and Territorial Recipients)

Emergency Rental Assistance Program Reporting Guidance

Table 2 ERA2 Award Reports – Reporting Periods and Submission Deadlines

State, Local, and Territorial Recipients Cycle

Calendar Quarter / Month and Year

Reporting Period Submission Deadline

Required (^) Monthly 1 Jun Monthly Jun 1-30, 2021 Jul 15, 2021 Required (^1) Q2 2021 Award Date – Jun 30, 2021 Jul 29, 2021 Required (^) Monthly 2 Jul Monthly Jul 1 - 31, 2021 Aug 15, 2021 Required (^) Monthly 3 Aug Monthly Aug 1 - 31, 2021 Sep 15, 2021 Required (^2) Q3 2021 Jul 1, 2021 – Sep 30, 2021 Oct 15, 2021 Required (^3) Q4 2021 Oct 1, 2021 – Dec 31, 2021 Jan 17, 2022 Required (^4) Q1 2022 Jan 1, 2022 – Mar 31, 2022 Apr 15, 2022 Required (^5) Q2 2022 Apr 1, 2022 – Jun 30, 2022 Jul 15, 2022 Required (^6) Q3 2022 Jul 1, 2022 – Sep 30, 2022 Oct 17, 2022 Required (^7) Q4 2022 Oct 1, 2022 – Dec 31, 2022 Jan 16, 2023 Required (^8) Q1 2023 Jan 1, 2023 – Mar 31, 2023 Apr 17, 2023 Required (^9) Q2 2023 Apr 1, 2023 – Jun 30, 2023 Jul 17, 2023 Required (^10) Q3 2023 Jul 1, 2023 – Sep 30, 2023 Oct 16, 2023 Required (^11) Q4 2023 Oct 1, 2023 – Dec 31, 2023 Jan 15, 2024 Required (^12) Q1 2024 Jan 1, 2024 – Mar 31, 2024 Apr 15, 2024 Required (^13) Q2 2024 Apr 1, 2024 – Jun 30, 2024 Jul 15, 2024 Required (^14) Q3 2024 Jul 1, 2024 – Sep 30, 2024 Oct 15, 2024 Required (^15) Q4 2024 Oct 1, 2024 – Dec 31, 2024 Jan 15, 2025 Required (^16) Q1 2025 Jan 1, 2025 – Mar 31, 2025 Apr 15, 2025 Required (^17) Q2 2025 Apr 1 , 2025 – Jun 30, 2025 Jul 15, 2025 Required (^18) Q3 2025 Jul 1, 2025 – Sep 30, 2025 Oct 15, 2025 Required (^19) Final Report Jan 31, 2026

Emergency Rental Assistance Program Reporting Guidance

Section III: Section-by-Section Guidance

The required reports consist of six modules: (A) Recipient Information; (B) Project Overview and Performance Narrative; (C) Performance Measures and Participant Demographics; (D) Participant Household Payment Data File; (E) Financial Reporting; (F) Annual Civil Rights Compliance and Reporting; and (G) Official Certification.

Treasury is requiring Tribe, TDHE, and the DHHL Recipients to report on a subset of the otherwise required information, as noted throughout this guidance. Please see Appendix 1 for a complete listing the data points applicable for Tribe, TDHE, and the DHHL reporting.

Please also see the accompanying Data Dictionary and Wireframes for the ERA components of Treasury’s Portal as posted on the Emergency Rental Assistance Program page.

Module A: Recipient Information

This portion of the report allows Recipients to review and update existing portal information about the Recipient. Generally, the Recipient will need to review and verify details about the Recipient and the subject ERA Project, and points of contact.

Verification of Recipient Details

The following information about the Recipient will be pre-populated on Treasury’s Portal form with information on the subject ERA Project. Recipients must review and verify the information and provide updates quarterly.

• Recipient DUNS Number;
• Recipient Taxpayer Identification Number (TIN);
• Recipient Legal Entity Name;
• Recipient Type;
• Recipient Street Address; and
• Recipient City, State, and Zip Code.

Official Points of Contact

Treasury’s Portal will display the names and contact information for Recipient’s staff previously designated as the Recipient’s Points of Contact for Reporting and Authorized Representative(s) for Reporting for its ERA Project(s). Recipients must review and verify the names and contact information as part of each Report submission.

Emergency Rental Assistance Program Reporting Guidance

• Information on the use of fact-based proxies for determining income eligibility for ERA assistance with a yes/no indicator of whether Recipient uses a fact-based proxy, and if yes, a brief narrative description of the proxy of up to 500 words or less.

Performance Narrative

In addition to the Project Overview, Recipients must provide a performance narrative (Treasury’s Portal will accommodate a narrative of up to 2,000 words or less) concerning the performance and accomplishments of the subject ERA Project. The performance narrative should support the performance and demographic data submitted and must cover the following topics:

• Activities implemented and notable achievements over the calendar quarter;
• Activities planned for the next calendar quarter;
• Notable challenges and status of each challenge;
• Details on compliance/non-compliance issues and mitigation plans;
• Requests for additional assistance or guidance from Treasury; and
• Other information, as appropriate. Recipients do not need to repeat information provided in the Project Overview section above.

Narrative on Effective Practices

Recipients may provide a brief narrative describing the Recipient’s effective practices for administering ERA programming to share with the ERA community (up to 500 words or less).

Emergency Rental Assistance Program Reporting Guidance

Module C: Performance Measures and Participant Demographics

This section requires Recipients to provide detailed information on the status of the subject ERA1 or ERA2 Project using the performance data and participant demographic information listed below.

Please see the accompanying Data Dictionary and Wireframes for the ERA components of Treasury’s Portal as posted on the Emergency Rental Assistance Program page.

For each measure and data element below, Recipients must report progress achieved over the reporting period. State, Local, and Territorial Recipients must also report certain data elements by race, gender, and ethnicity of the primary applicant for assistance in the household. Please see Appendix 4 for a list of the required demographic categories.

Note: Tribe, TDHE, and the DHHL Recipients are not required to report the race, gender and ethnicity data points for any of the following items.

Reminder on ERA Financial Assistance Types and Expenditure Categories

Recipients may use ERA funds to provide various forms of Financial Assistance, Housing Stability Services, and for Administrative Costs. The definitions below provide more detail around each of the three types of assistance.

Financial Assistance:

There are five types of Financial Assistance that Recipients may provide under the ERA program:

i. Rent; ii. Rental Arrears; iii. Utilities/Home Energy Costs; iv. Utilities/Home Energy Costs Arrears; and v. Other Expenses Related to Housing. It is important to track the type or types of Financial Assistance provided to each unique, participant household to comply with the section 501(g) reporting requirements in the Consolidated Appropriations Act of 2021. See Treasury’s ERA Frequently Asked Questions (FAQs) on the Emergency Rental Assistance Program page for more information on this topic.

Housing Stability Services

This assistance type includes a broad range of services that target households at risk of homelessness and instability, including eviction prevention and diversion services. Please see the detailed list published in Treasury’s ERA Frequently Asked Questions (FAQs) on the Emergency Rental Assistance Program page.

Emergency Rental Assistance Program Reporting Guidance

measures by race, ethnicity, and gender of the primary applicant for assistance. Appendix 4 includes Treasury’s definitions for relevant demographic data.

For the data elements requiring calculation of rates or averages, Treasury’s Portal will perform the calculations using data submitted by the Recipients to prerequisite fields. In these cases, the Recipient must review and verify these calculations before certifying and submitting the Quarterly Report. When reviewing and validating the system calculations, please notify Treasury if you identify any material inconsistencies between independently calculated and system-calculated figures.

Table 4 below summarizes performance data required of Tribe, TDHE, and the DHHL Recipients in this subpart. Tribe, TDHE, and the DHHL Recipients are required to provide current quarter totals only. Tribe, TDHE, and the DHHL Recipients are not required to report the information by race, ethnicity or gender of the primary applicant.

Table 4 ERA Performance Measures Required of Tribe, TDHE, and the DHHL Recipients ERA Performance Measures Current Quarter Total a. Number of unique households that completed and submitted an application for ERA assistance

X

b. Number of unique households that received assistance of any kind X c. Acceptance rate of applicants for ERA assistance System calculation d. Number of unique households that received ERA assistance by type X f. Total amount of ERA award funds paid to or for participant household (^) X

g. Average amount of ERA award funds provided to or for each participant household

System calculation

i. Housing stability services X

The following lists each required measure in this subpart with a definition and additional details for each.

a. Number of Unique Households that Completed and Submitted an

Application for ERA Assistance.

(Note: Tribe, TDHE, and the DHHL Recipients must report this element, with no requirement to report the information broken out by race, ethnicity and gender of the primary applicant for assistance.)

Emergency Rental Assistance Program Reporting Guidance

Definition: The number of unique households that submitted a complete application, as reasonably determined by the Recipient, for ERA assistance in the reporting period. The phrase “unique households” means that each household applying for assistance should only be counted once, including where applicants applied multiple times in the reporting period. The Recipient must report the number of unique households for whom the ERA Recipient received a completed application in the reporting period. The Recipient must also report the number broken out by the race, ethnicity, and gender of the primary applicant for assistance. (Tribe, TDHE, and the DHHL Recipients are not required to report these numbers by race, ethnicity, and gender)

b. Number of Unique Households that Received ERA Assistance of Any

Kind

Note: All Recipients, including Tribe, TDHE, and the DHHL Recipients must report this element, with no requirement to report the information broken out by race, ethnicity and gender of the primary applicant for assistance.

i. Number of Unique Households that Received ERA Assistance (#)

Definition: The number of unique participant households whose rent, rental arrears, utility/home energy payments, utility/home energy arrears, or other expenses related to housing were fully or partially paid under the subject ERA Project.

The Recipient must report the number of unique households that received ERA assistance of any type and of any dollar amount under the subject ERA Project in the reporting period. The Recipient must also report the number broken out by race, ethnicity, and gender of the primary applicant for assistance. (Tribe, TDHE, and the DHHL Recipients are not required to report these numbers by race, ethnicity, and gender).

ii. Number of Unique Households that Received their Initial ERA Assistance in the Current Reporting Period

Definition: The sum of the number of unique participant households whose rent, rental arrears, utility/home energy payments, utility/home energy arrears, or other expenses related to housing were fully or partially paid for the first time under the subject ERA Project during the reporting period.

The Recipient must report the number of unique households that received any ERA assistance of any type for the first time under the ERA Project in the reporting period. The Recipient must also report this number broken out by race, ethnicity, and gender of the primary applicant for assistance. (Tribe,