OMB Releases Agency Guidance for Disbursing COVID-19 Supplemental Funding

Published: April 14, 2020

Federal Market AnalysisCoronavirus (COVID-19) PandemicGovernment PerformanceWaste, Fraud, and Abuse

On Friday, OMB released guidance intend to help federal agencies balance speed, mission and stewardship with regards to coronavirus supplemental funding.

Key Takeaways:

  • OMB’s implementation guidance for COVID-19 supplemental funding emphasizes achieving mission goals, and speeding distribution of funds, while also maintaining transparency and oversight.
  • The guidance also gives details on how agencies should report CARES Act spending and awards utilizing existing reporting methods within agency financial systems, including reporting to  
  • OMB will also relax some deadlines for regular reporting to allow agencies time to concentrate on administering pandemic relief funding and legislation.

With over $2 trillion slated for COVID-19 relief and response through recent legislation, OMB provided agencies with guidance regarding disbursement of the funding.

Agencies are directed to use the following core principles when expending the provided funding:

  • Mission achievement - Federal managers and recipients at all levels should use data and evidence to achieve program objectives.
  • Expediency - Agencies should rapidly issue awards and fund programs to meet crucial needs.
  • Transparency and accountability - Agencies must report information on awards to provide the public with information in a clear, accurate, and timely manner.

In the area of mission achievement, OMB instructs agencies to develop and document expected new processes, intended outcomes, risk areas, and performance plans and measures. Agencies are expected to review progress and performance related to pandemic relief legislation internally at least quarterly, and they must report monthly to OMB on expenditures greater than $150,000. The appendix of the guidance gives details on how agencies should report CARES Act spending and awards utilizing existing reporting methods within agency financial systems, including reporting to Additionally, OMB will provide quarterly reports showing the impact of relief funds on employment, economic growth and affected industries.

To meet critical needs with expedited funding and awards, OMB instructs agencies to use previously granted flexibilities for procurement and emergency contracting while balancing “expediency and good stewardship.” Agencies must consider the following when implementing relief legislation and funding:

  • Utilizing qualified personnel to oversee awards
  • Streamlining regulations and internal processes
  • Balancing competition with timely execution
  • Balancing speed with fraud, waste and abuse mitigation
  • Ensuring resources go to evidence-based programs
  • Regularly communicating and coordinating with state and local governments, tribes, and nonprofits for financial assistance

To provide transparency and accountability of funds disbursed through pandemic relief legislation, OMB directs agencies to make evidence-based decisions using data, protect information and provide open data for public use and analysis. OMB states that accountability, oversight, and accurate tracking of funds and awards are essential.  OMB plans to use existing methods and reporting tools for information gathering, to limit agency administrative burdens. OMB instructs agency inspector general offices to develop plans to prevent and detect waste, fraud and abuse related to the distribution of relief funds. The Offices of Inspectors General (OIGs), along with OMB and the newly created Pandemic Response Accountability Committee (PRAC), should work together to coordinated oversight efforts using available technology.

The final provision of the OMB guidance looks to alleviate agency reporting burdens by extending deadlines for certain regular reporting and audit efforts. OMB will work with agencies to grant relief from OMB-established deadlines. Specifically, OMB is pausing required 2nd quarter FY 2020 FISMA metric reporting, and merging quarter one and two reporting requirements for Government Performance and Results Modernization Act priority goals.