CERTS Reporting Due February 15

• February 3, 2022
• Andrew Bollman

We’ve had been waiting for the Treasury to release guidance on the quarterly reporting requirement for months. We finally got that guidance in mid-December. The guidance laid out how the quarterly reporting will work, and Treasury also added a user guide and updated their FAQs section.

Grantees are required to submit their first CERTS quarterly report by February 15, 2022 in the CERTS portal. Most of the reporting relates to verifying information and certifications, as well as providing detailed use on the CERTS funds.

A couple of aspects of the reporting to highlight:

Eligible Expenses:

• Employee Payroll
• Independent Contractor Payroll
• Sole Proprietor Payroll
• Repayment of Debt Accrued to Maintain Payroll During the Pandemic
• Services and Equipment to Protect Workers and Customers from COVID-19
• Operations and Maintenance of Existing Facilities and Equipment
• Restored Compensation of Lost Pay and Benefits for Rehired Employees

Organizational use of funds with subsidiaries and affiliates

• Be sure to include all subsidiaries and affiliates, and report payments to each

Outstanding questions some grantees have

• If a grantee has $250,000 of eligible expenses through 12/31/21, are they required to report all $250,000? Or could they report a lower amount and report eligible expenses in a future quarter?
• Are grantees really required to spend 60% of funds on payroll costs? FAQ #22 addresses the question, but has confused grantees and left them seeking additional guidance.
• What constitutes an independent contractor, and do they need to be paid through

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