Explanation
BACKGROUND: The City received Emergency Rental Assistance (“ERA2”) Program funding through the American Rescue Plan Act of 2021, from the U.S. Department of Treasury, for the period May 7, 2021 through September 30, 2025. In agreement with the acceptance of ERA2, the City is required to comply with the provisions of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”), which includes the return of funds for any potential instances of fraud, waste, and/or abuse associated with the program.
ERA2 closeout ended April 30, 2026, at which time the City verified the amount suspected for potential fraud, waste, and/or abuse previously reported to federal oversight entities, including the Special Inspector General for Pandemic Recovery (SIGPR) and Offices of Inspector General (OIG). The U.S. Department of Treasury authorized the ERA2 return in the amount of $438,813.48. This ordinance is necessary to provide for the required reimbursement of ERA2 funds to the U.S. Department of Treasury.
The required repayment will be made using ERA interest earnings that have been set aside for this purpose, minimizing impacts on City operations and local resources. Through these actions, the City seeks to maintain the integrity of the ERA program while demonstrating its continued commitment to compliance, transparency, and responsible stewardship of federal funds.
FISCAL IMPACT: This ordinance authorizes the expenditure and return of $438,813.48 from the Emergency Rental Assistance Fund (Fund 2208) to reimburse the American Rescue Plan Act of 2021, administered by the U.S. Department of Treasury.
EMERGENCY DESIGNATION: Emergency action is requested to allow the financial transaction to be processed as soon as possible to mitigate risk of potential penalties from untimely action and assurance compliance with a 30-day deadline.
Title
To authorize the Director of Finance and Management to reimburse the U.S. Department of Treasury for ERA2 allocation; and to authorize the expenditure of $438,813.48 from the Emergency Rental Assistance Fund; and to declare an emergency. ($438,813.48)
Body
WHEREAS, the City received funds from the U.S. Department of Treasury for the Emergency Rental Assistance 2 (“ERA2) Program; and
WHEREAS, expenditures charged to ERA2 monies must be consistent with the applicable allowable costs, activities, and regulatory provisions incorporated within the grant agreement; and
WHEREAS, ERA2 funds awarded for certain allowable rental assistance and housing stability expenditures were suspected by the City as potential fraud, waste, and/or abuse of program dollars; and
WHEREAS, the City is required to return any ERA2 funds reported as potential fraud, waste, and/or abuse; and
WHEREAS, ERA2 Closeout Instructions for State, Territorial, Local, and Tribal Governments to return Emergency Rental Assistance funds to the U.S. Department of Treasury requires reimbursements to the ERA2 Program be made via ACH;
WHEREAS, an emergency exists in the usual daily operation of the Department of Finance and Management in that it is immediately necessary to authorize the Director to return $438,813.48 to mitigate risk of potential penalties from untimely action, for the preservation of the public health, peace, property, safety and welfare; NOW, THEREFORE,
BE IT ORDAINED BY THE COUNCIL OF THE CITY OF COLUMBUS:
SECTION 1. That the Director of the Department of Finance and Management is hereby authorized to expend $438,813.48 from the Emergency Rental Assistance Fund to reimburse the U.S. Department of Treasury for Emergency Rental Assistance 2 (“ERA2”) Program allocation;
SECTION 2. That the Director of the Department of Finance and Management is hereby authorized to expend $438,813.48 from ERA Fund 2208, Subfund 220802, in object class 05 Other Expenditures per the accounting codes in the attachment to this ordinance.
SECTION 3. That the funds necessary to carry out the purpose of this ordinance are hereby deemed appropriated, and the City Auditor shall establish such accounting codes as necessary.
SECTION 4. That for the reasons stated in the preamble hereto, which is hereby made a part hereof, this ordinance is hereby declared to be an emergency measure and shall take effect and be in force from and after its passage and approval by the Mayor, or ten days after passage if the Mayor does not approve the same.