Subject:
Title
Reimbursement payment to the U.S. Department of the Treasury for funds disbursed through the Emergency Rental Assistance program.
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Recommended Action:
Recommended Action
Approval of a reimbursement payment to the U.S. Department of the Treasury (Treasury) for funds disbursed through the Emergency Rental Assistance (ERA) program.
• Treasury notified the County in October of a compliance monitoring desk review of the ERA2 grant. On January 23, 2026, a monitoring letter was issued stating the County is responsible for remitting the $238,140.00 to the Treasury according to the Treasury Office of Inspector General Joint Notice dated October 4, 2024.
• The funds were disbursed through the ERA program to 11 cases that were subsequently identified as fraudulent applications by County investigation. The Clerk Office of Inspector General reported the case to local and federal law enforcement agencies.
• A request to reclassify non-federal County funds previously spent for ERA eligible activities to offset the ERA funds was denied by Treasury.
• The County received $45.8M of federal funding through the ERA program (ERA1 $19.3M and ERA2 $21.5M) to support housing stability during the COVID-19 pandemic.
• Between January 2021 and December 2022, a total of 5,692 applications were approved and $40.6M disbursed in housing assistance payments.
• The payment to the U.S. Treasury Department will be made from the current budget appropriation within General Government in the General Fund. No budget amendment is required.
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Strategic Priorities:
Smart Service Delivery
4.2 Achieve and maintain a high level of customer satisfaction.
4.4 Pursue continuous improvement.
Summary:
Summary
The Treasury is requiring a return of funds in the amount of $238,140.00. The funds were disbursed through the ERA Program to 11 cases that were identified by the County to be fraudulent applications.
Treasury notified the County in October of a compliance monitoring desk review of the ERA2 program. An entrance meeting took place on October 16, 2025, and weekly meetings were held throughout November.
Program policies, procedures and information on fraudulent applications were requested and provided. Forty (40) case samples were selected and reviewed in detail.
An exit interview was held on January 23, 2026, and a monitoring letter issued stating the County is responsible for remitting the $238,140.00 back to the Treasury. During the exit meeting and through additional follow-up with the lead monitor, Housing and Community Development (HCD) staff sought clarification on an option to recharacterize other County funds used to provide ERA-like assistance as ERA2 expenditures in lieu of repayment.
County response letter dated February 13, 2026, requested approval to recharacterize County funds was submitted to the Treasury.
The Treasury response letter dated March 13, 2026, denied the request to recharacterize other County funds citing the October 4, 2024, ERA Joint Treasury OIG Notice and ERA FAQs 47 and 48.
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Background Information:
The County received $45.8M of federal funding through the ERA program (ERA1 $19.3 ERA2 $21.5) to support housing stability during the COVID-19 pandemic.
The federal funds were administered by the U.S. Treasury Department. It was a new, emergency response program with an emphasis on distributing payments quickly. Guidelines and requirements were developed by Treasury during the program implementation period.
The Pinellas program was implemented between January 2021 and December 2022 by a collaborative partnership between HCD, Office of Management and Budget, Clerk Finance, Clerk IG, and vendors Tetra Tech and Witt O’Brien. During that period, 32,732 applications were created, 7,992 applications completed and reviewed, 5,692 applications were approved and a total of $40.6M disbursed in housing assistance payments.
One hundred forty-eight (148) fraudulent applications were identified by the County preventing $3,070,611.00 in improper payments.
Eleven (11) fraudulent applications were identified by the County after disbursement of funds totaling $238,140.00. The Inspector General referred the cases to federal and local law enforcement agencies for prosecution.
Fiscal Impact:
The reimbursement of funds to the Treasury is not to exceed $238,140.00.
Funding for this payment in the amount of $238,140 is included in a budget amendment recommended to the Board of County Commissioners.
Staff Member Responsible:
Gregg Mims, Director, Housing and Community Development
Bruce Bussey, Community Development Manager, Housing and Community Development (Presenter)
Partners:
Clerk of the Circuit Court and Comptroller Pinellas County
Attachments:
Treasury Desk Review Final Report
Treasury OIG Joint Notice dated October 4, 2024
Pinellas County Response Letter, February 13, 2026
Pinellas County Response March 13, 2026
Treasury Notification April 9, 2026
Summary of Treasury Repayment Issue
Report 2023-17 Audit of Emergency Rental Assistance Program, Clerk IG