On June 17, 2020, the Pandemic Response Accountability Committee (PRAC) issued its first report, “Top Challenges Facing Federal Agencies: COVID-19 Emergency Relief and Response Effort” (the “Report”). PRAC was established by the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”). It consists of the twenty-one offices of inspectors general (OIGs) that oversee the agencies that received the bulk of the emergency funding, and it sits within the Council of Inspectors General on Integrity and Efficiency (CIGIE). The purpose of PRAC is to lead the efforts of CIGIE to promote transparency and conduct oversight of the funds disbursed under the CARES Act and related legislation, which currently totals $2.4 trillion. This first report provides a summary, by agency, of identified challenges in disbursing the emergency funding, especially the potential for fraud, abuse, and misuse of those funds, which will likely lead to audits, investigations, and qui tam lawsuits under the federal False Claims Act (FCA) in the months and years to come.

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