10 common pitfalls to executing an effective Emergency Rental Assistance Program

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Distributing Emergency Rental Assistance (ERA) funding to qualified tenants in a timely manner can be fraught with many obstacles. State and local governments should watch out for these 10 common pitfalls with operations, compliance, vendors, and more, and keep in mind these tips for overcoming them.


Pitfall #1 - Operational inefficiencies: Small and large operational inefficiencies alike can result in devastating programmatic consequences for your Emergency Rental Assistance Program (ERAP). Are you confident in your capacity to navigate a dynamic program environment with consistently changing guidance and requirements? 

Tip: Make sure that your staff has the capacity and policy knowledge to be able to catch inefficiencies early on. Know your staff, know what they are capable of. If you do not have the in-house capacity, get a quality assurance/quality control (QA/QC) monitor to provide the in-depth policy knowledge to your program.

erap common pitfalls


Pitfall #2 - Inspector general findings: Poorly managed case files can lead to negative audit findings, repayment of funds, and unwanted media attention for your ERAP. Will your program be on the hook for previously distributed federal funding if your files and processes face audit scrutiny? 

Tip: Performing QA/QC or even capacity audits is a best practice in regard to case file review. Checking that everything is in compliance along the way takes immense pressure off of program closeout.

Pitfall #3 - Recoupment of funds: Recoupment of federal funding is the universal worst-case scenario in any grant program, in any state. Are you confident that your ERAP is defended against recoupment of funding as a result of audit or programmatic review?

Tip: Having a strong programmatic monitoring plan in place from the beginning of a program can drastically decrease chances of findings. 

Pitfall #4 - Excessive reliance on contractors: Congratulations! You have hired a vendor to implement your ERAP. Does your staff have the experience and availability to monitor the vendor to make sure they are doing their job?

Tip: You hired a vendor to do their job, but you need some in-house capacity to monitor them and track progress. An overreliance on vendors can be an issue, especially if the program is not on track. Make sure you have that in-house capacity to monitor, or get a QA/QC vendor to do it for you.

Pitfall #5 - Staffing shortages: You procured a vendor for a turnkey solution, with a target for a certain amount of money to disperse in a certain time period. In order to meet benchmarks, the vendor will need to staff up and train quickly to meet your needs, which can result in pitfalls such as poor production, operational deficiencies, fraud, waste, and abuse, and ultimately recoupment of funds. Does your vendor have sufficient adequately trained staff to meet your time and delivery goals?

Tip: Staffing shortages are one of the prime reasons that programs fail – you just do not have enough people. Especially in this climate, where ERAP solicitations were released one right after the other. We recommend evaluating the benchmarks you want to hit in the next year and whether your vendor is providing enough staff to meet those goals.

Pitfall #6 - Poor production: Many factors lead to poor or under-production of eligibility reviews: lack of training, staffing, strategy, etc. What controls are you implementing to support high-quality production for your ERAP reviews?

Tip: Often, most of the focus is geared toward production – how many payments are going out the door, etc. However, if you ignore factors that may contribute to poor production, you may be ignoring a huge problem. Spend some time reviewing staffing and training requirements that your company and/or your vendor is providing.

Pitfall #7 - Fraud, waste, and abuse: The concern of fraud, waste, and abuse has tripled across the compliance community in regard to any pandemic relief funding. Inspectors general and auditors expect to see controls in place specific to safeguarding against these pitfalls. Do you have an anti-fraud plan? How is your ERAP monitoring and reporting suspected fraud, waste, and abuse?

Tip: Make sure that you are not only advertising where to report fraud, waste, and abuse, but also have an SOP written that addresses what your program is doing to prevent them. 

Pitfall #8 - Negative publicity: Slow payments or inequity make for some big headlines. It is often difficult to highlight all the successes of a program when overshadowed by failures. Who is looking out for your agency should your vendor or the technology solution implementing your ERAP fail?

Tip: Having reporting capabilities that can foresee these problems before they become front-page news is not just a strategic advantage, it is vital in establishing public trust for these programs. Make sure you are getting accurate reporting that not only makes sense to you, but also can stand up in a Senate hearing.

Pitfall #9 - Missed deadlines: Deadlines are written in contracts for a reason, but sometimes the penalty for missing a deadline is not. How do you ensure that your ERAP vendors are meeting their deadlines and keeping to the benchmarks you set?

Tip: Many contracts have great penalties written in for missed deadlines, while others may not. However, none of the penalties mean anything unless the deadlines are being tracked, monitored, and, most importantly, held accountable for.

Pitfall #10 - Under-subscribed program: Not hitting the entire target population or adding strict requirements above and beyond federal guidance are just some of the factors that can lead to an under-subscribed program. In some cases, you may not be targeting certain populations or areas effectively, resulting in potential inequity and under-subscription. Is your program hitting the mark, and if not, why?

Tip: Having an understanding of where your target populations are and how they are being served is a critical first step. Prioritizing equitable dissemination often will solve the issue of an under-subscribed program.

The biggest pitfall

Although the above pitfalls can be devastating to an ERAP, the biggest pitfall of all is not discovering these pitfalls in time to prevent wasting funding and staffing resources, as well as risking your organization’s reputation. We urge you to create a transparent program with stringent controls, perform regular benchmarking to confirm that your program is on target with your goals, and reach out for assistance when you need it. 

Contact our team for more information about how to avoid ERAP pitfalls, or learn more about our ERAP services.


Amanda Campen, Senior Manager, Government Advisory



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This has been prepared for information purposes and general guidance only and does not constitute legal or professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice. No representation or warranty (express or implied) is made as to the accuracy or completeness of the information contained in this publication, and CohnReznick LLP, its partners, employees and agents accept no liability, and disclaim all responsibility, for the consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision based on it.