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Please find below updates on the Shuttered Venues Operator Grant (SVOG) program administered by the Small Business Administration (SBA).
LATEST SVOG REPORT FROM THE SBA: AS OF MAY 23, 2022
More than $14.5 billion in COVID-19 economic relief has been awarded to over 13,000 performing arts venues and organizations, movie theaters, talent representatives, producers, and museums. This program is no longer taking applications and is in the final stages of making grant decisions on supplementals awards, Reconsideration 2.0, and appeals to about 200 remaining existing grantees.
SVOG COMPLIANCE REPORT
This month, the White House and Office of Management and Budget (OMB) published an updated compliance report for several federal grant programs, including SVOG. The OMB section 2 CFR 200 compliance supplement provides a helpful recap of the program and guidelines for implementation that serve as a resource to third party auditors. This is most applicable to only those grantees, who will expend $750,000 or more of federal funds in a fiscal year, using one or multiple federal sources such as SVOG, NEA, and/or EIDL. (Note: PPP funds do not need to be included.) Because this is a very long document, we have excerpted the 7-page SVOG section for your convenience, which is located on pages 1,004 through 1,010 of the original document. Please also know that the SBA is continuing to produce updated FAQ guidance in administering the SVOG program and those latest changes will amend this OMB Compliance Report.
EMPLOYEE RETENTION TAX CREDIT (ERTC) AND SVOG
I wanted to alert those SVOG grantees, who also applied for Employee Retention Tax Credits (ERTC) from the IRS about an important issue. There is an inconsistency in implementation that is currently being resolved by the SBA in its Post-Award FAQs for Question 45.
In Question 45, it currently says that “…Consistent with the allocability standards, grantees should only pay personnel costs that have not already been reimbursed by other Federal funding sources, such as a PPP or EIDL, or wages used to receive the Employee Retention Tax Credit or the paid sick and family leave credits.”
Unfortunately, this SBA answer is not fully accurate and in line with IRS regulations, as it applies to the ERTC only. It is correct that an SVOG grantee, who received ERTC credits for payroll costs in the 3rd quarter of 2021 (July, August, Sept.), is not allowed to use SVOG funds for the same payroll costs covered by ERTC credits during that specific time period. However, IRS guidelines state that you can use SVOG funds to cover payroll costs, even if you received ERTC credits, for specifically these periods of March 2020 through June 30, 2021. Yes, you can “double-dip” in other words. SBA has informed me that they are currently working on realigning their FAQ #45 to match the IRS guidance for ERTC and will be publishing the update soon.
SBA WEBSITE RESOURCES FOR SVOG GRANTEES
The SBA has updated their website for grantees with a section on Manage your SVOG grant (sba.gov). It is full of helpful information including:
- Guidance documents and FAQs
- Informational Sessions and other assistive aids
- How to spend SVOG award funds
- How to respond to the Final Budget Action item
- How to respond to the Expense Report Action item
- Audit requirements
- Additional information on grant closeout process
- Get technical support with the SVOG portal
SBA WEBINARS FOR SVOG GRANTEES
SBA has also produced the first of three helpful webinars on preparing for an audit, if applicable to you. However, this information would be helpful to all grantees in simply understanding best practices for spending your SVOG grant funds. The link to the first audit webinar, which took place in May and was geared more for nonprofits and state and local governmental agencies. The link to this webinar can be found here: Shuttered Venue Operators Grant: Audit Webinar - Youtube.
The second SBA audit webinar will build on information from the first webinar and introduce audit guidance specifically for sole-proprietor and for-profit arts and culture businesses administering an SVOG grant. This next webinar will take place on Thursday, June 9, 2022 @ 2:00pm.
The third SBA audit webinar’s date will be scheduled in July sometime, and the focus will be on an additional alternative that the SBA is working on for sole-proprietors and for-profit businesses to use to comply with audit requirements. Stay tuned for details.
NATIONAL INDEPENDENT VENUE ASSOCIATION (NIVA) CONFERENCE
The Arts Action Fund has become an Affiliate Member of NIVA to bolster support for the groundbreaking work that they’ve done during this pandemic. I’ve already registered for their first annual NIVA conference taking place in Cleveland, Ohio on July 11–12, 2022, and I hope you attend too. NIVA '22 will bring together its community of National Independent Venue Association members, agents, managers, affiliate members, and companies that are interested in partnering with NIVA. This in-person conference, taking place at the start of Independent Venue Week, will be a place for NIVA members to discuss the state of the industry and topics including safety, technology, inclusion, diversity, equality, accessibility, booking, ticketing, and marketing, plus network with other members.
JOIN MY BIWEEKLY ZOOM OFFICE HOURS WITH NINA NEXT FRIDAY @ 11:00 a.m. ET
You can ask me any of your federal COVID-19 relief questions during my Zoom Office Hours. The next one will be Friday, June 3 @ 11:00 a.m. ET. Use this Zoom meeting link to join the call. If you have attended Office Hours with Nina before, we want to hear from you! Please share your story and update us on how the Arts Action Fund has helped you secure COVID-19 economic relief funding.
To read an archive of Arts Action Fund federal updates and more, visit our COVID-19 Resources page.