Feds Offer More Detailed Guidance on CARES Funds

The US Department of Treasury issued a new round of additional, much more extensive guidance concerning the use of federal funds to pay for, and reimburse, expenses related to the COVID crisis.

1200px-Seal_of_the_United_States_Department_of_the_Treasury.svgA newly released guidance document (seven pages, pdf document) is available on the Treasury website. It covers frequently asked questions about the uses permitted under the emergency federal CARES legislation.

From the guidance:

May a State receiving a payment transfer funds to a local government?

Yes, provided that the transfer qualifies as a necessary expenditure incurred due to the public health emergency and meets the other criteria of section 601(d) of the Social Security Act. Such funds would be subject to recoupment by the Treasury Department if they have not been used in a manner consistent with section 601(d) of the Social Security Act.

Are recipients permitted to use Fund payments to pay for unemployment insurance costs incurred by the recipient as an employer?

Yes, Fund payments may be used for unemployment insurance costs incurred by the recipient as an employer (for example, as a reimbursing employer) related to the COVID-19 public health emergency if such costs will not be reimbursed by the federal government pursuant to the CARES Act or otherwise.

More details are provided in the full guidance document.

As previously reported on Conduit Street, the Maryland Department of Budget and Management revised its guidance on the distribution of federal Coronavirus Relief Funds – indicating that a county with an approved spending plan and indemnification agreement may receive “frontloaded” distributions, rather than waiting for item-by-item reimbursement.

MACo, in a letter signed by a multitude of county leaders, had expressed concern that the reimbursement-only model would hamper these much-needed local efforts. See Conduit Street coverage: “Counties: Proposed Reimbursement Model for CARES Funds Too Slow.

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