On August 28, the U.S. Department of Treasury’s Office of Inspector General (OIG) released updated guidance outlining new requirements for recipients of the Coronavirus Relief Fund (CRF) that was authorized under  the Coronavirus Aid, Relief and Economic Security (CARES) Act (P.L. 116-136). The CRF provides $150 billion in aid for state, county and municipal governments with populations of over 500,000 people to address necessary expenditures incurred due to the COVID-19 public health emergency.

The new guidance comes after a July 2 memorandum was released stating that OIG is responsible for monitoring and oversight of the receipt, disbursement and use of CRF payments. Included in the memorandum were preliminary details on interim and quarterly reporting, reporting timeline and record retention requirements. In response to the memorandum, prime CRF recipients were directed to submit their first interim report on July 17, 2020.

Of key concern to counties regarding the new guidance released by OIG are additional reporting and record retention requirements for counties using CRF payments to cover payroll expenses for public safety, public health and human services employees who are "substantially dedicated" to mitigating the impacts of COVID-19. The new requirements may be more extensive than what was required under the U.S. Treasury’s guidance released on August 10, 2020, which focused on flexibility for local governments in order to ease administrative burdens. Late additions to CRF reporting requirements may prevent counties from receiving reimbursements for payroll expenses incurred during the pandemic, severely impacting budget forecasts.

NACo is working with U.S. Treasury officials to provide clarification to our members on these new requirements and their impact on counties’ CRF record keeping.

Additionally, NACo created a new document that compiles language related to payroll expenses for public health and public safety employees from  the U.S. Treasury's original CRF guidance (Aug. 10), U.S. Treasury OIG FAQ (Aug. 28) and U.S. Treasury OIG’s original reporting memorandum (July 2).