U.S. Treasury releases updated Coronavirus Relief Fund guidance, includes new information on reporting requirements and appeals process

Key Takeaways

On November 25, the U.S. Department of Treasury’s Office of Inspector General (OIG) released an updated FAQ document that provides clarification on the reporting requirements and new information on the audit and appeals process for Coronavirus Relief Fund (CRF) prime recipients. The CRF, which was established under the Coronavirus Aid, Relief and Economic Security (CARES) Act, 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 updated guidance answered many questions sent from NACo to U.S. Treasury officials.  The deadline for CRF recipients to spend their allocations is December 30, 2020.

The updated document has been modified to clarify some key provisions that apply to counties. An important addition is a definition of the “various expenditure categories” for prime recipients to accurately report their expenditures in the GrantSolutions portal. Additional updates include new information on how to report payroll costs, non-federal fund matching requirement established by the Stafford Act, loans and interest.  Other key provisions outlined in this document is a section on the recoupment of CRF dollars.

Treasury OIG’s updated guidance also includes new information on the CRF appeals process if it determines a CRF recipient did not spend dollars in compliance with 601(d) of the Social Security Act. As outlined in the guidance, CRF recipients will have the opportunity to appeal a determination of noncompliance by the Treasury OIG, both before and after the covered period ends on December 30, 2020.

With the December 30 deadline looming and a daily increase in COVID cases that continues to surpass the highest levels that we saw in the spring, counties need to have access to CRF funds beyond this expiration date. NACo research estimates that counties are projecting a $202 billion budgetary deficit through Fiscal Year 2021. This figure includes $114 billion in lost revenue, $30 billion in additional COVID-19 expenditures and an additional $58 billion in state funding cuts. Beyond a CRF extension, all counties need additional flexible and direct funding in order to continue to respond to COVID in our communities.