National Leadership on the CRF: NACo Shapes the U.S. Department of Treasury Implementation of the Coronavirus Relief Fund
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Throughout the course of the coronavirus pandemic, counties have been on the front lines, providing vital health services, distributing vaccines, mitigating economic challenges and much more. Counties across the country are investing their Coronavirus Relief Fund (CRF) payments and other federal funds authorized under the CARES Act, and NACo has been there every step of the way, engaging with the U.S. Department of the Treasury, providing feedback and securing key changes to CRF spending and reporting guidelines.
Click below to explore a timeline of Treasury CRF guidelines and NACo's engagement efforts.
March 2020Prior to U.S. Treasury establishing guidance for the Coronavirus Relief Fund (CRF), NACo engaged with Treasury officials to educate our federal partners of the various expenses that should be eligible under the CARES Act, and our concerns over the CRF formula. |
NACo sent a letter to Treasury officials ahead of first round of official CRF guidance was released. To view the letter, click here. |
April 28, 2020NACo hosted a national membership call with Counsel to the Treasury Secretary, Dan Kowalski, who spearheaded developing CRF guidance. During the call, Kowalski participated in a Q&A with our membership to provide clarification on eligible expenses such as FEMA matching requirement, small businesses, child care and payroll expenses for public health/public safety employees. This was Kowalski’s first speaking engagement with a national organization after Treasury’s first iteration of CRF guidance was released. |
To access Treasury's resources and guidance on the Coronavirus Relief Fund, click more. |
June 26, 2020NACo hosted a national webinar to highlight county CRF plans and hear from Counsel to the Treasury Secretary, Dan Kowalski. Kowalski discussed items related to emergency paid leave, state mandating additional CRF requirements, CRF recoupment process and incurred versus obligated costs. |
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June 30, 2020Treasury released new CRF guidance that provided clarification on the definition of “incurred costs.” |
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August 10, 2020Treasury policy releases updated guidance on payroll expenses, which states that CRF recipients can use funds to cover entire payroll costs. Additionally, the guidance also includes clarification that counties can use CRF dollars towards the FEMA non-federal cost share. NACo engaged regularly with Treasury to ensure that CRF dollars could be used towards the FEMA cost share. |
To access Treasury policy's updated guidance, click here. Clarifications on eligible uses for payroll costs can be found on pages 5-6 (Questions 21 and 30). Guidance on FEMA cost share use can be found on page 8 (Question 42). |
August 14, 2020NACo hosted a national membership webinar with officials from Treasury’s Office of Inspector General (OIG) after the agency released its first round on CRF reporting and record retention requirements. OIG discussed the new requirements and how counties can ensure they are spending dollars in compliance to avoid recoupment. |
To view a recording of the webinar, click here. |
August 28, 2020OIG released new CRF guidance on reporting and record retention requirements for payroll expenses for public heath and public safety employees. This guidance conflicted with previous guidance released by Treasury’s policy team, and ultimately would lead to counties not receiving reimbursements for payroll expenses they had already covered with CRF dollars. In response to the new guidance, NACo created a brief that highlights conflicting 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). |
To view NACo's brief on Treasury policy and OIG guidance, click here. |
September 1, 2020NACo, along with our Big 7 partners, sent a letter to Treasury OIG expressing our concerns over the conflicting guidance and need to rewrite to better align with Treasury policy guidance concerning payroll expenses. |
To view the letter, click here. |
September 2, 2020Treasury policy released updated guidance that provided clarification on use of funds to cover payroll and benefits of public employees, and clarification on the various employment positions under the public health and public safety sector. NACo actively engaged with both Treasury policy and Treasury OIG to ensure that both definitions included a broad range of individuals employed by county governments to ensure reimbursement for payroll expenses. Beyond the definitions, the guidance said that recipients could use CRF dollars to cover 100 percent of payroll expenses, which NACo also worked to have included. |
To access Treasury policy's updated guidance, click here. Clarifications on CRF uses for payroll and benefits can be found on page 9 (Question 47) and guidance on FEMA cost share on page 10 (Question 49). |
September 21, 2020Treasury OIG released updated CRF reporting and record retention requirements that walk back previous mandates and discrepancies. NACo played an integral role in pushing Treasury OIG to align their guidance with that of the policy team’s released on August 10 to ensure counties receive reimbursements for payroll expenses. |
To view Treasury OIG's updated FAQ document, click here. To learn more on how these OIG updates relate to counties, click here. |
October 9, 2020NACo hosted a national membership call with officials from Treasury OIG to explain updated guidance on payroll expenses and upcoming deadlines for CRF recipients to submit reporting costs. OIG also discussed that new guidance will be released regarding the recoupment and appeals process. |
To listen to a recording of the call, click here. NACo has also published a summary of the call, which can be found here. |
October 19, 2020Treasury policy released updated guidance on the CRF that provided new clarification on items including using CRF dollars for public university student refunds, purchasing of equipment, real property acquisition and small business support. |
To access Treasury policy's updated CRF guidance, click here. The new questions can be found on pages 12-13 (Questions 57-59). |
November 25, 2020Treasury OIG released updated guidance on CRF reporting and record retention requirements that provided clarification on the recoupment and appeals process for CRF prime recipients. Prior to OIG’s updated guidance, NACo urged OIG to release additional information on both the appeals and recoupment process of county CRF recipients. |
To view Treasury OIG's updated guidance, click here. To learn more about NACo's efforts to advocate for additional guidance, click here. |
December 10, 2020NACo hosted officials from Treasury OIG during the 2020 LUCC/RAC Virtual Fall Symposium. OIG presented on the new appeals process as well as new data on how prime recipients are investing CRF dollars. |
To view Treasury OIG's update to NACo's membership on the CRF, click here. Treasury OIG officials speak from 45:50 - 1:07:36. |
Ongoing effortsOn a weekly basis, NACo engages with officials from both Treasury policy and Treasury OIG – sending questions from our members for representatives to answer, asking when future guidance will be released and relaying concerns from our members about current CRF guidance. |
To learn more about NACo's ongoing efforts and how counties are allocating CRF dollars, click here. |