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Local Government Coronavirus Relief Funds

Governor Inslee announced that the state would award $300 million of the state’s CARES funding to local governments that did not receive direct distributions under the CARES Act.

Cities and counties are taking extraordinary measures to protect their residents during the COVID-19 pandemic while continuing to provide the basic services communities rely on. Commerce is moving these critical dollars so communities can cover critical expenses arising from the COVID-19 emergency, including isolation and quarantine sites, staffing and the procurement of medical supplies and equipment for health care, and planning for safe reopening and recovery.

The funds are available under section 601(a) of the Social Security Act, as added by section 5001 of the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”). 

Recipients and awards

Funds will be provided to cities and counties with populations under 500,000 that were ineligible to receive direct funding under the CARES Act. Cities and counties below 500,000-population will receive a per capita distribution of $30.00, with a minimum distribution of $250,000 per county and $25,000 for cities and town. The specific distribution allocations were determined by the Office of Financial Management. Click here for a complete list of local governments and their award amounts from the state’s Coronavirus Relief Funds (CRF).

Funding criteria

Expenditures must be used for actions taken to respond to the public health emergency.

Under the CARES Act, the Coronavirus Relief Funds may be used to reimburse local governments in response to the COVID-19 public health emergency during the period of March 1, 2020 thru Oct. 31, 2020*.

These may include expenditures incurred to allow the local government to respond directly to the emergency, such as by addressing medical or public health needs, as well as expenditures in response to second-order effects of the emergency, such as economic support to those suffering from employment or business interruptions due to COVID-19-related business closures.

Funds may NOT be used to fill shortfalls in government revenue to cover expenditures that would not otherwise qualify under the statute. Although a broad range of uses is allowed, revenue replacement is not a permissible use of Fund payments.

Payments may NOT be used to cover costs accounted for in the budget most recently approved as of March 27, 2020. The “most recently approved” budget refers to the enacted budget for the relevant fiscal period for the particular government. A cost is not considered to have been accounted for in a budget merely because it could be met using a budgetary stabilization fund, rainy day fund, or similar reserve account.

Eligible costs

Allowable expenditures include, but are not limited to:

    1. Medical expenses such as:
      • COVID-19-related expenses of public hospitals, clinics, and similar facilities.
      • Costs of providing COVID-19 testing, including serological testing.
      • Emergency medical response expenses, including emergency medical transportation, related to COVID-19.
      • Expenses for establishing and operating public telemedicine capabilities for COVID-19-related treatment.
    2. Public health expenses such as:
      • Expenses for communication and enforcement by State, territorial, local, and Tribal governments of public health orders related to COVID-19.
      • Expenses for acquisition and distribution of medical and protective supplies, including sanitizing products and personal protective equipment, for medical personnel, police officers, social workers, child protection services, and child welfare officers, direct service providers for older adults and individuals with disabilities in community settings, and other public health or safety workers in connection with the COVID-19 public health emergency.
      • Expenses for disinfection of public areas and other facilities, g., nursing homes, in response to the COVID-19 public health emergency.
      • Expenses for technical assistance to local authorities or other entities on mitigation of COVID-19-related threats to public health and safety.
      • Expenses for public safety measures undertaken in response to COVID-19.
      • Expenses for quarantining individuals.
    1. Payroll expenses for public safety, public health, health care, human services, and similar employees whose services are substantially dedicated to mitigating or responding to the COVID-19 public health emergency.
    2. Expenses of actions to facilitate compliance with COVID-19-related public health measures, such as:
      • Expenses for food delivery to residents, including, for example, senior citizens and other vulnerable populations, to enable compliance with COVID-19 public health precautions.
      • Expenses to facilitate distance learning, including technological improvements, in connection with school closings to enable compliance with COVID-19 precautions.
      • Expenses to improve telework capabilities for public employees to enable compliance with COVID-19 public health precautions.
      • Expenses of providing paid sick and paid family and medical leave to public employees to enable compliance with COVID-19 public health precautions.
      • COVID-19-related expenses of maintaining state prisons and county jails, including as relates to sanitation and improvement of social distancing measures, to enable compliance with COVID-19 public health precautions.
      • Expenses for care for homeless populations provided to mitigate COVID-19 effects and enable compliance with COVID-19 public health precautions.
    3. Expenses associated with the provision of economic support in connection with the COVID-19 public health emergency, such as:
      • Expenditures related to the provision of grants to small businesses to reimburse the costs of business interruption caused by required closures.
      • Expenditures related to a State, territorial, local, or Tribal government payroll support program.
      • Unemployment insurance costs 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.
    4. Any other COVID-19-related expenses reasonably necessary to the function of government that satisfy the Fund’s eligibility criteria.

Grantees are charged with determining whether or not an expense is eligible based on the US Treasury’s Guidance and as provided in the grantee’s contract scope of work with Commerce. 

To assist jurisdictions with this determination, Commerce has developed an eligibility cost test. This test gives each jurisdiction full authority to make the appropriate call for each circumstance.

TEST – If all responses for the particular incurred cost are “true” for all five statements below, then a jurisdiction can feel confident the cost is eligible:

  1. The expense is connected to the COVID-19 emergency.
  2. The expense is “necessary”.
  3. The expense is not filling a short fall in government revenues.
  4. The expense is not funded thru another budget line item, allotment or allocation, as of March 27, 2020.
  5. The expense wouldn’t exist without COVID-19 OR would be for a “substantially different” purpose.

It is the responsibility of each jurisdiction to define “necessary” or “substantially different”, giving the jurisdiction the authority and flexibility to make their own determination.

Additional consideration – The intent of these funds is to help jurisdictions cover the immediate impacts of the COVID-19 emergency. Both direct costs to the jurisdiction and costs to their communities. There are many possible eligible costs.

Many costs are clearly eligible and others are in more of a grey area. One could probably justify some of the “grey area” costs based on the test, but are they directly addressing the immediate impacts? Possibly not. In these situations it may be safer and more appropriate to utilize the funds in one of the many other eligible cost categories that more clearly meet the intent of the funds. Again, each jurisdiction has the full authority to make the final call based on their circumstances and justification.

Please feel free to utilize the Eligibility Cost Test Checklist to assist with determining eligible costs for your jurisdiction.

Contracting requirements

Prior to receiving funds, a contract will need to be executed between the local governmental entity and the state. Award letters with additional instructions to initiate the contracting process will be emailed to the cities and counties receiving an allocation in the next 1-2 weeks, through May 22nd.

All awardees will be required to set up an SWV number so funds may be sent electronically.  Please find detailed instructions here: Office of Financial Management. It may take up to three weeks after the submittal of this information for an electronic transfer account to be set up. 

Funds will be provided on a reimbursement basis only. The awardee shall submit invoice reimbursement requests through Commerce’s online invoicing process. Invoices must include a detailed breakdown of the costs incurred within each eligible budget category. All awardees will certify each invoices expenses are allowable per CRF Treasury Guidance.

*Please note: In order to ensure all awardees and their costs incurred in response to the COVID-19 emergency are paid out by the December 30, 2020 per the CRF Treasury Guidance, expenditures are only being accepted on costs incurred through October 31, 2020.  All final requests for reimbursement must be submitted no later than November 15, 2020.

Commerce is working to make the contracting process as quick and easy as possible. Please continue to check this web page for additional information. 

Reporting requirements

Each submitted invoice must include a detailed breakdown of the costs incurred within each eligible budget category and the total reportable eligible expenses in response to the COVID-19 public health emergency. Accompanying each invoice must be an executed A-19 certification and A-19 activity report:

  1. A completed A-19 Certification:
    • An individual authorized to execute on behalf of the local government must certify by signing this document under penalty of perjury that the items and costs listed herein and on the accompanying Commerce A-19 Voucher are eligible charges for necessary expenditures incurred due to the COVID-19 public health emergency that were not previously accounted for in the most recent approved budget as of March 27, 2020, and that the funds were used in accordance with section 601(a) of the Social Security Act, as added by section 5001 of the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”).
  2. A completed A-19 Activity Report (instructions included in document):
    • Must be submitted as an Excel spreadsheet, not a PDF, and include the total amount of all previous reimbursement requests and the total amount of funds being requested in the current reimbursement request for each applicable sub-category.
    • Include a detailed breakdown of the individual eligible expenditures reported by each sub-category.
    • Include a brief description of the use of the funds being requested for each applicable sub-category. Keep descriptions as concise as possible, but include adequate context to demonstrate how these funds addressed the COVID-19 emergency.

Incomplete or improperly prepared submissions may result in payment delays. No receipts or proof of payment for costs incurred will be required to be submitted to Commerce. Jurisdictions are still required to maintain sufficient accounting records in accordance with state and federal laws; and are responsible for maintaining clear and accurate program records, and making them accessible to Commerce and the State Auditor. Monitoring visits may be scheduled.

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