April 23, 2020
Further Updated May 29, 2020: CARES Act Update: Eligible Expenditures for Coronavirus Relief Funds
CARES Act and the Coronavirus Relief Fund Update: New Guidance on eligible expenditures for CRF amounts.
The CARES Act created the Coronavirus Relief Fund to provide $150 billion for payments to states, tribal governments, and units of local government for fiscal year 2020. The payments have already been made to states. Large local governments with populations of over 500,000 also received direct distributions.
The following provides an overview of eligible expenditures for CRF amounts. Since our initial alert describing the guidance released by the U.S Treasury Department (“Treasury”), Treasury has updated its FAQ guidance. This article has been updated to reflect the updated guidance, including the most recent FAQ guidance issued on May 28, 2020. The guidance now includes a specific direction to states to share 45 percent of the amount received with smaller local governmental entities, confirms that federal single audit, internal controls and sub-recipient monitoring and management requirements apply, and include a few additional illustrative examples of eligible uses.