Local Government Frequently Asked Questions

FAQ Update

 

General


What is the Local Government Coronavirus Relief Fund Program?


Answer

The Local Government Coronavirus Relief Fund (“CRF”) Program was established by Governor Lee and the FSAG committee to provide a full reimbursement of any COVID-19-related expenses incurred by a local government that was not included in a direct distribution by US Treasury. $115 million in federal Coronavirus Relief Fund payments have been reserved for this program. These funds are limited by the terms of the CARES Act and regulation by the US Treasury and may only be used to cover expenses that:

  • are necessary expenditures incurred due to the public health emergency with respect to the Coronavirus Disease 2019 (COVID–19);
  • were not accounted for in the budget most recently approved as of March 27, 2020 (the date of enactment of the CARES Act) for the State or government; and
  • were incurred during the period that begins on March 1, 2020, and ends on December 30, 2020.

Updated August 11, 2020


Who receives an allocation in this program?


Answer

The $115 million allocation is reserved for all local governments in the state with populations below 500,000, excluding portions of municipalities within local governments that received direct allocations from the US Treasury (City of Memphis, Shelby County, and Nashville-Davidson Metropolitan Government). Local governments will initially be eligible to request a 30% advance of their allocated amount and the remaining 70% balance may be accessed on a reimbursement basis after the advance has been substantiated by required documentation.
Updated August 11, 2020


How do I receive access to funds allocated to my jurisdiction?


Answer

CRF will be advanced and reimbursed through the Tennessee CARES Act Management System (TN CAMS) online portal. Local governments will be required to upload all necessary supporting documentation for each claimed expense in TN CAMS. The designated user for each jurisdiction will receive an email enabling them to set up an account and begin the process of requesting funds. If you are not a designated user, you will need to coordinate with the city or county in order to receive funding related to the CRF. Recipients must register for the system and attend the required Townhall training by August 15, 2020 or forfeit funds.


By what date must funds be spent?


Answer

Local governments must provide support for the initial 30% advance, if taken, by September 30 or the remaining 70% balance may be subject to de-obligation and reallocation to other local governments based on need. The deadline for requesting the 30% advance, if taken, is September 1. Additionally, all reimbursement requests for the remaining 70% of the allocation must be submitted by November 1.


What are the applicable deadlines for this program that jurisdictions should be aware of?


Answer

  • September 1, 2020: Deadline for a jurisdiction to request an advance, if an advance is desired.
  • September 30, 2020: Deadline for 30% advance to be spent in full, and for submission of all supporting documentation to be submitted to TN-CAMS, or funds may be subject to de-obligation and reallocation.
  • November 1, 2020: Deadline to submit all Requests for Funding (“RFFs”).

Updated September 14, 2020


Will costs incurred after the November 1 deadline be eligible for reimbursement?


Answer

Treasury has stated that all costs must be incurred between March 1, 2020 and December 30, 2020 to be eligible for coverage under CRF. Accordingly, an applicant may submit a RFF for expenses incurred after the November 1 program submission deadline so long as the applicant submits proper documentation for these expenses by November 1 and substantiates those expenses once they are paid in December. The funds will be approved by the November deadline as obligated funds but they will not be disbursed until all December expenses have been substantiated.

For example, if the applicant prepays December expenses by November 1 and has proof of purchase of those costs by November 1, then they can submit them for reimbursement through this program. Additionally, the applicant may submit work orders and invoices for the expenses to be paid in December, projected payroll costs for December, etc., however the funding will not be released until the cost/expense is substantiated in CAMS with the proper documentation.
Updated August 11, 2020


Will jurisdictions be required to take the 30% advance?


Answer

No, recipients are not required to seek advanced funds. They may, instead, request funds immediately and solely on a reimbursement basis if they so choose. Supporting documentation must be provided to substantiate all funds requested on a reimbursement basis. Additionally, all reimbursement requests must be submitted by November 1. Extensions will not be granted.


Are funds that are reimbursable under Stafford Act Public Assistance also under CRF?


Answer

While several expenses will be considered reimbursable expenses under both programs, duplication of benefits is strictly prohibited. All expenses submitted will be subject to review by Tennessee Emergency Management Agency for eligibility or prior claims for Stafford Act Public Assistance. When submitting your RFA or RFF please be mindful of the following procedure for TEMA/CRF review:

  • If the expense you are seeking payment for is clearly reimbursable under TEMA/Stafford Act only then the applicant should apply with TEMA first.
  • If the applicant is unsure as to whether the expense falls under TEMA or CRF then the applicant should apply through the CRF program in TN CAMS.
  • If the expense is clearly both TEMA and CRF eligible (meaning either program could fund the expense) then the applicant should apply through the CRF program in TN CAMS first.
  • The State of Tennessee will cover all local cost-share for Stafford Act claims, which is otherwise ½ of the non-federal cost-share or 12.5% of the total claim. This will revert back to 75% Federal/12.5% State/12.5% Local after December 30th.

Updated August 11, 2020

 


Who funds the 12.5% portion of the TEMA cost and what pool of funds is that 12.5% being funded with?


Answer

The State of Tennessee will cover all local cost-share for Stafford Act claims, which is otherwise ½ of the non-federal cost-share or 12.5% of the total claim. This will revert back to 75% Federal/12.5% State/12.5% Local after December 30, 2020. The 12.5% will be funded by CRF dollars provided to the State of Tennessee by the federal government. These funds will not be taken out of the portion of CRF dollars allotted to the Local Government Program.
  Updated September 14, 2020


Are schools eligible to apply under this local government CRF program?


Answer

No. Local education agencies may work directly with the Department of Education for any federal funds made available for schools. Local governments may support local education agencies by using their allotted funds to cover eligible expenses for schools such as providing PPE, IT equipment, etc., but the local government may not create a subrecipient by giving its funds through direct payments to the school. For instance, a local government may use its CRF allocation for expenses associated with the local cost share for district technology grants. The creation of subrecipients is strictly prohibited under this program. Local Education Agencies can learn more about funds and support available from the Tennessee Department of Education at https://www.tn.gov/education/health-and-safety/update-on-coronavirus/reopening-guidance.html
Updated August 11, 2020


May a local government issue stipends to teachers in the form of direct payments and then seek reimbursement for those payments under this program?


Answer

No. The direct payment of CRF dollars from a jurisdiction to a teacher would create a subrecipient which is strictly prohibited under this program. The jurisdiction, however, may purchase goods needed by teachers to facilitate learning during this pandemic and then seek reimbursement for the costs of those goods through this program.
Updated September 14, 2020


May a local government issue funds from this program directly to a non-profit organization that supports its community?


Answer

The creation of subrecipients is strictly prohibited under this program. Accordingly, a local government may not directly grant funds to a non-profit, thus creating a subrecipient. A local government may, however, use portions of its allocated funds to be reimbursed for eligible expenses associated with items purchased by the local government and given to the non-profit. Non-profits may seek CRF assistance directly from the Tennessee Community CARES program administered by the Department of Human Services. More information is available at https://tncaresact.tn.gov/dhs.
Updated August 11, 2020


Will jurisdictions be eligible to receive additional funds once all allocated funds have been spent and substantiated?


Answer

In order to ensure needs are addressed, local governments will be permitted to record claims over and above their allocation amount. These claims will only be processed should additional funds be made available. Local governments are encouraged to submit all eligible expenses to ensure that these claims are processed in a timely manner. No claim submitted after November 1 will be reimbursed.


Will jurisdictions be required to comply with general procurement and bidding procedures for expenses they are seeking reimbursement for under this CRF program?


Answer

Local governments will need to follow their applicable local purchasing laws and policies. If a jurisdiction intends to suspend any normal purchasing policies or procedures it should seek adoption of emergency policies by its local governing body that allows for such avoidance.
Updated September 14, 2020


Will jurisdictions be allowed to disburse funds received to other smaller units of local governments or other entities?


Answer

This program strictly prohibits the creation of subrecipients. All allocations by jurisdiction may be found on the program website: tncaresact.tn.gov. These allocations were made by the State of Tennessee consistent with prior Legislative allocations using Federal Census Bureau data that represented the population as of July 1, 2018. These jurisdictions and allocations are fixed.
Updated August 11, 2020

Eligible Expenses

Medical Expenses

Are the funds available for antibody testing of all employees?


Answer

Yes, this would be an eligible expense if the purpose of the testing is to test for COVID-19 antibodies. Treasury guidance allows for CRF to be used for medical expenses associated with COVID-19, including testing for current infection or serological testing for antibodies. This may include testing of employees to identify or mitigate COVID-19 spread or as part of determining reopening procedures.

Public Health


Can a jurisdiction use Coronavirus Relief Fund for the additional cleaning and cleaning products to fight the virus at all of its facilities?


Answer

Yes, this would be an eligible cost as long as it is not a part of budgeted cleaning expenses (it would need to be above and beyond, they would need to provide documentation supporting this and it must be for COVID-19).


Can the funds be used for the purchase of hand sanitizer for all of a jurisdiction’s facilities?


Answer

Yes, as long as it’s for uses related to preventing the spread of COVID-19.

Payroll

Can the funds be used to cover payroll expenses for employees?

Answer

Yes, the funds may be used to cover payroll expenses, but only for employees who are substantially dedicated to mitigating or responding to COVID-19. These employees who are deemed substantially dedicated to COVID-19 can have their payroll from March 1-December 30, 2020 reimbursed in full. If the employee was only partially dedicated to COVID-19 then you would only be able to seek a portion of their payroll to be reimbursed and documentation would need to be supplied regarding the percentage of time and hours spent working on COVID-19 related activities.
Updated August 11, 2020


How does a government determine whether payroll expenses for a given employee satisfy the “substantially dedicated” condition?


Answer

Per the OIG guidance issued on September 2, 2020, “the relevant unit of government should maintain documentation of the ‘substantially dedicated’ conclusion with respect to its employees.” It is no longer assumed, per OIG, that public health and public safety employees are substantially dedicated to mitigating or responding to the COVID-19 public health emergency. Accordingly, when seeking reimbursement for payroll for any category of employee the unit of government must also submit documentation demonstrating that the employee was substantially dedicated to mitigating or responding to COVID-19. This documentation may include a detailed narrative, activity log, payroll hourly breakdown, or any other documentation that would allow a reasonable conclusion that the employee was substantially dedicated to responding or mitigating COVID-19.

For a non-public health and public safety employee, a jurisdiction should likewise maintain adequate documentation and timekeeping records to demonstrate that the majority of the employee’s time was spent responding to the public health emergency.

In the event an employee spent less than a substantial amount of time performing COVID-19 related duties then the jurisdiction may only be reimbursed for the time that employee was dedicated to COVID-19. Per OIG’s September 2, 2020, guidance “[t]his means, for example, that a government could cover payroll expenses allocated on an hourly basis to employees' time dedicated to mitigating or responding to the COVID-19 public health emergency.” For example, if the employee spent five hours each week performing COVID-19 related duties then only those five hours of the employee’s payroll are reimbursable.

Under all three categories of payroll reimbursement (public health & safety who are substantially dedicated; non-public health and safety who are substantially dedicated; and non-public health and safety who spend less than a substantial amount of time related to COVID-19) documentation of the employees’ hours worked and a description of those as hours and duties as they relate to mitigating or responding to COVID-19 is required to be eligible for reimbursement.
Updated September 14, 2020


What are some examples of types of covered employees?


Answer

Treasury’s Guidance provides examples of broad classes of employees whose payroll expenses would be eligible CRF expenses. These classes of employees include:

  • 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. Per OIG’s September 2, 2020, guidance the following personnel are considered public health or safety under the CRF:
    • “Treasury is supplementing its guidance to clarify that public safety employees would include police officers (including state police officers), sheriffs and sheriff deputies, firefighters, emergency medical responders, correctional and detention officers, and those who directly support such employees such as dispatchers and supervisory personnel.”
    • “Public health employees would include employees involved in providing medical and other health services to patients and supervisory personnel, including medical staff assigned to schools, prisons, and other such institutions, and other support services essential for patient care (e.g. laboratory technicians) as well as employees of public health departments directly engaged in matters related to public health and related supervisory personnel.”
  • Payroll and benefit costs associated with public employees who could have been furloughed or otherwise laid off but who were instead repurposed to perform previously unbudgeted functions substantially dedicated to mitigating or responding to the COVID-19 public health emergency.
  • Payroll and benefit costs of educational support staff or faculty responsible for developing online learning capabilities necessary to continue educational instruction in response to COVID-19 related school closures. (Note, schools themselves may not apply through this program, but instead may seek guidance on federal funds available through the Department of Education).

Updated September 14, 2020


Do eligible straight-time payroll costs only include medical, law enforcement and EMS type payroll? What about other departments whose normal activities have now been dedicated to mitigation roles such as custodial staff, Emergency Management Office/team, and jailers. Would these types of roles also be eligible costs?


Answer

Possibly. CRF funding may be used for non-public health and public safety employee if there is adequate documentation available to demonstrate they were working on COVID-19 related tasks and those tasks took up the majority of each employee’s time.
Updated August 11, 2020


Is overtime eligible under this funding?


Answer

Possibly. If the employee is substantially dedicated to mitigating or responding to COVID-19, then the overtime is deemed an eligible expense under this program. If the employee is not substantially dedicated to mitigating or responding to COVID-19, then only the overtime related to that employee’s COVID-19 duties is eligible under this program.
Updated September 14, 2020


May payments from this program be used to cover across the board hazard pay for employees working during the current state of emergency?


Answer

No. Hazard pay may be covered under this program if it is provided for performing hazardous duty or work involving physical hardship that in each case is related to COVID-19. If an employee is substantially dedicated to mitigating or responding to COVID-19 their hazard pay must still be paid only for the duties related to COVID-19. For example, a jurisdiction may use payments from this program to cover hazard pay for a police officer who came in close contact with members of the public to enforce public health or public safety orders. Across the board hazard pay, however, for all members of a police department regardless of their duties would not be covered under this program.

Hazard pay and overtime pay for employees who are not substantially dedicated to mitigating or responding to COVID-19 may only be reimbursed under this program for hazard pay and overtime for COVID-19 related duties.
Updated September 14, 2020


May payments from this program be used to cover employee bonuses?


Answer

No. Treasury strictly prohibits payments for workforce bonuses using CRF dollars.
Updated August 11, 2020


Do payroll expenses include fringe?


Answer

Yes. Benefits are eligible for reimbursement under this program for employees who are substantially dedicated to mitigating or responding to COVID-19.
Updated September 14, 2020


When government department employees were asked to stagger the days worked due to social distancing requirements are the payroll expenses for those employees covered under this program?


Answer

Possibly. The use of payments from this program to cover payroll or benefits expenses of public employees are limited to those employees whose work duties are substantially dedicated to mitigating or responding to the COVID-19 public health emergency. Accordingly, if employees are paid leave time in order to comply with social distancing requirements then they would potentially be eligible for reimbursement for that paid leave if the leave is due to COVID-19 and over and above the leave typically budgeted for that employee. If the employee is paid to work remotely due to social distancing requirements than that would be an eligible payroll expense that was necessary to mitigate or respond to COVID-19. The key distinction is if the employee was working remotely then it falls under payroll, but if they were paid not to work that falls under administrative leave.
Updated September 14, 2020


The CARES Act Relief Fund Program mentions payroll related to the COVID-19 emergency as an eligible expense. Does that mean straight time and overtime?


Answer

Funds may be used to cover payroll or benefits expenses of public employees whose work duties are substantially dedicated to mitigating or responding to the COVID-19 public health emergency, including public safety, public heath, health care, human services, and similar employees. Payroll expenses would not include any other types of bonuses, even if for employees in the aforementioned categories.
Updated September 14, 2020


Would this funding apply to general employees who are not public safety or healthcare that are responsible for managing reimbursement of COVID-19 funds, managing budgets related to COVID-19 expenditures, purchasing COVID-19 protective equipment; staff who have been cross-trained to operate COVID-19 hotlines or information channels; or public information officers dedicated to keeping the community updated with services offered to help treat, mitigate or respond to COVID-19 public health measures?


Answer

Yes, this would be an eligible expense so long as a detailed narrative and documentation are supplied demonstrating that the employee was substantially dedicated to mitigating or responding to COVID-19. The Fund may support a “broad range of uses” including payroll expenses for several classes of employees whose services are “substantially dedicated to mitigating or responding to the COVID-19 public health emergency.”
Updated September 14, 2020


If a jurisdiction is over budget on part-time EMS workers who staff an ambulance, could these funds be used to cover the extra cost above the budgeted amount?


Answer

Yes, the Treasury guidance provides that unbudgeted payroll expenses for health care employees who are substantially dedicated to mitigating or responding to the COVID-19 public health emergency are qualifying costs. If a jurisdiction has documentation that clearly shows the costs that are above and beyond regular, budgeted expenses (e.g. a contract amendment or something else that documents the additional costs), the additional costs would be eligible.


Can the funds be used to pay employee cost of Emergency Management Coordinator for time spent on COVID-19 activities?


Answer

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 are eligible. These expenses would need to be documented carefully, including but not limited to, a detailed description of the employees’ specific duties related to mitigating or responding to COVID-19, and the time dedicated to COVID-19 mitigation or response by this category of employees.
Updated August 11, 2020


Can a jurisdiction utilize these funds for contracting with a person to provide childcare, so employees do not miss work when their children lost childcare?


Answer

This would be an eligible expense IF it were for employees (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.


Are personnel costs related to COVID-19 sick time for city employees eligible costs?


Answer

Expenses of providing paid sick and paid family medical leave to public employee to enable compliance with COVID-19 public health precautions are eligible costs.
Updated August 11, 2020


May fund payments be used to cover increased administrative leave costs of public employees who could not telework in the event of a stay at home order or a case of COVID-19 in the workplace?


Answer

Treasury requires that payments be used only to cover costs that were not accounted for in the budget most recently approved as of March 27, 2020. As stated in the Guidance, a cost meets this requirement if either (a) the cost cannot lawfully be funded using a line item, allotment, or allocation within that budget or (b) the cost is for a substantially different use from any expected use of funds in such a line item, allotment, or allocation. If the cost of an employee was allocated to administrative leave to a greater extent than was expected, the cost of such administrative leave may be covered using payments from the Fund.

Accordingly, the administrative leave costs may be covered under this program if: (1) the leave is over and above normal budgeted leave that would be provided to employees, and (2) the leave is necessary to ensure safety and reduce the spread of COVID-19 infections.
Updated August 11, 2020

Public Health Compliance


Can the funds be used to pay for government employees to barricade playgrounds?


Answer

Yes, if they closed playgrounds as a result of orders on social distancing due to the COVID-19 pandemic.


Can the funds be used to pay for marketing materials to communicate to and educate the public on CDC guidelines related to COVID-19?


Answer

Yes. So long as these costs were necessary due to COVID-19, not budgeted for as of March 27, 2020, and are incurred costs between March 1, 2020 and December 30, 2020.
Updated August 11, 2020


If a jurisdiction incurs expenses for additional cleaning services and the purchase of additional cleaning and disinfecting supplies, are these eligible costs under this program?


Answer

Yes, this would be an eligible cost as long as it is not a part of budgeted cleaning expenses as of the March 27, 2020 budget (i.e., it would need to be above and beyond the original budgeted amount if cleaning supplies were previously budgeted for, and documentation supporting this increased need due to COVID-19 would be required).
Updated August 11, 2020


In an instance where COVID-19 created a need for an EMC to have a dedicated vehicle for the purpose of emergency management; if the vehicle is to be used to conduct COVID-19 surveillance, respond to medical calls, transport equipment, comply with the Governor's executive orders, and any other COVID related issues that continue to arise would the purchase of that vehicle be an eligible expense under this program?


Answer

Yes, so long as the applicant can show that there was an unbudgeted need for the vehicle due to COVID-19 and the purchase occurred between March 1, 2020 and December 30, 2020.
Updated August 11, 2020


Can funds be used to build a public health building in order to meet the increased demand of caring for and treating patients diagnosed with COVID-19?


Answer

It would be difficult to use CRF funds to pay for the construction of a public health building. While this would likely be an eligible expense, all funds must be incurred by December 30, 2020. According to Treasury, this requires that the costs be incurred and all goods or services be rendered by December 30, 2020. In this situation that would mean that only the portion of the completed construction may be eligible for coverage under this program.
Updated August 11, 2020


Would the purchase of new PC’s with integrated cameras to allow staff to attend remote meetings via Zoom, Google Meet, Microsoft Teams, etc. be an eligible cost?


Answer

U.S. Treasury guidance expressly allows for “Expenses to improve telework capabilities for public employees to enable compliance with COVID-19 public health precautions.”


Are costs for IT, phones, computers, and other equipment eligible costs under this program? What about credit card fees paid for by a water department in order to process bill payments remotely?


Answer

Computer and IT costs necessary to facilitate telework for public employees are eligible costs under this program so long as they were not originally budgeted for as of March 27, 2020, are necessary due to COVID, and are purchased by December 30, 2020. This may also include credit card fees paid for by a water or utility company so that bills could be processed remotely so long as the department paid those fees directly to the credit card company as a result of COVID-19 and the fees were paid between March 1, 2020 and December 30, 2020.
Updated August 11, 2020


Can a jurisdiction purchase additional waste management equipment necessary to handle the increased amount of waste that has resulted during the COVID-19 pandemic?


Answer

Yes. The purchase of additional waste management vehicles and/or other equipment necessary to manage the increased amount of waste present in the jurisdiction in light of COVID-19 is an eligible expense. Please provide a detailed narrative as to the expense itself, why it is necessary due to COVID-19, that the expenses were not accounted for in your budget as of March 27, 2020, and that all equipment will be purchased and in hand rendering a good or service by December 30, 2020.
Updated September 14, 2020


Can a jurisdiction seek reimbursement for expenses related to work performed by an outside contractor that would typically be performed by inmates but is now prohibited due to COVID-19 restrictions?


Answer

Yes. A jurisdiction may seek reimbursement for costs related to work traditionally performed by inmates that is no longer permissible due to COVID-19 restrictions put in place by the Department of Corrections. For example, a jurisdiction may hire a mowing service to maintain the greenspace near highways and roadways that would typically be maintained by inmates on work duty. The jurisdiction, however, may only be reimbursed for the period between March 1-December 30, 2020, when the inmates were ordered not to work on these duties. For example, if the inmates were not told to stop such work until April 1, 2020, then only the expenses related to hiring an outside contractor from April 1-December 30, 2020 would be reimbursable.
Updated September 14, 2020


Can a jurisdiction use these funds for expenses related to online bill payment or drive thru bill pay in order to maintain social distancing during the COVID-19 pandemic?


Answer

Yes, as long as the jurisdiction can demonstrate that the infrastructure or equipment purchased to facilitate remote or drive thru bill pay was necessary due to COVID-19, not within the budget as of March 27, 2020, and all equipment or infrastructure can be purchased and in use by December 30, 2020.
Updated September 14, 2020


Can CRF dollars be used for COVID-19 civic communication services and surveys to gather information from residents, businesses and school districts to inform and guide a jurisdiction’s COVID-19 recovery planning and actions?


Answer

Yes, as long as the jurisdiction can demonstrate in its narrative and documentation that these services were necessary due to COVID-19, not within the budget as of March 27, 2020, and the services were in place and rendering a good or service to the community that is related to COVID-19 by December 30, 2020.
Updated September 14, 2020


Can a fire department use these funds to purchase equipment necessary to meet the increased call demand due to COVID-19?


Answer

Yes, as long as the department can demonstrate in its detailed narrative and documentation that these purchases were necessary due to COVID-19, not within the budget as of March 27, 2020, and that all goods will be delivered by December 30, 2020.
Updated September 14, 2020

Economic Support


Can funds from the CRF be used to supplement local governments’ lost property tax revenue?


Answer

No, Treasury guidance states that CRF Funds may not be used for purposes of replacing lost revenue.


Can funds from this program be used to supplement lost revenue due to cancelled events or revenue generating programs that were cancelled due to COVID-19?


Answer

No. Lost revenue is not an eligible expense under this program. An applicant may be able to recoup lost expenses related to the event, for example a non-refundable deposit for a venue, only if that expense was not budgeted for as of March 27, 2020.
Updated August 11, 2020


If a jurisdiction’s EMS service incurred a large drop in ambulance services from March-July 2020, can it seek reimbursement under this program for this revenue shortfall?


Answer

No. Lost revenue or revenue shortfalls are not eligible under this program.
Updated September 14, 2020

Allocation and Nature of Funds


Are Fund payments to State and local governments considered grants?


Answer

No. Fund payments made by Treasury to State and local governments are not considered to be grants but are “other financial assistance” under 2 C.F.R. § 200.40.


Is there a Catalog of Federal Domestic Assistance (CFDA) number assigned to the Fund?


Answer

Yes. The CFDA number assigned to the Fund is 21.019, pending completion of registration.


Are Fund payments considered federal financial assistance for purposes of the Single Audit Act?


Answer

Yes, Fund payments are considered to be federal financial assistance subject to the Single Audit Act (31 U.S.C. §§ 7501-7507) and the related provisions of the Uniform Guidance, 2 C.F.R. § 200.303 regarding internal controls, §§ 200.330 through 200.332 regarding subrecipient monitoring and management, and subpart F regarding audit requirements.