Over the past few weeks, the US Treasury Department and the Minnesota Management & Budget (MMB) have issued updated Coronavirus Relief Fund guidance. The US Treasury Office of Inspector General (OIG) Frequently Asked Questions Related to Reporting and Recordkeeping Record Keeping was updated on 9/21/2020 and the MMB FAQs for Local Governments was updated on 9/25/2020. Below are a few key items from the updated guidance:

US Treasury Update: Public Safety Payroll Documentation Requirements

  • On August 28th, the US Treasury OIG clarified what documentation was needed to prove public safety payroll costs were eligible for CRF reimbursement. On September 21st, they relaxed much of those requirements.

  • Under the most recent guidance, the US Treasury OIG clarified governments do not need to demonstrate that public safety employees were substantially dedicated to the emergency or that the public safety employee’s function was substantially different then what was originally budgeted. The government must still have supporting documentation for the amount of public safety payroll applied to the CRF grant.

  • See Treasury OIG – CRF FAQs, Questions #63, 70-72

MMB Update: Fund Transfers to Other Local Governments

  • On September 25th, MMB updated their FAQs for Local Governments document to include a Transfers Between Local Governments section, questions 30 – 32. The new questions offer clarification on when transfers to other local governments are eligible for CRF reimbursement.

  • Question 31: Can local governments transfer funds to other local governments with whom they share COVID-19 related costs for shared services or to other local governments within their boundaries?

Yes, provided the transfer qualifies as a necessary expenditure incurred due to COVID-19 and meets the other criteria of the CARES Act. For example, the City of Minneapolis may transfer funds to Minneapolis Public Schools. In addition, to facilitate fair share of costs, Minnesota local governments that traditionally share services such as fire, ambulance, police, or public health functions via a joint powers agreement or other arrangement may transfer funds for this purpose to other local governments outside their boundaries for needs that meet all CARES Act requirements.

Like with all things Covid-19 related, the guidance can change quickly. We will provide updated guidance as significant changes occur. Please contact us if you have any questions.

Here are links to access the most up to date guidance:

US Treasury Guidance:

https://home.treasury.gov/policy-issues/cares/state-and-local-governments
https://www.treasury.gov/about/organizational-structure/ig/Pages/CARES-Act-Reporting-and-Record-Keeping-Information.aspx

Minnesota Management & Budget

https://mn.gov/mmb/covid-19-response-accountability-office/local-governments/

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