Dear USET/USET SPF Family,
The U.S. Department of the Treasury (Treasury) has announced revised guidance
for the Coronavirus Relief Fund (CRF) issued by the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). Under the CARES Act, CRF funds could be used for costs incurred by December 31, 2021. Previously, Treasury determined that, for a cost associated with the acquisition of a good or service, or the acquisition of or improvement to real estate to be considered to have been incurred within the covered period, performance, or delivery must have occurred during the covered period.
Treasury is now revising its guidance to provide that a cost associated with a necessary expenditure incurred due to the COVID-19 public health emergency should be considered to have been incurred by December 31, 2021. However, the Tribal recipient must have incurred an obligation with respect to such a cost by December 31, 2021. Treasury has now defined this obligation with the Department of Labor’s Uniform Guidance definition under 2 C.F.R. 200.1. To be clear, CRF dollars must now be obligated, rather than expended, by December 31, 2021 to be compliant with the revised guidance issued by Treasury. Our member USET/USET SPF Tribal Nations should review this new guidance to ensure they are in compliance with the new requirements.
Treasury’s reporting framework is also now permitting Tribal recipients to record their expenditures through September 30, 2022. The CRF’s eligible use continues to be restricted to “necessary expenditures incurred due to” the COVID-19 public health emergency. Treasury currently expects that this expenditure deadline will provide sufficient time for Tribal recipients to expend their funds in accordance with the eligible uses of the CRF. Treasury has also made certain adjustments to its frequently asked questions document to reflect this revision and it will provide Tribal Nation recipients with subsequent updates regarding how this change will impact CRF reporting requirements. The remainder of Treasury’s guidance remains in effect.
Questions on the CRF should be sent to firstname.lastname@example.org. For more information on the CRF please click here, and for more information on the revised Treasury Guidance please click here. Treasury has also issued information on reporting and recordkeeping requirements on CRF payments, which can be accessed by clicking here.
For more information, please contact Brian Howard, USET SPF Senior Policy Analyst, at email@example.com.