CARES Act Update: Coronavirus Relief Fund for State and Certain Local Governments – Application Deadline April 17, 2020


The U.S. Department of Treasury published guidance pertaining to Section 601 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), which created the $150 billion Coronavirus Relief Fund to benefit state and local governments through direct payments to cover costs attributable to the novel coronavirus (COVID-19). The Department of Treasury’s guidance, including key considerations for local government units seeking to apply for relief funds, is described below.

Eligible Expenses

Funds awarded to local governments from the Coronavirus Relief Fund may only be utilized for eligible expenses. To qualify as an eligible expense under Section 601 of the CARES Act, an expenditure must satisfy three conditions:

  1. The expenditure must be necessitated due to the public health emergency with respect to COVID-19;
  2. The expenditure must not be accounted for in the budget for the state or local government most recently approved as of March 27, 2020; and
  3. The expense must be incurred during the period beginning on March 1, 2020 and ending on December 30, 2020.

The guidance from the Department of Treasury provides that additional details regarding eligible uses of relief funds will be forthcoming in subsequent guidance.

Eligible Governmental Units

To qualify as an eligible governmental unit for the receipt of relief funds, a local government unit must be a county, municipality or township with a population that exceeds 500,000 based on U.S. Census Bureau data for calendar year 2019.

The Department of Treasury has identified the following city and counties in Ohio as eligible governmental units for the receipt of relief funds:

  • City of Columbus
  • Cuyahoga County
  • Franklin County
  • Hamilton County
  • Montgomery County
  • Summit County

Deadline to Apply for Relief Funds

The deadline for eligible governmental units to apply for funds through the Coronavirus Relief Fund is 11:59 p.m. on Friday, April 17, 2020. To apply for funds, qualifying governments must certify their eligibility and submit supporting documentation through the Department of Treasury’s online portal. The CARES Act provides that payments to qualifying governments will be made no later than April 26, 2020 – 30 days after the enactment of the CARES Act.

Calfee attorneys stand ready to assist local government clients with this application process and will continue to provide updates as additional guidance becomes available.

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