Yesterday, the U.S. Department of Treasury (Treasury) issued re-interpreted guidance on the Coronavirus Relief Fund (CRF) which provides more flexibility for Tribal Governments to utilize their remaining funds. The revised guidance is “to provide that a cost associated with a necessary expenditure incurred due to the public health emergency shall be considered to have been incurred by December 31, 2021, if the recipient has incurred an obligation with respect to such cost by December 31, 2021.”
An “obligation”, as defined within this revised guidance, is “an order placed for property and services and entry into contracts, sub-awards, and similar transactions that require payment”, which is consistent with 2 C.F.R. 200.1 definition of Uniform Guidance.
Previously, Treasury only considered costs to have been incurred if performance or delivery took place by December 31, 2021. In addition, Treasury announced that expenditures are also permitted to be recorded through September 30, 2022.
The CRF was established within the Coronavirus Aid, Relief, and Economic Security (CARES) Act, which was passed on March 25, 2020. The National Indian Gaming Association thanks all of the tireless advocates that fought to continue to provide more resources for Tribal Governments to address the ongoing ramifications of the COVID-19 pandemic.
The revised guidance from Treasury is attached. Please reach out to Danielle Her Many Horses at firstname.lastname@example.org with any questions or concerns with this alert.