COVID-19 Federal Assistance e311


Compliance & Reporting, Federal Funding Streams

Funding Source

American Rescue Plan Act, CARES Act, FEMA, HUD, Infrastructure Investments and Jobs Act

How can a municipality avoid duplication of benefits?

Municipalities should consider conducting a duplication of benefits analysis from the earliest stages of the process.  This duplication of benefits analysis should be completed before receiving or providing federally funded assistance.

A municipality may complete a duplication of benefits analysis by developing an overall budget that demonstrates the funding needed for the activity and the funding reasonably anticipated (similar to a “sources and uses” analysis for a housing or economic development project). This budget should include all Federal and non-Federal funding, as well as in-kind donations, keeping in mind the specific requirements and restrictions of each funding source. If the budget shows that the need is equal to or greater than the funding sources, there is no duplication of benefits.

Municipalities can take other steps, including but not limited to requiring beneficiaries to disclose all other financial assistance they have applied for or received, provide a self-certification indicating that they have not received a duplicative benefit, or fill out a questionnaire listing potentially duplicative assistance that they have already received or reasonably anticipate receiving.   In addition, municipalities can consider requiring applicants to disclose any new grants approved or other applications for assistance submitted in the period between their application submission to your municipality and its ultimate approval.

Lastly, if your city has an overlapping jurisdiction with another municipality or county, both parties should consider coordinating efforts to avoid duplication of benefits before they start distributing benefits. For example, with rental assistance, a city, county or state might all have rental assistance programs that could potentially provide assistance to the same household for the same period of time.

Last Revised: April 14, 2021