Where can we find key components and information on the allowable uses of the COVID-19 relief packages?

Federal agencies allocating funding under the COVID-19 relief packages have generally provided centralized locations to access policy, guidance, reporting, and auditing requirements. Frequently Asked Questions (“FAQs”) can help determine how funding may or may not be used by municipalities.[1] The following is a list of some of the federal agencies managing COVID-19 relief funding, and links to where they are aggregating resources, guidance, and FAQs.

• The U.S. Department of the Treasury (“Treasury”) has received $975 billion in COVID-19 relief funding including direct assistance to individuals and funding allocated to states to cover costs directly related to COVID-19 response and recovery or to mitigate the economic impacts of COVID-19. [Treasury COVID-19 Relief Hub.[2]] Some of the noteworthy programs for Treasury funds pertinent to municipalities are:
  • Coronavirus State and Local Fiscal Recovery Funds (“CSLFRF”) – for direct assistance to support long-term recovery from the pandemic including supporting public health expenditures, addressing negative economic impacts caused by the public health emergency, replacing lost public sector revenue, providing premium pay for essential workers, and investing in water, sewer, and broadband infrastructure.[3] Treasury released the CSLFRF Final Rule, which is effective April 1, 2022, allowing for more flexibility in expenditures.[4]
  • Emergency Rental Assistance Program (“ERAP”) – for direct rental assistance to households for rent and utilities.[5]
  • Capital Projects Fund ("CPF") – for states, territories, and tribal governments to carry out capital projects to address infrastructure challenges impacting communities’ access and directly enable work, education, and health monitoring, including remote options, in response to the public health emergency.[6] Treasury updated the CPF FAQ in January 2022.[7]
  • Homeowner Assistance Fund ("HAF") – for states, territories, and tribal governments to provide direct relief to vulnerable homeowners.[8] Treasury updated the HAF-Guidance in February 2022.[9]
  • State Small Business Credit Initiative (“SSBCI”) - provides recipient jurisdictions funding for: (1) credit and investment programs for existing small businesses and start-ups, and (2) technical assistance to small businesses applying for SSBCI funding and other government small business programs.[10]
• The U.S. Department of Housing and Urban Development (“HUD”) has allocated $12.4 billion in COVID-19 relief funding for programs directed at housing relief, supporting vulnerable communities, or supporting economic recovery efforts in line with HUD’s National Objectives.[11] [HUD Coronavirus Hub.[12]]
  • For cities with direct allocations of Community Development Block Grant (“CDBG”) formula programs, HUD is consolidating policy, guidance, and federal register updates specific to CDBG, Community Development Block Grant Disaster Recovery (“CDBG-DR”), and Community Development Block Grant CARES (“CDBG-CV”) allocations. [CDBG COVID-19 Resources.[13]]
• The U.S. Department of Health and Human Services (“HHS”) has received $484.5 billion for COVID-19-related grant programs.[14] HHS is centralizing resources for funding including overviews of available funding, application information, funding-specific guidance, FAQs, and reporting and auditing requirements. [HHS Coronavirus Grant Opportunities and Guidance.[15]]
• Over $263 billion has been allocated to the Coronavirus Education Stabilization Fund to support state and local education facilities recover and rebuild from the COVID-19 pandemic.^[16] The U.S. Department of Education’s COVID-19 Resources for Schools, Students, and Families hub includes a funding overview, guidelines and requirements, and FAQs, as well as specific guidance to direct funding programs:[17]
  • Elementary and Secondary School Emergency Relief Fund (ESSER)[18]
  • Higher Education Emergency Relief Fund (HEERF)[19]
  • Governor’s Emergency Education Relief Fund (GEERF)[20]
• The U.S. Department of Transportation (“USDOT”) has received $106.3 billion in funding [USDOT COVID-19 Relief Funding] available to support COVID-19 preparedness and recovery measures specific to public transportation, airports and air travel, and other transit infrastructure.[21] [Transportation: Coronavirus Relief Resources.[22]]
• The Federal Communications Commission (“FCC”) awarded $450 million in COVID-19 relief funding [FCC Funding] to support communication needs related to telehealth.[23] The FCC also administered the $7.1 billion Emergency Connectivity Fund that supported eligible schools and libraries and the $3.2 billion Emergency Broadband Benefit that supported households struggling to pay for internet service [FCC Coronavirus Overview].[24] As of March 1, 2022, the FCC is continuing to support household broadband through the Affordable Connectivity Program.[25]

Municipalities may find it challenging to determine which funding source to utilize to cover a cost that may be eligible under several different funding sources. Some strategies for making that determination include:

• Position more restrictive funding (e.g., FEMA Public Assistance Program[26]) to be prioritized and used first, before tapping into more flexible funding (e.g., CSLFRF), where reasonable. 
• Understand the specific documentation, timelines, and eligibility requirements of each program as they may differ.
• Track costs to avoid duplication of benefits when funding across multiple funding sources.

Municipalities should also refer to Treasury’s Personal Finance and Consumer Protection - Steps for Quicker Financial Relief to determine how funds can address immediate financial needs of individuals and households including:

• General Information for Bank and Credit Union Customers;
• Mortgage and Housing Assistance;
• Consumer Credit and Other Loans and Debt;
• Student Loans;
• Telephone, Cellphone, and Internet;
• Utility Bills (Water, Gas/Oil, Electricity); and
• Other Help with Finances.[27]

Last Updated: March 31, 2022