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10-14-2020 Workshop Packet
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10-14-2020 Workshop Packet
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The 1st monthly report was submitted in September. The 2nd monthly report will be approved at the <br />Council meeting on October 14th. A “single audit” at the end of the year will need to conducted to <br />confirm the proper use of the funds. Any fund expended in a manner contrary to federal or state <br />guidance will need to be repaid. <br />Public Safety <br />The Coronavirus Relief Fund (CRF) Guidance dated 09-02-2020 indicates that local governments <br />“may presume that payroll costs for the public health and public safety employees are payments for <br />services substantially dedicated to mitigating or responding to the COVID-19 public health emergency, <br />unless the chief executive (or equivalent) of the relevant government determines that specific <br />circumstances indicate otherwise.” <br />On September 21st, the Department of the Treasury, Office of the Inspector General (OIG) released <br />new guidance regarding documentation required for using CARES Act Funds to cover payroll costs for <br />public health and safety employees. Per the new OIG guidance, governments can presume that all <br />payroll costs for public health and public safety employees are payments for services sustainably <br />dedicated to mitigating or responding to the COVID-19 public health emergency. <br />Exerts from the new guidance regarding OIG’s responses regarding public health and public safety <br />employees: <br />70. To what level of documentation will a government be held to support the reimbursement of public <br />health and safety payroll that was "presumed" to be substantially dedicated to mitigating the <br />emergency? <br />The recipient of CRF payments must maintain and make available to Treasury OIG upon <br />request, all documents and financial records sufficient to establish compliance with subsection <br />601(d) of the Social Security Act, as amended (42 U.S.C. 801(d)). Documents/records include <br />payroll records for the covered period March 1 through December 30, 2020. Records include, <br />but are not limited to (1) general and subsidiary ledgers used to account for the receipt of CRF <br />payments and subsequent disbursements; and (2) payroll, time, and human resource records to <br />support costs incurred for payroll expenses. Please refer to the Treasury OIG memorandum, <br />Coronavirus Relief Fund Reporting and Record Retention Requirements (OIG-20-021; July 2, <br />2020). These document requirements apply to supporting payroll reimbursement amounts using <br />CRF proceeds and not to support the presumption that public health and safety payroll is <br />substantially dedicated to mitigating the emergency. <br />(a)Will a government have to demonstrate/substantiate that a public health or public safety <br />employee's function/duties were in fact substantially dedicated to mitigating the <br />emergency? <br />No, the government will not have to demonstrate/substantiate that a public health or public <br />safety employee’s function/duties were substantially dedicated to mitigating the emergency <br />but must maintain records and documentation supporting payroll amounts reimbursed using <br />CRF proceeds. As indicated in Treasury’s Guidance, as an administrative accommodation, <br />governments may presume that public health and public safety employees meet the <br />substantially dedicated test, unless the chief executive (or equivalent) of the relevant <br />government determines that specific circumstances indicate otherwise. Treasury’s FAQs <br />add that entire payroll cost of an employee whose time is substantially dedicated to
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