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AS OF JUNE 24, 2021
<br />8
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<br />whose services are substantially dedicated to mitigating or responding to the
<br />COVID-19 public health emergency." What has changed in CSFRF/CLFRF, and
<br />what type of documentation is required under CSFRF/CLFRF? [5/27]
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<br />Many of the expenses authorized under the Coronavirus Relief Fund are also eligible uses
<br />under the CSFRF/CLFRF. However, in the case of payroll expenses for public safety,
<br />public health, health care, human services, and similar employees (hereafter, public
<br />health and safety staff), the CSFRF/CLFRF does differ from the CRF. This change
<br />reflects the differences between the ARPA and CARES Act and recognizes that the
<br />response to the COVID-19 public health emergency has changed and will continue to
<br />change over time. In particular, funds may be used for payroll and covered benefits
<br />expenses for public safety, public health, health care, human services, and similar
<br />employees, including first responders, to the extent that the employee’s time that is
<br />dedicated to responding to the COVID-19 public health emergency.
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<br />For administrative convenience, the recipient may consider a public health and safety
<br />employee to be entirely devoted to mitigating or responding to the COVID-19 public
<br />health emergency, and therefore fully covered, if the employee, or his or her operating
<br />unit or division, is primarily dedicated (e.g., more than half of the employee’s time is
<br />dedicated) to responding to the COVID-19 public health emergency.
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<br />Recipients may use presumptions for assessing whether an employee, division, or
<br />operating unit is primarily dedicated to COVID-19 response. The recipient should
<br />maintain records to support its assessment, such as payroll records, attestations from
<br />supervisors or staff, or regular work product or correspondence demonstrating work on
<br />the COVID-19 response. Recipients need not routinely track staff hours. Recipients
<br />should periodically reassess their determinations.
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<br />2.15. What staff are included in “public safety, public health, health care, human
<br />services, and similar employees”? Would this include, for example, 911 operators,
<br />morgue staff, medical examiner staff, or EMS staff? [5/27]
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<br />As discussed in the Interim Final Rule, funds may be used for payroll and covered
<br />benefits expenses for public safety, public health, health care, human services, and
<br />similar employees, for the portion of the employee’s time that is dedicated to responding
<br />to the COVID-19 public health emergency.
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<br />Public safety employees would include police officers (including state police officers),
<br />sheriffs and deputy sheriffs, firefighters, emergency medical responders, correctional and
<br />detention officers, and those who directly support such employees such as dispatchers
<br />and supervisory personnel. Public health employees would include employees involved
<br />in providing medical and other health services to patients and supervisory personnel,
<br />including medical staff assigned to schools, prisons, and other such institutions, and other
<br />support services essential for patient care (e.g., laboratory technicians, medical examiner
<br />or morgue staff) as well as employees of public health departments directly engaged in
<br />matters related to public health and related supervisory personnel. Human services staff
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