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5 <br /> <br />May recipients use Fund payments to provide emergency financial assistance to individuals and <br />families directly impacted by a loss of income due to the COVID-19 public health emergency? <br />Yes, if a government determines such assistance to be a necessary expenditure. Such assistance could <br />include, for example, a program to assist individuals with payment of overdue rent or mortgage payments <br />to avoid eviction or foreclosure or unforeseen financial costs for funerals and other emergency individual <br />needs. Such assistance should be structured in a manner to ensure as much as possible, within the realm <br />of what is administratively feasible, that such assistance is necessary. <br />The Guidance provides that eligible expenditures may include expenditures related to the provision of <br />grants to small businesses to reimburse the costs of business interruption caused by required closures. <br />What is meant by a “small business,” and is the Guidance intended to refer only to expenditures to <br />cover administrative expenses of such a grant program? <br />Governments have discretion to determine what payments are necessary. A program that is aimed at <br />assisting small businesses with the costs of business interruption caused by required closures should be <br />tailored to assist those businesses in need of such assistance. The amount of a grant to a small business to <br />reimburse the costs of business interruption caused by required closures would also be an eligible <br />expenditure under section 601(d) of the Social Security Act, as outlined in the Guidance. <br />The Guidance provides that expenses associated with the provision of economic support in connection <br />with the public health emergency, such as expenditures related to the provision of grants to small <br />businesses to reimburse the costs of business interruption caused by required closures, would <br />constitute eligible expenditures of Fund payments. Would such expenditures be eligible in the absence <br />of a stay-at-home order? <br />Fund payments may be used for economic support in the absence of a stay-at-home order if such <br />expenditures are determined by the government to be necessary. This may include, for example, a grant <br />program to benefit small businesses that close voluntarily to promote social distancing measures or that <br />are affected by decreased customer demand as a result of the COVID-19 public health emergency. <br />May Fund payments be used to assist impacted property owners with the payment of their property <br />taxes? <br />Fund payments may not be used for government revenue replacement, including the provision of <br />assistance to meet tax obligations. <br />May Fund payments be used to replace foregone utility fees? If not, can Fund payments be used as a <br />direct subsidy payment to all utility account holders? <br />Fund payments may not be used for government revenue replacement, including the replacement of <br />unpaid utility fees. Fund payments may be used for subsidy payments to electricity account holders to the <br />extent that the subsidy payments are deemed by the recipient to be necessary expenditures incurred due to <br />the COVID-19 public health emergency and meet the other criteria of section 601(d) of the Social <br />Security Act outlined in the Guidance. For example, if determined to be a necessary expenditure, a <br />government could provide grants to individuals facing economic hardship to allow them to pay their <br />utility fees and thereby continue to receive essential services.