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2 <br /> <br />May a State receiving a payment transfer funds to a local government? <br />Yes, provided that the transfer qualifies as a necessary expenditure incurred due to the public health <br />emergency and meets the other criteria of section 601(d) of the Social Security Act. Such funds would be <br />subject to recoupment by the Treasury Department if they have not been used in a manner consistent with <br />section 601(d) of the Social Security Act. <br />May a unit of local government receiving a Fund payment transfer funds to another unit of <br />government? <br />Yes. For example, a county may transfer funds to a city, town, or school district within the county and a <br />county or city may transfer funds to its State, provided that the transfer qualifies as a necessary <br />expenditure incurred due to the public health emergency and meets the other criteria of section 601(d) of <br />the Social Security Act outlined in the Guidance. For example, a transfer from a county to a constituent <br />city would not be permissible if the funds were intended to be used simply to fill shortfalls in government <br />revenue to cover expenditures that would not otherwise qualify as an eligible expenditure. <br />Is a Fund payment recipient required to transfer funds to a smaller, constituent unit of government <br />within its borders? <br />No. For example, a county recipient is not required to transfer funds to smaller cities within the county’s <br />borders. <br />Are recipients required to use other federal funds or seek reimbursement under other federal programs <br />before using Fund payments to satisfy eligible expenses? <br />No. Recipients may use Fund payments for any expenses eligible under section 601(d) of the Social <br />Security Act outlined in the Guidance. Fund payments are not required to be used as the source of <br />funding of last resort. However, as noted below, recipients may not use payments from the Fund to cover <br />expenditures for which they will receive reimbursement. <br />Are there prohibitions on combining a transaction supported with Fund payments with other CARES <br />Act funding or COVID-19 relief Federal funding? <br />Recipients will need to consider the applicable restrictions and limitations of such other sources of <br />funding. In addition, expenses that have been or will be reimbursed under any federal program, such as <br />the reimbursement by the federal government pursuant to the CARES Act of contributions by States to <br />State unemployment funds, are not eligible uses of Fund payments. <br />Are States permitted to use Fund payments to support state unemployment insurance funds generally? <br />To the extent that the costs incurred by a state unemployment insurance fund are incurred due to the <br />COVID-19 public health emergency, a State may use Fund payments to make payments to its respective <br />state unemployment insurance fund, separate and apart from such State’s obligation to the unemployment <br />insurance fund as an employer. This will permit States to use Fund payments to prevent expenses related <br />to the public health emergency from causing their state unemployment insurance funds to become <br />insolvent.