Important CARES Act Dates for Local Governments

At Abdo, Eick & Meyers, we’re committed to ensuring our clients are informed on the important legislation affecting their organization. With this in mind, we have gathered information regarding key CARES Act dates and have listed this information below for your convenience.

• Final report due to the State for cities and towns is due on November 24, 2020. County final reports are due December 9, 2020. Remember this should be a cumulative on each report, not what was just spent during the time period.
• Any remaining CARES Act money not spent needs to be returned to the county by November 20, 2020. The city is responsible for lining up that payment and is encouraged to be in touch with the county so they know what to expect.
• We have included an important piece of information relating to timing of expenses below. This is from the State’s FAQ’s updated as of October 22, 2020. You can review the entire PDF document by clicking here.
  • Please note: If eligible items were ordered for delivery prior to November 15 (for cities) and December 1 (for counties) and have not been received yet due to supply chain disruption the city/county needs to have proper documentation in place and this should include a statement from the vendor about the supply chain disruption due to COVID-19.

— From the PDF: FAQs for Local Governments receiving Coronavirus Relief Funds (CRF) from the State of Minnesota —

11. Are expenses incurred (but not spent) before the end of the covered period an eligible use of CRF funds?

No. Per the certification form that each local government signed prior to receiving funds:

“Any aid amount remaining unexpended by an eligible city or town on November 15, 2020, must be sent to the home county in which the city or town is located. For cities located in Hennepin County the funds must be transferred to Hennepin County Medical Center or granted to another hospital in the county’s boundaries. For the cities or towns located in Ramsey County the funds must be granted to Regions Hospital or another hospital in the county’s boundaries. The transfer must be made no later than November 20, 2020. Any amount of aid remaining unexpended by an eligible county by December 1, 2020 must be returned to Minnesota Management and Budget by December 10, 2020.”

“Unexpended” means the payment has not been made (check has not been cut). Funds must be paid out no later than November 15 for cities and towns and no later than December 1 for counties. The only two exceptions are listed below.

There are two exceptions to this rule:

• CRF eligible payroll expenses incurred through Nov. 15 (for cities and towns) and Dec. 1 (for counties) are allowed, even if not paid until after Nov. 15 for cities and towns and Dec. 1 for counties.
• Eligible items ordered for delivery prior to Nov. 15 (for cities and towns) and Dec. 1 (for counties) that have not yet been received due to supply chain disruption are allowed, even if not paid until after Nov.15 for cities and towns and Dec. 1 for counties. Federal guidance recognizes this possibility:

“Similarly, in recognition of the likelihood of supply chain disruptions and increased demand for certain goods and services during the COVID-19 public health emergency, if a recipient enters into a contract requiring the delivery of goods or performance of services by (the end of the covered period), the failure of a vendor to complete delivery or services by (the end of the covered period), will not affect the ability of the recipient to use payments from the Fund to cover the cost of such goods or services if the delay is due to circumstances beyond the recipient’s control.”

For a supply chain disruption scenario, it is generally expected that payments will take place within 90days of a cost being incurred.

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Have questions about these dates or other information related to the CARES Act relief funds for your organization? We can help you find answers. Reach out to an AEM expert to continue the conversation.

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