CSAC Bulletin Article

CRF Spending Deadline Approaches

December 10, 2020

As the Governor pointed out last week in a letter to counties, cities, and school districts, December 31 marks the deadline for spending federal dollars allocated through the Coronavirus Relief Fund (CRF), passed as part of the CARES Act. Fifteen counties received direct CRF allocations from the federal government and all counties received a sub-allocation from the state. The funds must be spent on costs associated with responding to the COVID-19 pandemic incurred by December 31, 2020. Unspent funds must be returned to the US government.

The US Treasury Department has issued extensive guidance and FAQs, but the section about when costs must be incurred reads, in part, as follows:

“Initial guidance released on April 22, 2020, provided that the cost of an expenditure is incurred when the recipient has expended funds to cover the cost. Upon further consideration and informed by an understanding of State, local, and tribal government practices, Treasury is clarifying that for a cost to be considered to have been incurred, performance or delivery must occur during the covered period but payment of funds need not be made during that time (though it is generally expected that this will take place within 90 days of a cost being incurred).”

We are confident that all counties will spend their full allocations by the deadline, based on information they have provided to the California Department of Finance.

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