Double-dipping isn’t about chips and queso anymore. 

By this point everybody is somewhat familiar with the Coronavirus Aid, Relief and Economic Security (CARES) Act.  Discussions about the Paycheck Protection Programs (PPP) and Economic Injury Disaster Loans (EIDL) are now common points of discussion at the office and at home (or your brand-new home office).  The rules regarding eligible expenditures, loan forgiveness, and measurement periods will make your head spin. 

A couple of items to keep in mind as the Federal government continues updating and releasing more information on CARES Act funding:

Specific in the guidance issued for state and local governments, the CARES Act requires that the payments from the Coronavirus Relief Fund (CRF) be used to cover expenses that are 1) necessary expenditures incurred due to the public health emergency, 2) were not accounted for in the most recently approved budget, and 3) were incurred during the period March 1, 2020 through December 30, 2020.  Additional guidance on eligible uses of the CRF funds for state and local governments can be found at https://home.treasury.gov/policy-issues/cares/state-and-local-governments. 

Further, be mindful of cost-reimbursement type contracts.  For cost-reimbursement type contracts double-dipping is an immediate concern.  Payroll paid for by PPP funds for employees that are also charged to a Federal program creates an unintended duplication of payment by the Federal government when the PPP loan is forgiven.  Be cognizant of what types of expenses and payroll items are being charged to normal Federal funding programs and the funding received through the CRF.

Information and updates regarding the CARES Act is constantly changing and evolving.  There are multiple resources available online, and KT has a dedicated team of experts available to answer any questions you might have. Watch our blog and social media for the latest updates.