When is a Cost Considered "Incurred" for Cares Funding Purposes?

AK
Amanda Kellar
Fri, Sep 4, 2020 6:54 PM

A member has purchased an ambulance with CARES funding. Where they are located has tough winters, and the ambulance needs an enclosed storage garage. While the construction materials for the storage garage can be purchased and received prior to 12/30, the structure itself cannot be built until after March or April.

Are other local governments using CARES funding for new public health-related construction that cannot be completed and put into use prior to the 12/30 deadline?  The June 30th guidance on when a cost is considered to be incurred for purposes of the requirement that expenses be incurred within the covered period seems gray on this.  We would appreciate any thoughts folks might have on this and I will pass your emails along to the inquiring member.

[photo]

Amanda Kellar
Deputy General Counsel / Director of Legal Advocacy
International Municipal Lawyers Association, Inc.

A 51 Monroe St., Suite 404, Rockville, MD, 20850

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A member has purchased an ambulance with CARES funding. Where they are located has tough winters, and the ambulance needs an enclosed storage garage. While the construction materials for the storage garage can be purchased and received prior to 12/30, the structure itself cannot be built until after March or April. Are other local governments using CARES funding for new public health-related construction that cannot be completed and put into use prior to the 12/30 deadline? The June 30th guidance on when a cost is considered to be incurred for purposes of the requirement that expenses be incurred within the covered period seems gray on this. We would appreciate any thoughts folks might have on this and I will pass your emails along to the inquiring member. [photo] Amanda Kellar Deputy General Counsel / Director of Legal Advocacy International Municipal Lawyers Association, Inc. A 51 Monroe St., Suite 404, Rockville, MD, 20850 [cid:image003.jpg@01D682CB.3F481970]<http://www.facebook.com/IMLA-259977855541/> [cid:image004.jpg@01D682CB.3F481970] <http://www.linkedin.com/company/international-municipal-lawyers-association-inc./> [cid:image005.jpg@01D682CB.3F481970] <http://twitter.com/imlalegal> [cid:image006.jpg@01D682CB.3F481970] <http://soundcloud.com/internationalmunicipallawyersassociation> P (202) 466-5424 ext. 7116 W www.imla.org<http://www.imla.org/> Plan Ahead! IMLA's 85th Virtual Annual Conference<http://imla.org/events/conferences>, September 21-October 16, 2020! IMLA's 2021 Mid-Year Seminar<https://imla.org/events/seminars>, April 23-26, 2021 in Washington, DC!