I presume that everyone has seen these guidelines but how does everyone interpret Section 5 on a public agency's ability to use the funds for a grant program to businesses for COVID-19 business interruption or payroll support program. Page 1 further states that: "The requirement that expenditures be incurred "due to" the public health emergency means that expenditures must be used for actions taken to respond to the public health emergency. These may include expenditures incurred to allow the State, territorial, local, or Tribal government to respond directly to the emergency, such as by addressing medical or public health needs, as well as expenditures incurred to respond to second-order effects of the emergency, such as by providing economic support to those suffering from employment or business interruptions due to COVID-19-related business closures. Do you interpret the language to permit only the costs incurred by the public agency to administer the grant or payroll support programs or do you interpret the language to be broader and include the funds that are distributed by the public agency to the private sector for economic support? The specificity of the guidance leaves something to be desired. Thank you in advance for your assistance. Gregory P. Priamos County Counsel County of Riverside gpriamos@rivco.org<mailto:gpriamos@rivco.org> 951.955.6300 [CountyLogo] CONFIDENTIALITY NOTICE: This communication is intended for the use of the individual or entity to which it is addressed and may contain attorney work product and/or attorney client information that is privileged, confidential and exempt from disclosure under applicable law. If the reader of this communication is not the intended recipient or the employee or agent responsible for delivering this communication to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify our office by reply e-mail or by telephone and immediately delete this communication and all its attachments. Confidentiality Disclaimer This email is confidential and intended solely for the use of the individual(s) to whom it is addressed. The information contained in this message may be privileged and confidential and protected from disclosure. If you are not the author's intended recipient, be advised that you have received this email in error and that any use, dissemination, forwarding, printing, or copying of this email is strictly prohibited. If you have received this email in error please delete all copies, both electronic and printed, and contact the author immediately. County of Riverside California <http://www.countyofriverside.us/>