Cares Act sec. 2103 - reimbursement of unemployment payments
Will the 50% reimbursement be for all benefits paid between March and December 2020, or only 50% of the extra $600 pandemic unemployment insurance?
Joe Callanan
Town Solicitor
t: (781) 789-2669
Sent from outside my office in Town Hall.
From: Disasterrelief [disasterrelief-bounces@lists.imla.org] on behalf of Amanda Stanley [astanley@lkm.org]
Sent: Monday, April 27, 2020 3:14 PM
To: Corrie Manning; Eileen Blackwood; disasterrelief@lists.imla.org
Subject: Re: [Disasterrelief] 2 CFR contract provisions
I was informed by our Department of Labor that it will be automatically be taken off the quarterly reimbursement bill. The reimbursing municipalities will get a bill for only 50% of the cost. The bill will show what the total cost was, the subtraction due to the CARES Act, and then the new total. It is applicable to all reimbursing municipalities regardless of size through December 31, 2020.
Amanda L. Stanley
General Counsel
astanley@lkm.orgmailto:astanley@lkm.org
785-354-9565
From: Corrie Manning cmanning@cacities.org
Sent: Monday, April 27, 2020 1:34 PM
To: Eileen Blackwood eblackwood@burlingtonvt.gov; Amanda Stanley astanley@lkm.org; disasterrelief@lists.imla.org
Subject: RE: 2 CFR contract provisions
If anyone has examples of how this is working logistically in their state, I would be curious to hear.
It is my understanding this is not limited to cities over 500,000, but it anyone has a different understanding I would be curious to hear that as well.
Thanks,
Corrie Manning
General Counsel
League of California Cities
p. 916.658.8267
cmanning@cacities.orgmailto:cmanning@cacities.org | www.cacities.org<UrlBlockedError.aspx>
[cid:image002.png@01D4A73F.6528ADD0]
Strengthening California Cities
Through Education & Advocacy
Twitterhttps://twitter.com/CaCities │ Facebookhttps://www.facebook.com/leagueofcacities │ YouTubehttps://www.youtube.com/user/leagueofcacities │ LinkedInhttps://www.linkedin.com/company/league-of-california-cities/
Disclaimer: This communication may contain the League of California Cities' confidential and proprietary data. This message is intended only for the personal and confidential use of the designated recipients named above. If you are not the intended recipient of this message you are hereby notified that any review, dissemination, distribution or copying of this message is strictly prohibited. In addition, if you have received this message in error, please advise the sender by reply email and delete the message.
The League of California Cities does not provide legal advice and nothing in this email should be construed as legal advice. Please contact your legal counsel if you have a legal question regarding any information in this email.
From: Disasterrelief [mailto:disasterrelief-bounces@lists.imla.org] On Behalf Of Eileen Blackwood
Sent: Tuesday, April 21, 2020 3:41 PM
To: Amanda Stanley <astanley@lkm.orgmailto:astanley@lkm.org>; disasterrelief@lists.imla.orgmailto:disasterrelief@lists.imla.org
Subject: Re: [Disasterrelief] 2 CFR contract provisions
Yes, our state unemployment folks tell us they are still figuring out how the reimbursement will work logistically, but they have confirmed that self-insured plans will be reimbursed for 50% of the benefits.
Eileen M. Blackwood
City Attorney & Corporation Counsel
City Hall
149 Church St., Suite 11
Burlington, VT 05401
(802) 865-7125
eblackwood@burlingtonvt.govmailto:eblackwood@burlingtonvt.gov
From: Disasterrelief [mailto:disasterrelief-bounces@lists.imla.org] On Behalf Of Amanda Stanley
Sent: Tuesday, April 21, 2020 3:07 PM
To: disasterrelief@lists.imla.orgmailto:disasterrelief@lists.imla.org
Subject: Re: [Disasterrelief] 2 CFR contract provisions
[WARNING]: External Message
Has anyone looked into CARES II Section 2103? It looks like there is a provision in section 2103 that possibly allows reimbursement for 50% of state unemployment benefits for self-insured plans for municipalities. Just wondering how different states are handling this.
Thanks,
Amanda L. Stanley
General Counsel
astanley@lkm.orgmailto:astanley@lkm.org
785-354-9565
From: Disasterrelief <disasterrelief-bounces@lists.imla.orgmailto:disasterrelief-bounces@lists.imla.org> On Behalf Of Houston, Norma
Sent: Tuesday, April 21, 2020 12:34 PM
To: disasterrelief@lists.imla.orgmailto:disasterrelief@lists.imla.org
Subject: [Disasterrelief] 2 CFR contract provisions
Listmates:
As you all are no doubt painfully aware, contracts under which costs are incurred for which an applicant seeks FEMA PA reimbursement are subject to 2 CFR Part 200 (Uniform Guidance) procurement requirements. Among these requirements are that a number of federally-required contract provisions must be included in the contracts. Even under the current E/E guidance issued by FEMA for the COVID-19 event, the federal contract provision requirement is still in effect. Have any of your states enacted legislation (or perhaps for those with broad local ordinance authority, an ordinance) incorporating these contracts provisions by reference by operation of law where required and applicable under federal law?
[http://www.sog.unc.edu/dailybulletin/images/SOGLogoForEmail.gif]Norma R. Houston
Lecturer in Public Law and Government
The University of North Carolina at Chapel Hill
Campus Box 3330, Knapp-Sanders Building
Chapel Hill, NC 27599-3330
T: 919.843.8930
www.sog.unc.eduhttp://www.sog.unc.edu/
E-mails sent to or from this e-mail address that relate to the School of Government's work are public records and may be subject to public access under the North Carolina public records law.
Please note that this communication and any response to it will be maintained as a public record and may be subject to disclosure under the Vermont Public Records Act.
CAUTION: This email originated from outside our organization. Exercise caution when replying, opening attachments or clicking links.
This email and any files transmitted with it are privileged, confidential and intended solely for the use of the individual or entity to which they are addressed. If you have received this email in error please notify the sender immediately and delete this e-mail from your system. You should not disseminate, distribute or copy this e-mail. Please note that any views or opinions presented in this email are solely those of the author and do not necessarily represent those of the Town of Weymouth. Finally, the recipient should check this email and any attachments for the presence of viruses. The Town of Weymouth accepts no liability for any damage caused by any virus transmitted by this email.
Town of Weymouth, 75 Middle Street, Weymouth, MA, 02189
www.weymouth.ma.us
It is 50% of all benefits and 100% of the extra $600.
Amanda L. Stanley
General Counsel
astanley@lkm.orgmailto:astanley@lkm.org
785-354-9565
From: JCallanan@weymouth.ma.us JCallanan@weymouth.ma.us
Sent: Wednesday, April 29, 2020 12:42 PM
To: Amanda Stanley astanley@lkm.org; Corrie Manning cmanning@cacities.org; Eileen Blackwood eblackwood@burlingtonvt.gov; disasterrelief@lists.imla.org
Subject: Cares Act sec. 2103 - reimbursement of unemployment payments
Will the 50% reimbursement be for all benefits paid between March and December 2020, or only 50% of the extra $600 pandemic unemployment insurance?
Joe Callanan
Town Solicitor
t: (781) 789-2669
Sent from outside my office in Town Hall.
From: Disasterrelief [disasterrelief-bounces@lists.imla.org] on behalf of Amanda Stanley [astanley@lkm.org]
Sent: Monday, April 27, 2020 3:14 PM
To: Corrie Manning; Eileen Blackwood; disasterrelief@lists.imla.orgmailto:disasterrelief@lists.imla.org
Subject: Re: [Disasterrelief] 2 CFR contract provisions
I was informed by our Department of Labor that it will be automatically be taken off the quarterly reimbursement bill. The reimbursing municipalities will get a bill for only 50% of the cost. The bill will show what the total cost was, the subtraction due to the CARES Act, and then the new total. It is applicable to all reimbursing municipalities regardless of size through December 31, 2020.
Amanda L. Stanley
General Counsel
astanley@lkm.orgmailto:astanley@lkm.org
785-354-9565
From: Corrie Manning <cmanning@cacities.orgmailto:cmanning@cacities.org>
Sent: Monday, April 27, 2020 1:34 PM
To: Eileen Blackwood <eblackwood@burlingtonvt.govmailto:eblackwood@burlingtonvt.gov>; Amanda Stanley <astanley@lkm.orgmailto:astanley@lkm.org>; disasterrelief@lists.imla.orgmailto:disasterrelief@lists.imla.org
Subject: RE: 2 CFR contract provisions
If anyone has examples of how this is working logistically in their state, I would be curious to hear.
It is my understanding this is not limited to cities over 500,000, but it anyone has a different understanding I would be curious to hear that as well.
Thanks,
Corrie Manning
General Counsel
League of California Cities
p. 916.658.8267
cmanning@cacities.orgmailto:cmanning@cacities.org | www.cacities.org<UrlBlockedError.aspx>
[cid:image002.png@01D4A73F.6528ADD0]
Strengthening California Cities
Through Education & Advocacy
Twitterhttps://twitter.com/CaCities │ Facebookhttps://www.facebook.com/leagueofcacities │ YouTubehttps://www.youtube.com/user/leagueofcacities │ LinkedInhttps://www.linkedin.com/company/league-of-california-cities/
Disclaimer: This communication may contain the League of California Cities' confidential and proprietary data. This message is intended only for the personal and confidential use of the designated recipients named above. If you are not the intended recipient of this message you are hereby notified that any review, dissemination, distribution or copying of this message is strictly prohibited. In addition, if you have received this message in error, please advise the sender by reply email and delete the message.
The League of California Cities does not provide legal advice and nothing in this email should be construed as legal advice. Please contact your legal counsel if you have a legal question regarding any information in this email.
From: Disasterrelief [mailto:disasterrelief-bounces@lists.imla.org] On Behalf Of Eileen Blackwood
Sent: Tuesday, April 21, 2020 3:41 PM
To: Amanda Stanley <astanley@lkm.orgmailto:astanley@lkm.org>; disasterrelief@lists.imla.orgmailto:disasterrelief@lists.imla.org
Subject: Re: [Disasterrelief] 2 CFR contract provisions
Yes, our state unemployment folks tell us they are still figuring out how the reimbursement will work logistically, but they have confirmed that self-insured plans will be reimbursed for 50% of the benefits.
Eileen M. Blackwood
City Attorney & Corporation Counsel
City Hall
149 Church St., Suite 11
Burlington, VT 05401
(802) 865-7125
eblackwood@burlingtonvt.govmailto:eblackwood@burlingtonvt.gov
From: Disasterrelief [mailto:disasterrelief-bounces@lists.imla.org] On Behalf Of Amanda Stanley
Sent: Tuesday, April 21, 2020 3:07 PM
To: disasterrelief@lists.imla.orgmailto:disasterrelief@lists.imla.org
Subject: Re: [Disasterrelief] 2 CFR contract provisions
[WARNING]: External Message
Has anyone looked into CARES II Section 2103? It looks like there is a provision in section 2103 that possibly allows reimbursement for 50% of state unemployment benefits for self-insured plans for municipalities. Just wondering how different states are handling this.
Thanks,
Amanda L. Stanley
General Counsel
astanley@lkm.orgmailto:astanley@lkm.org
785-354-9565
From: Disasterrelief <disasterrelief-bounces@lists.imla.orgmailto:disasterrelief-bounces@lists.imla.org> On Behalf Of Houston, Norma
Sent: Tuesday, April 21, 2020 12:34 PM
To: disasterrelief@lists.imla.orgmailto:disasterrelief@lists.imla.org
Subject: [Disasterrelief] 2 CFR contract provisions
Listmates:
As you all are no doubt painfully aware, contracts under which costs are incurred for which an applicant seeks FEMA PA reimbursement are subject to 2 CFR Part 200 (Uniform Guidance) procurement requirements. Among these requirements are that a number of federally-required contract provisions must be included in the contracts. Even under the current E/E guidance issued by FEMA for the COVID-19 event, the federal contract provision requirement is still in effect. Have any of your states enacted legislation (or perhaps for those with broad local ordinance authority, an ordinance) incorporating these contracts provisions by reference by operation of law where required and applicable under federal law?
[http://www.sog.unc.edu/dailybulletin/images/SOGLogoForEmail.gif]Norma R. Houston
Lecturer in Public Law and Government
The University of North Carolina at Chapel Hill
Campus Box 3330, Knapp-Sanders Building
Chapel Hill, NC 27599-3330
T: 919.843.8930
www.sog.unc.eduhttp://www.sog.unc.edu/
E-mails sent to or from this e-mail address that relate to the School of Government's work are public records and may be subject to public access under the North Carolina public records law.
Please note that this communication and any response to it will be maintained as a public record and may be subject to disclosure under the Vermont Public Records Act.
CAUTION: This email originated from outside our organization. Exercise caution when replying, opening attachments or clicking links.
This email and any files transmitted with it are privileged, confidential and intended solely for the use of the individual or entity to which they are addressed. If you have received this email in error please notify the sender immediately and delete this e-mail from your system. You should not disseminate, distribute or copy this e-mail. Please note that any views or opinions presented in this email are solely those of the author and do not necessarily represent those of the Town of Weymouth. Finally, the recipient should check this email and any attachments for the presence of viruses. The Town of Weymouth accepts no liability for any damage caused by any virus transmitted by this email.
Town of Weymouth, 75 Middle Street, Weymouth, MA, 02189
www.weymouth.ma.ushttp://www.weymouth.ma.us
