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CARES Relief Fund - eligibility analysis re: remote technology, court expenses

Alison Earles

Wed, Jul 15, 2020 2:56 PM

Who disagrees? Agrees? Thanks

Remote services technology for public meetings and municipal court operations, including captioning services and remote interpreter services for accessibility. This supports telework for judges and city officials as well as general public health. Remote services, even when simultaneous with in-person meetings, ensure that those with symptoms, positive results, or recent exposure can stay home and still participate. Such services support open meetings and open court requirements.

"2. Public health expenses such as . . . * Expenses for public safety measures undertaken in response to COVID-19."
"4. Expenses of actions to facilitate compliance with COVID-19-related public health measures, such as: . . . Expenses to improve telework capabilities for public employees to enable compliance with COVID-19 public health precautions."

Costs associated with hiring IT consultants to set up the remote service technology.

"2. Public health expenses such as . . . "* Expenses for technical assistance to local authorities or other entities on mitigation of COVID-19-related threats to public health and safety."

Costs associated with disinfecting a public space in a city building, including a court.
"2. Public health expenses such as . . . * Expenses for disinfection of public areas and other facilities, e.g., nursing homes, in response to the COVID-19 public health emergency."

Costs associated with notifying individuals of exposure to COVID-19 in a court facility. (July 8 guidance.)https://home.treasury.gov/system/files/136/Coronavirus-Relief-Fund-Frequently-Asked-Questions.pdf

"Are expenses associated with contact tracing eligible? Yes, expenses associated with contract tracing are eligible."

Costs associated with house arrest technology for individuals who would normally be incarcerated but have been exposed to COVID-19 and must be quarantined.
"2. Public health expenses such as . . . * Expenses for quarantining individuals." "* Expenses for public safety measures undertaken in response to COVID-19."

Costs associated with remote technology for those on probation, to ensure that they can meet probation requirements without in-person meetings and reduce the incarcerated population (which improves social distancing in jails.)

"4. Expenses of actions to facilitate compliance with COVID-19-related public health measures, such as: . . . * COVID-19-related expenses of maintaining state prisons and county jails, including as relates to sanitation and improvement of social distancing measures, to enable compliance with COVID-19 public health precautions."

[cid:GMA_93e66f00-2c34-4807-9563-c79ead7acc0d.png] Alison Earles, CIPP/US
Senior Associate General Counsel
Office: 678-651-1028 Fax: 678-651-1029
www.gacities.com http://www.gacities.com

READER ADVISORY NOTICE: This information is intended only for the individual named above. If you received this in error, please call 404-688-0472 to notify the sender, and then delete the email without printing, copying or retransmitting it. In addition, be advised that Georgia has a very broad open records law and that your email communications with GMA may be subject to public disclosure.

Hey, did you notice my new email address?

GMANET is now GACITIES.COM. While I'm still getting the emails you send me, please update your contacts to note my new email address.

NOT LEGAL ADVICE: Any information contained herein (including any attachments) is not intended to be and should not be construed as legal advice or the establishment of an attorney-client relationship. Such information also is not intended and should not be construed as advice with respect to municipal financial products, the issuance of municipal securities, or solicitation to induce any municipal securities transaction. The person sending this communication is not a "municipal advisor" as defined in Section 15B of the Securities Exchange Act of 1934. You should consult with your own legal, accounting, tax, financial and other advisors, as applicable.

CONFIDENTIALITY NOTICE: This email may contain privileged or confidential information and is for the sole use of the intended recipient(s). If you are not the intended recipient, any disclosure, copying, distribution, or use of the contents of this communication is prohibited and may be unlawful. If you have received this electronic transmission in error, please reply immediately to the sender that you have received the message in error, and delete it. Thank you.

This email has been scanned by the Symantec Email Security.cloud service.
For more information please visit http://www.symanteccloud.com

Greetings, all. I have a few questions about eligibility for CARES Relief Funds received by cities. I think the following uses of funds for unbudgeted expenses that the city deems "reasonably necessary" "due to COVID-19" are eligible under the general rule (unbudgeted in budget that existed on March 27, necessary due to COVID-19, incurred between March 1 and December 30, 2020.) All quoted language in this email are from the June 30 guidance<https://home.treasury.gov/system/files/136/Coronavirus-Relief-Fund-Guidance-for-State-Territorial-Local-and-Tribal-Governments.pdf> except when the July 8 guidance is mentioned. I note that under the general rule, the guidance states that it interprets "necessary" "broadly to mean that the expenditure is reasonably necessary for its intended use in the reasonable judgment of the government officials responsible for spending Fund payments." I also think that specific examples of expenses listed in the guidance support the expenses, as set forth below. Who disagrees? Agrees? Thanks Remote services technology for public meetings and municipal court operations, including captioning services and remote interpreter services for accessibility. This supports telework for judges and city officials as well as general public health. Remote services, even when simultaneous with in-person meetings, ensure that those with symptoms, positive results, or recent exposure can stay home and still participate. Such services support open meetings and open court requirements. "2. Public health expenses such as . . . * Expenses for public safety measures undertaken in response to COVID-19." "4. Expenses of actions to facilitate compliance with COVID-19-related public health measures, such as: . . . Expenses to improve telework capabilities for public employees to enable compliance with COVID-19 public health precautions." Costs associated with hiring IT consultants to set up the remote service technology. "2. Public health expenses such as . . . "* Expenses for technical assistance to local authorities or other entities on mitigation of COVID-19-related threats to public health and safety." Costs associated with disinfecting a public space in a city building, including a court. "2. Public health expenses such as . . . * Expenses for disinfection of public areas and other facilities, e.g., nursing homes, in response to the COVID-19 public health emergency." Costs associated with notifying individuals of exposure to COVID-19 in a court facility. (July 8 guidance.)<https://home.treasury.gov/system/files/136/Coronavirus-Relief-Fund-Frequently-Asked-Questions.pdf> "Are expenses associated with contact tracing eligible? Yes, expenses associated with contract tracing are eligible." Costs associated with house arrest technology for individuals who would normally be incarcerated but have been exposed to COVID-19 and must be quarantined. "2. Public health expenses such as . . . * Expenses for quarantining individuals." "* Expenses for public safety measures undertaken in response to COVID-19." Costs associated with remote technology for those on probation, to ensure that they can meet probation requirements without in-person meetings and reduce the incarcerated population (which improves social distancing in jails.) "4. Expenses of actions to facilitate compliance with COVID-19-related public health measures, such as: . . . * COVID-19-related expenses of maintaining state prisons and county jails, including as relates to sanitation and improvement of social distancing measures, to enable compliance with COVID-19 public health precautions." [cid:GMA_93e66f00-2c34-4807-9563-c79ead7acc0d.png] Alison Earles, CIPP/US Senior Associate General Counsel Office: 678-651-1028 Fax: 678-651-1029 www.gacities.com<http://www.gacities.com> READER ADVISORY NOTICE: This information is intended only for the individual named above. If you received this in error, please call 404-688-0472 to notify the sender, and then delete the email without printing, copying or retransmitting it. In addition, be advised that Georgia has a very broad open records law and that your email communications with GMA may be subject to public disclosure. Hey, did you notice my new email address? GMANET is now GACITIES.COM. While I'm still getting the emails you send me, please update your contacts to note my new email address. NOT LEGAL ADVICE: Any information contained herein (including any attachments) is not intended to be and should not be construed as legal advice or the establishment of an attorney-client relationship. Such information also is not intended and should not be construed as advice with respect to municipal financial products, the issuance of municipal securities, or solicitation to induce any municipal securities transaction. The person sending this communication is not a "municipal advisor" as defined in Section 15B of the Securities Exchange Act of 1934. You should consult with your own legal, accounting, tax, financial and other advisors, as applicable. CONFIDENTIALITY NOTICE: This email may contain privileged or confidential information and is for the sole use of the intended recipient(s). If you are not the intended recipient, any disclosure, copying, distribution, or use of the contents of this communication is prohibited and may be unlawful. If you have received this electronic transmission in error, please reply immediately to the sender that you have received the message in error, and delete it. Thank you. ______________________________________________________________________ This email has been scanned by the Symantec Email Security.cloud service. For more information please visit http://www.symanteccloud.com ______________________________________________________________________

Nicholas Spiropoulos

Wed, Jul 15, 2020 6:00 PM

I agree 100%.

Last night, my Assembly approved spending on very similar things. We wrote justifications for the expenses into the information memorandum justifying each and every project. If you want an example of the IT justifications, let me know.

Nicholas Spiropoulos | Matanuska-Susitna Borough Attorney | (907) 861-8677

From: Disasterrelief disasterrelief-bounces@lists.imla.org On Behalf Of Alison Earles
Sent: Wednesday, July 15, 2020 6:56 AM
To: disasterrelief@lists.imla.org
Subject: [Disasterrelief] CARES Relief Fund - eligibility analysis re: remote technology, court expenses

[EXTERNAL EMAIL - CAUTION: Do not open unexpected attachments or links.]
Greetings, all. I have a few questions about eligibility for CARES Relief Funds received by cities. I think the following uses of funds for unbudgeted expenses that the city deems "reasonably necessary" "due to COVID-19" are eligible under the general rule (unbudgeted in budget that existed on March 27, necessary due to COVID-19, incurred between March 1 and December 30, 2020.) All quoted language in this email are from the June 30 guidancehttps://home.treasury.gov/system/files/136/Coronavirus-Relief-Fund-Guidance-for-State-Territorial-Local-and-Tribal-Governments.pdf except when the July 8 guidance is mentioned. I note that under the general rule, the guidance states that it interprets "necessary" "broadly to mean that the expenditure is reasonably necessary for its intended use in the reasonable judgment of the government officials responsible for spending Fund payments." I also think that specific examples of expenses listed in the guidance support the expenses, as set forth below.

Who disagrees? Agrees? Thanks

Costs associated with hiring IT consultants to set up the remote service technology.

"2. Public health expenses such as . . . "* Expenses for technical assistance to local authorities or other entities on mitigation of COVID-19-related threats to public health and safety."

"Are expenses associated with contact tracing eligible? Yes, expenses associated with contract tracing are eligible."

[cid:image001.png@01D65A8E.0C1B4D20]

Alison Earles, CIPP/US

Senior Associate General Counsel

Office: 678-651-1028 Fax: 678-651-1029

www.gacities.com http://www.gacities.com

Hey, did you notice my new email address?

GMANET is now GACITIES.COM. While I'm still getting the emails you send me, please update your contacts to note my new email address.

I agree 100%. Last night, my Assembly approved spending on very similar things. We wrote justifications for the expenses into the information memorandum justifying each and every project. If you want an example of the IT justifications, let me know. Nicholas Spiropoulos | Matanuska-Susitna Borough Attorney | (907) 861-8677 From: Disasterrelief <disasterrelief-bounces@lists.imla.org> On Behalf Of Alison Earles Sent: Wednesday, July 15, 2020 6:56 AM To: disasterrelief@lists.imla.org Subject: [Disasterrelief] CARES Relief Fund - eligibility analysis re: remote technology, court expenses [EXTERNAL EMAIL - CAUTION: Do not open unexpected attachments or links.] Greetings, all. I have a few questions about eligibility for CARES Relief Funds received by cities. I think the following uses of funds for unbudgeted expenses that the city deems "reasonably necessary" "due to COVID-19" are eligible under the general rule (unbudgeted in budget that existed on March 27, necessary due to COVID-19, incurred between March 1 and December 30, 2020.) All quoted language in this email are from the June 30 guidance<https://home.treasury.gov/system/files/136/Coronavirus-Relief-Fund-Guidance-for-State-Territorial-Local-and-Tribal-Governments.pdf> except when the July 8 guidance is mentioned. I note that under the general rule, the guidance states that it interprets "necessary" "broadly to mean that the expenditure is reasonably necessary for its intended use in the reasonable judgment of the government officials responsible for spending Fund payments." I also think that specific examples of expenses listed in the guidance support the expenses, as set forth below. Who disagrees? Agrees? Thanks Remote services technology for public meetings and municipal court operations, including captioning services and remote interpreter services for accessibility. This supports telework for judges and city officials as well as general public health. Remote services, even when simultaneous with in-person meetings, ensure that those with symptoms, positive results, or recent exposure can stay home and still participate. Such services support open meetings and open court requirements. "2. Public health expenses such as . . . * Expenses for public safety measures undertaken in response to COVID-19." "4. Expenses of actions to facilitate compliance with COVID-19-related public health measures, such as: . . . Expenses to improve telework capabilities for public employees to enable compliance with COVID-19 public health precautions." Costs associated with hiring IT consultants to set up the remote service technology. "2. Public health expenses such as . . . "* Expenses for technical assistance to local authorities or other entities on mitigation of COVID-19-related threats to public health and safety." Costs associated with disinfecting a public space in a city building, including a court. "2. Public health expenses such as . . . * Expenses for disinfection of public areas and other facilities, e.g., nursing homes, in response to the COVID-19 public health emergency." Costs associated with notifying individuals of exposure to COVID-19 in a court facility. (July 8 guidance.)<https://home.treasury.gov/system/files/136/Coronavirus-Relief-Fund-Frequently-Asked-Questions.pdf> "Are expenses associated with contact tracing eligible? Yes, expenses associated with contract tracing are eligible." Costs associated with house arrest technology for individuals who would normally be incarcerated but have been exposed to COVID-19 and must be quarantined. "2. Public health expenses such as . . . * Expenses for quarantining individuals." "* Expenses for public safety measures undertaken in response to COVID-19." Costs associated with remote technology for those on probation, to ensure that they can meet probation requirements without in-person meetings and reduce the incarcerated population (which improves social distancing in jails.) "4. Expenses of actions to facilitate compliance with COVID-19-related public health measures, such as: . . . * COVID-19-related expenses of maintaining state prisons and county jails, including as relates to sanitation and improvement of social distancing measures, to enable compliance with COVID-19 public health precautions." [cid:image001.png@01D65A8E.0C1B4D20] Alison Earles, CIPP/US Senior Associate General Counsel Office: 678-651-1028 Fax: 678-651-1029 www.gacities.com<http://www.gacities.com> READER ADVISORY NOTICE: This information is intended only for the individual named above. If you received this in error, please call 404-688-0472 to notify the sender, and then delete the email without printing, copying or retransmitting it. In addition, be advised that Georgia has a very broad open records law and that your email communications with GMA may be subject to public disclosure. Hey, did you notice my new email address? GMANET is now GACITIES.COM. While I'm still getting the emails you send me, please update your contacts to note my new email address. NOT LEGAL ADVICE: Any information contained herein (including any attachments) is not intended to be and should not be construed as legal advice or the establishment of an attorney-client relationship. Such information also is not intended and should not be construed as advice with respect to municipal financial products, the issuance of municipal securities, or solicitation to induce any municipal securities transaction. The person sending this communication is not a "municipal advisor" as defined in Section 15B of the Securities Exchange Act of 1934. You should consult with your own legal, accounting, tax, financial and other advisors, as applicable. CONFIDENTIALITY NOTICE: This email may contain privileged or confidential information and is for the sole use of the intended recipient(s). If you are not the intended recipient, any disclosure, copying, distribution, or use of the contents of this communication is prohibited and may be unlawful. If you have received this electronic transmission in error, please reply immediately to the sender that you have received the message in error, and delete it. Thank you.