Frequently Asked Questions (FAQs)


American Rescue Plan Act (ARPA) - PORTAL NOW OPEN

 Illinois' Non-Entitlement Unit  (NEU) allocation is $742 million. In Illinois, eligible NEUs include more than 1,250 cities, towns and villages that each serve a population under 50,000. 

To assist local governments as they claim their allotments, the State of Illinois has established The NEU Portal.
Per Treasury guidance, NEUs that do not claim their allotments within 60 days after the State begins accepting and processing requests for funding from NEUs will lose their allotments, which will be distributed to other NEUs.


Need Help? Contact the NEU Support Team 
ILARPA@crowe.com 
217-862-2730 

Summary of Important Local CURE Deadline Updates

  • Extended Deadline: The deadline to submit costs for reimbursement will be expanded to January 31, 2022, granting LGUs another year to submit costs incurred from March 1 – December 31, 2021. 
  • Allotment Transfers: Due to the added flexibility within the Local CURE program, the originally planned reallocation of Local CURE funds within Allotment A (counties and municipalities) and Allotment B (local health departments) will no longer occur. For additional flexibility DCEO will be approving allotment transfers between counties and local health departments, when requested by entities with unspent funds.
  • Audit Requirements Reminder: As a recipient of Local CURE funding, your entity is required to comply with 2 CFR 200- Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F- Audit Requirements, because the Local CURE program was funded by the federal CARES Act. Any questions regarding audit requirements can be sent to CEO.Accountability@Illinois.gov.

Reimbursement Request Submission Deadline Information

  • Costs must be incurred between March 1, 2020, and December 31, 2021, consistent with the provisions of the CARES Act, Public Act 101-0636 authorizing the Local CURE Support Program, and the Local CURE Support Program rules at 14 Ill. Admin. Code Part 700.
  • As a reminder, identification of the date a cost is incurred is based on the applicable basis of accounting. 
    • Consistent Application of the Basis of Accounting: Each LGU should continue following its official, standard basis of accounting applied pursuant to established LGU policies, procedures, and protocols.
    • Entities on the Cash Basis: If the entity is on the cash basis, a cost is incurred based on the date of payment.  Therefore, all payments must be made by December 31, 2021.  
    • Entities on the Accrual Basis: If the entity is on the accrual basis, a cost is incurred at the time a good has been received from or services have been rendered by a contractor or vendor.  Therefore, the goods or services must be received by the LGU as of December 31, 2021.  Payment is not required to have been made as of the December 31st deadline, but rather in accordance with the terms and conditions of the applicable contract or purchase order and by closeout dates established within subaward agreements.  Note: Creation or issuance of a purchase order or subcontract may create an obligation or encumbrance; however, it does not establish or otherwise create a cost.
    • Entities’ Payroll Charges: Payroll costs need to be incurred by December 31, 2021.  The corresponding payment should be recorded following the LGU’s established Basis of Accounting. Payment for payroll can be made after December 31, 2021 as long as it agrees with the established LGU’s policies, procedures, and protocols.
    • Payment Support: Evidence of payment must continue to be provided with each transaction submitted for reimbursement. 
    • Assets Not Placed In-Service by December 31, 2021: Under certain circumstances, the United States Department of the Treasury has indicated CRF monies may be utilized to create a reserve of personal protective equipment or develop increased intensive care unit capacity. Purchases must continue to be reasonable, necessary, and appropriately documented though the assets (e.g., ventilators) may not be in-service as of December 31, 2021.  We refer you to Treasury’s Frequently Asked Questions dated October 19, 2020 for additional guidance. 
    • Assets Not Received by December 31, 2021: United States Depart of the Treasury has indicated in recognition of the likelihood of supply chain disruptions and increased demand for certain goods and services during the COVID-19 public health emergency, if a recipient enters into a contract requiring the delivery of goods or performance of services by December 31, 2021, the failure of a vendor to complete delivery or services by December 31, 2021, will not affect the ability of the recipient to use payments from the Fund to cover the cost of such goods or services if the delay is due to circumstances beyond the recipient’s control.

Important Tips

  • The deadline to submit a reimbursement request is January 31, 2022.
  • Multiple line item expenses are allowed per request form submission. Each submission, if approved, will result in a check from the State. Multiple submissions for smaller amounts will result in more checks and may slow down the payment process. A single submission for a larger amount ensures local governments can get their money faster.
  • To add another line item expense, click the blue ‘Create’ and complete the required fields.  There is no limit to the number of line item expenses per request form submission.
  • Limit one invoice/transaction per line item within the request form submission.  Information is required to support each invoice/transaction (e.g. invoice reference number, amount).
  • A payroll register must be provided for all payroll reimbursement requests.
  • When providing proof of payment for a purchase, include either a cancelled check or itemized credit card statement, and the relevant General Ledger detail. Please redact all credit card numbers.
  • The Authorized Representative name included on your request form submission must match the authorized signer on the certification agreement. If not matched, the request will be rejected by the compliance team and local government units will be asked to revise.

General

Is an approved ordinance required before we can submit for reimbursement?
No, DCEO does not require local government units to pass a Local CURE ordinance as part of the certification process.  However, local government units must return a signed certification agreement to DCEO for disbursement of approved funds.

How do I login to the portal?

An updated internet browser is required to use the portal. To access the Portal for the first time, please follow the link emailed to your local government unit contact person and register. We recommend book marking the portal URL for ease of access in the future. If you do not receive a registration email, first check your Spam/Junk folders and then contact LocalCURE@crowe.com. 
 

What do I do if my local government unit has not received a certification number?

Please reach out to LocalCURE@crowe.com.


Can I turn expenses in on a rolling basis or just a one time submission?
Local government units may submit reimbursement requests on a rolling basis. However, we recommend submitting costs incurred between March 1 - June 30, 2020 by September 30, 2020 and costs incurred between July 1- August 31, 2020 by November 30, 2020. Costs incurred after September 1 should be submitted within 30 days. Please remember all reimbursement requests must be submitted by January 31, 2022.

What is considered "proof of payment?"
In addition to a purchase orders and/or invoices, proof of payment includes documentation such as a cancelled check, bank statement highlighting an electronic payment and check stub. This is not an exhaustive list. 

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Program

If a local government unit submits COVID-related expenditures to FEMA and they pay 75%, would the remaining 25% be eligible for reimbursement under the Local CURE program?  If so, what documentation would is required to submit for the remaining 25%?  
Yes. Reimbursements may be used to meet the non-federal matching requirements for Stafford Act assistance to the extent such matching requirements entail COVID-19-related costs that otherwise satisfy CURE eligibility criteria and the Stafford Act. The same documentation provided to FEMA can also be provided for CURE reimbursement, but the narrative justification should clarify reimbursement for only the 25% non-federal matching requirement.  

The County was allocated $xxx amount and the County's Health Department was allocated $xx amount .  If the Health Department exhausts all of its allocated funds can the County claim the remainder of the Health Department's expenses?

If the County and the Health Department share the same FEIN, the remaining County Health Department COVID-related expenditures could be claimed by the County.

Why are funds to support local business not available for this use under the Local CURE program?
Funds for direct business support have been appropriated under the Business Interruption Grants (BIG) program.  More information on BIG can be found here. Additionally, DCEO is launching the Economic Support Grant Program. Information is forthcoming. 

We are a small municipality and have not had many expenses; however, our revenue has gone down significantly.   Is this an eligible expense under the Local CURE program?
Revenue shortfall replacement, including reimbursement or payment of utility bills, is ineligible for reimbursement under the Local CURE program.

What does “substantially dedicated” mean? Is this based on number of hours a day/week/month spent on COVID-19 related tasks?
It is time exclusively spent on COVID-19 related tasks and is documented.

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Employee Pay

Documentation needed for claiming Public Safety payroll:

Title

Documentation needed

Justification Narrative needed

Public Safety Employees*

(1) General and subsidiary ledgers used to account for the receipt of CRF payments and subsequent disbursements; (2) Payroll, time, and human resource records to support costs incurred for payroll expenses per employee (e.g. payroll report); and (3) a summary (or lead sheet) to link the amount requested for reimbursement to the supporting documentation files.

Statement indicating, positions are "substantially dedicated public safety employees"

Public Safety Related Administrative Employees

Statement and/or timesheet records indicating the hours included were "substantially dedicated to mitigating or responding to COVID-19"

*Public safety employees would include police officers, sheriffs and deputy sheriffs, firefighters, emergency medical responders, emergency managers, correctional and detention officers, and those who directly support such employees such as dispatchers and supervisory personnel.

Is there any guidance on what positions are covered under Public Safety or Public Health?

Yes. Public safety employees would include police officers (including state police officers), sheriffs and deputy sheriffs, firefighters, emergency medical responders, correctional and detention officers, and those who directly support such employees such as dispatchers and supervisory personnel.

Public health employees would include employees involved in providing medical and other health services to patients and supervisory personnel, including medical staff assigned to schools, prisons, and other such institutions, and other support services essential for patient care (e.g., laboratory technicians) as well as employees of public health departments directly engaged in matters related to public health and related supervisory personnel.

Can the Local CURE program funding be used for hazard/essential employee pay?
Yes, provided the expenses meet required criteria under the program. A local government can claim payroll for Public Safety, Public Health, Health Care, Human Services and similar employees whose services are “substantially dedicated” to mitigating or responding to the COVID-19 public health emergency. Documentation will be required to show when staff were “substantially dedicated.”

Can we back pay hazard/essential employee pay?
The Department sees retroactive hazard pay as a bonus and bonuses are not allowed under the Treasury guidance, unless documentation is submitted to prove that there has been negotiations or proposed ordinances dating back to early in the pandemic. Documentation should include the rate of hazard pay.

We had to furlough employees and therefore expect to have unemployment insurance costs for these employees receiving unemployment during their furlough. Would the unemployment insurance costs be an eligible expense under the Local CURE program?
Unemployment insurance cost increases during the period of March 1, 2020 to December 31, 2021 directly related to COVID-19 would be reimbursable. 

Is Administrative Leave eligible for reimbursement?
Administrative leave expenses related to COVID-19 would be eligible for reimbursement under this program. The administrative leave policy would need to be submitted along with supporting documentation such as the following: 1) payroll records for each position included within the request, including at a minimum, the position title, rate of pay and time period covered; 2) general ledger records demonstrating the expense items; 3) a copy of the administrative leave policy and/or leave agreement with the employee; and 4) justification narrative. If someone can do their job at home, you cannot use administrative leave for this purpose. For example, Parking Meter Officers cannot do their job at home and would qualify for administrative leave. Regarding FMLA, if employees were placed on paid administrative leave due to COVID-19, their pay is eligible for reimbursement. Note, not all FMLA leaves are related to COVID-19 and those not related are not be eligible.  

Shift/ Administrative Leave Example

We split our public works team and some police staff into two groups. The two groups rotated the weeks worked (Group A worked week one and was off week two, etc.). They were paid for the weeks not worked. This was done in case an employee in one of these groups were to be quarantined, the whole department wouldn't have to be quarantined and we still had employees to do the essential work. Are we able to submit this type of paid administrative leave for reimbursement?


If placed on admin leave due to COVID-19, this would eligible for reimbursement as part of administrative leave expenses that were not budgeted. The administrative leave policy must be submitted with this request.


**NEW: 10/16/2020 Webinar-Payroll Reimbursement FAQ's 
Are payroll costs such as IMRF, FICA and benefits eligible for reimbursement?
Fringe benefits-such as employer contributions to IMRF and FICA-are an allowable payroll cost. If seeking reimbursement for unemployment insurance, provide sufficient documentation demonstrating the cost incurred to the local government unit is over and above previous, pre-COVID payments.

If the total payroll submission is eligible for reimbursement but exceeds the total available funds for a local government unit, how should we annotate that on the supporting documents?
Please use the lead sheet to illustrate methodology and leave notes for the compliance review team to tie out the amount requested versus the amount reflected on the payroll reports.

Meeting the local government unit’s allotment and aligning to payroll will not meet down to the penny. If you need to short a payroll period to meet allotment, write a note on the lead sheet and take a percentage instead of reducing each position for the pay period.

If you have a payroll period with a start date prior to March 1, use the lead sheet to illustrate the request is only for payroll costs incurred after March 1.

How do we use the lead sheet?  
The lead sheet template is a general guide to help illustrate how the request ties out to the supporting documentation. Users can add or remove columns, add notes, etc. as needed.  

If an employees’ time was spent responding to filing grants and holding public hearings for local businesses, are these wages eligible for reimbursement?
Any time that is less than substantially dedicated but was used towards COVID-related work/programs, will be allowable under the new Administrative expense category. DCEO is in the final stages of revising the Local CURE program rules for the category.   We will provide further guidance in the coming weeks.

Are salaries Sheriff deputies’ eligible for reimbursement regardless of whether their duties were altered due to COVID or budgeted for the fiscal year?  
Yes, public safety payroll expenses are eligible for reimbursement, as long as they were incurred between March 1, 2020 and December 31, 2021, and the local government unit certifies that their time was substantially dedicated to the mitigation of COVID.


Eligibility for Reimbursement

We have had to add cameras and audio capabilities in our theater so that we can use it for City Council meetings, are these expenses reimbursable?

Possibly- if such expenses are in response to the public health emergency, represent an increase over previously budgeted amounts and are limited to what is necessary. A narrative justification will need to be provided as supporting documentation for reimbursement.

We are purchasing online permitting software so our residents can get more services online during this COVID-19 shutdowns, is this an eligible expense?
Yes. If such expenses are in response to the public health emergency, represent an increase over previously budgeted amounts and are limited to what is necessary. A narrative justification will need to be provided as supporting documentation for reimbursement.

Staff is disinfecting their workstations, buildings, and vehicles daily. This is would not be done without COVID-19. Is this time spent on this task reimbursable
Costs related to additional cleaning measures, disinfectants and hand sanitizer in an effort to prevent the spread of COVID-19 are eligible expenses provided they occur in the reimbursable period (March 1 - December 31, 2021). However, the time for staff cleaning is not eligible provided the employees are disinfecting during their normal work shifts. Additionally, enhanced cleaning costs- such as added days to a cleaning contract to combat the spread of COVID-19- would be eligible provided they occur within the program period. 

Are temporary outside/curbside voting area needs, including voting booths or machines to be placed at all polling places for November 3, 2020, a covered expense? Is hazard pay for election  judges a covered expense? 
This would most likely be covered by the State Board of Elections budget and most likely would not be reimbursable under this program. Please refer to the eligibility test, i.e. the expense is not being reimbursed through a different emergency response program.

We have tracked our police calls for service as they relate to COVID-19; for example, calls regarding large gatherings, businesses non-compliant with the stay at home order, etc.  How can we track the reimbursable pay? Can we use the number of COVID-19 calls the police department received in one day divided by the number of total calls to get a percentage for the day, then that percentage and multiply by the total cost of police department salaries for the day to find the reimbursement amount? 
Police officers would meet the criteria of public safety, public health, health care, human services, and similar employees whose services are substantially dedicated to mitigating or responding to the COVID-19 public health emergency.  Evidence the time allocated and submitted is attributable to COVID-19-related response activities and the costs can be supported through documentation.

We needed to digitize records for sanitary reasons and to allow residents access to records during stay at home orders. Does the Local CURE program cover these costs?
Digitization of records may be permitted if such expenses are in response to the public health emergency, represent an increase over previously budgeted amounts and are limited to what is necessary. A strong narrative justification is required. Additionally, the program only covers the performance of services through Dec 30th. If the contract goes longer, the reimbursement request needs to be scaled back.


Covering the costs of “parklets” installed by a LGU

  • Costs related to the installation of LGU owned parklets will be covered by the Local CURE program when proper documentation is included with the reimbursement claim.

  • Costs must be limited to what is deemed “necessary” by a LGU and must be limited to expenses incurred as they relate to “facilitating compliance with COVID-19 related public health measures.”

  • Examples of aligning support includes, but is not limited to, the following:

    • A LGU wishes to facilitate the public health measure of limiting indoor dining. The installation of the parklet is connected to a public health order which prevents or limits indoor dining within the LGU’s jurisdiction.

    • A LGU wishes to facilitate necessary public health measures in order to allow for public events such as farmers markets or races where the LGU may incur costs related to issuing permits and blocking streets to make it a safe space.

  • The table below gives examples of costs which are considered necessary and not necessary. This table is not an exhaustive list, it is intended to give examples of what an LGU may deem necessary.

Necessary

Not Necessary

Purchasing public-owned road barriers to block traffic.

Purchasing chairs & tables for use by restaurants.

Costs related to the construction of the parklet that is located on city easement / road*.

Costs related to constructing a parklet that is located on private property.

Costs related to the construction of plexiglass shields to create “booths” within the parklet.

Costs related to renting tents for use in a parklet.

*If an LGU wishes to install on private property, approvals will be deemed on a case by case basis. General guidance of locating parklets on public land only is to prevent abuse of funds.


Treasury guidance on the purchase of vehicles and property: 

Question #58 Treasury guidance found in the CRF FAQ says, in regards to expenses of acquiring or improving real property and of acquiring equipment (e.g., vehicles),  a government must (i) determine that it is not able to meet the need arising from the public health emergency in a cost-effective manner by leasing property or equipment or by improving property already owned and (ii) maintain documentation to support this determination. 


Work from Home & Distance Learning Expenditures

We [city government] needed additional equipment and technology to respond in a stay-at-home situation. The technology and equipment needs total nearly $400,000, none of which is in our approved FY21 budget. Would these expenses for laptops, software, and cellular hot spots be reimbursable?
Possibly. If such expenses are in response to the public health emergency, represent an increase over previously budgeted amounts and are limited to what is necessary. A narrative justification will need to be provided as supporting documentation for reimbursement.

If employees do not have internet at home and are being asked to work from home to social distance with duties which require internet usage would an internet hotspot provided by the local government be reimbursable?
Possibly. If such expenses are in response to the public health emergency, represent an increase over previously budgeted amounts and are limited to what is necessary. A narrative justification will need to be provided as supporting documentation for reimbursement.

Could this funding be used to develop WIFI hotspots to facilitate distance learning?
Such expenditures would only be permissible if they are necessary for the public health emergency. The cost of projects that would not be expected to increase capacity to a significant extent until the need for distance learning and telework have passed due to this public health emergency would not be necessary due to the public health emergency and thus would not be eligible for reimbursement.

I noticed that "facilitating distance learning" is an eligible expense. There is a growing concern that schools may have to go to remote learning. This could impact workforce. Could funding through this program be used to pay for staffing from local organizations to assist students that have to remote learn at a facility so the parents don't have to choose between a job and their children?

Yes. Costs of educational support staff or faculty responsible for developing online learning capabilities necessary to continue educational instruction