Updated May 28, 2020
The U.S. Treasury Department has announced some critical deadlines for tribal relief under the Coronavirus Aid, Relief, and Economic Security (CARES) Act. The application portal for the final $3.2 billion in funds is scheduled to open on May 20; tribal relief applications must be submitted by May 29. Distribution of COVID-19 funds will take place on or around June 5. Treasury will decide the final distribution formula after the application data is received.
Tribal governments that want to participate in the next round of distributions must submit proof of their total employees and 2019 expenditure data upfront before being considered for relief. IRS Form 941 from each quarter of calendar year 2019 will be used as the basis for number of employees. Information being evaluated includes employees that work for the Tribal government directly and employees that work for any entity where the Tribal government holds at least a 51 percent ownership interest.
During a forum co-hosted by the Native American Finance Officers Association (NAFOA), tribal leaders expressed concerns over privacy and having to submit their financial information up front. Another area of concern is the fact that inconsistent sources of population data from federal agencies and the U.S. Census may be used unfavorably against tribes to point out discrepancies in application data.
Tribal governments must also enter â€œTotal governmental expendituresâ€ and â€œTotal amount of federal financial assistanceâ€ for the 12 months of the 2019 fiscal year into the application portal.
â€œGiven what a lifeline this money will be to continue government functions and provide services to tribal members, itâ€™s imperative to provide accurate, certifiable data,â€ advises Corrine Wilson, REDW Principal and National Tribal Practice Leader.
REDW can help tribes prepare or review the financial worksheet that must be submitted, with the underlying support for how the dollar amounts are derived. Our firm can also help tribes select the best links or relevant pages from financial documents to support the figures. For your questions, we urge tribal financial leaders to contact Corrine Wilson by email or at 602.730.3609.
Increase your knowledge of the compliance and possible tax considerations to expending these funds and avoid potential missteps — or access REDW’s on demand stream for our webinar: â€œCompliance for Federal Funding under the CARES Act â€“ Including Tax Considerationsâ€ that took place Friday, May 22. Corrine Wilson co-presented with attorney Mary Streitz of Dorsey & Whitney.
Click here for more guidance from Treasury on the application process.
REDW is committed to keeping you informed at all times, but especially during a crisis of the magnitude of the COVID-19 pandemic.Â Stay connected with us onÂ LinkedInÂ andÂ @REDWLLC. Or check out some of our other updatesÂ here.