About COVID-19 Federal Funding
The federal government has enacted at least six pieces of legislation in response to the public health emergency caused by COVID-19. Three pieces of legislation were enacted in March 2020, the largest and most notable of which was the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”). This $2.2 trillion package included numerous initiatives, including but not limited to the Paycheck Protection Program (PPP), economic impact payments ($1,200 payments to qualified individuals), Economic Injury Disaster Loans (EIDL), Provider Relief Funds for health care providers, the Coronavirus Relief Fund (CvRF) for state and local governments, and an array of other new initiatives and expansions to existing programs. Additionally, the Consolidated Appropriations Act, 2021 was enacted on December 27, 2020. This law authorized $900 billion in additional COVID-related assistance.
Most recently, the American Rescue Plan Act of 2021 (“ARPA”) was signed into law on March 11, 2021. This law provides $1.9 trillion for continued COVID-19 response and recovery, including $350 billion for the Coronavirus State and Local Fiscal Recovery Funds.
Total Federal Awards to Massachusetts: $113 Billion
The federal government is expected to provide approximately $113 billion in aid to Massachusetts in response to the COVID-19 pandemic. Funding has been given to three groups: businesses and individuals, public entities, and Commonwealth agencies.
Businesses and individuals received about $51 billion through programs like the Paycheck Protection Program for businesses and stimulus checks for individuals.
Public entities other than Commonwealth agencies received about $10 billion through programs like the Coronavirus Local Fiscal Recovery Fund for municipal and county governments, and Federal Transit Authority grants to Regional Transportation Authorities.
Commonwealth agencies received about $49 billion, primarily to support COVID-related Unemployment Insurance benefits, expansions of existing programs like the Community Development Block Grant, and new programs like the Coronavirus Relief Fund and the Coronavirus State Fiscal Recovery Fund.
Additionally, new federally-administered initiatives like funding of COBRA coverage and the expansion of the child tax credit are expected to provide nearly $4 billion to Commonwealth residents.
The tool below summarizes funding directed to Massachusetts by major federal legislation in response to COVID-19. Use the arrows at the bottom to toggle between:
- A chart of funding provided by legislation and funding type; and
- A table view of funding provided to Massachusetts, with basic descriptive information, estimated amounts, and links for more information where available.
Total Federal Awards to Commonwealth Agencies: $49 Billion
(below chart updated weekly)
Of the $49 billion expected to be provided to Commonwealth agencies, about $33.7 billion is provided for a specific purpose, usually in the form of additional spending for existing programs. Most notably, this includes nearly $29 billion for COVID-related Unemployment Insurance benefits and administrative funding provided in the CARES Act and extended via the December 2020 stimulus package and the American Rescue Plan Act. Other key estimated funding streams include the Elementary and Secondary School Emergency Relief Funds ($2.6 billion); child care stabilization funding ($314 million), and the Homeowner Assistance Fund ($179 million).
The remaining $15.5 billion is comprised of funding sources that provide more discretion to the Commonwealth to determine how funds are spent. These include the Coronavirus State Fiscal Recovery Fund ($5.3 billion); the Coronavirus Relief Fund ($2.5 billion); the enhanced Federal Medical Assistance Percentage (FMAP), which is expected to generate approximately $2 billion; federal rental assistance of approximately $437 million; the Federal Emergency Management Agency’s Public Assistance grant program (expected to generate about $937 million); the Epidemiological and Laboratory Capacity grant program for testing and contact tracing (over $1.8 billion across several pieces of legislation); and other comparatively flexible programs.
The table below summarizes COVID-related federal funds expected to be provided to the Commonwealth (other than certain unique programs that have dedicated sections on this page, such as the Coronavirus State Fiscal Recovery Fund, the Coronavirus Relief Fund, and the FEMA Public Assistance program), and provides information about how the Commonwealth is spending these funds. This table is updated weekly.
Use the drop-down lists to filter for specific federal legislation, purposes, funding sources, or administering state agencies. Right-click on a funding source or use the button on the top right to view expenditure details. Click the arrows in the bottom right corner to view the table in full-screen mode.
Revenue maximization in an evolving federal environment
As the federal government issues guidance and new rounds of federal funds and as the priorities to respond to the pandemic change, A&F adapts its strategy for allocating funds in order to maximize the amount of federal funds available to the Commonwealth.
Most of the work associated with maximizing federal revenue happens retrospectively: an expense is incurred and allocated to an available state or federal funding source, but it may be reallocated later if a more appropriate funding source is identified. Spending may be reallocated between different federal funding sources, or between federal sources and state sources. Factors that A&F considers in matching spending with funding sources include: eligibility rules, spending deadlines, the availability of new funding sources, compliance risks, and other considerations.
About the Coronavirus State and Local Fiscal Recovery Funds
About the Coronavirus State and Local Fiscal Recovery Funds
The federal American Rescue Plan Act (ARPA) provided approximately $8.7 billion to Massachusetts through the new Coronavirus State and Local Fiscal Recovery Funds. The Commonwealth received $5.3 billion from the Coronavirus State Fiscal Recovery Fund (CSFRF). Municipalities and functional counties in the Commonwealth received $3.4 billion from the Coronavirus Local Fiscal Recovery Fund (CLFRF). Tribes in the Commonwealth received $25 million from the Coronavirus State and Local Fiscal Recovery Funds for Tribal Governments.
There are four categories of eligible uses for the CSFRF and CLFRF:
- Respond to the public health emergency with respect to COVID-19 or its negative economic impacts;
- Provide premium pay to employees providing essential work during the COVID-19 public health emergency;
- Provide government services to the extent of a government's reduction in revenue due to COVID-19; and
- Invest in water, sewer, or broadband infrastructure.
Funds are specifically prohibited from being used for:
- Offsetting tax cuts; or
- Public pension funds.
Coronavirus State Fiscal Recovery Fund: $5.3 Billion
On June 4, 2021, Governor Baker announced that $109 million in CSFRF funding would be distributed to four communities who are among the hardest-hit by the COVID-19 pandemic, and who received disproportionately small amounts of federal funding through the CLFRF compared to other hard-hit communities. These four communities are Chelsea, Everett, Methuen, and Randolph. Please see below for more information about CLFRF allocations to cities and towns in Massachusetts.
On June 7, 2021, A&F transferred $75 million in CSFRF to the COVID-19 Massachusetts Emergency Paid Sick Leave Fund. These funds will be used to reimburse eligible employers for providing paid sick leave for COVID-related illnesses, quarantine, and vaccinations.
On June 15, 2021, the Commonwealth launched the Massachusetts VaxMillions Giveaway, which is funded by CSFRF.
On June 28, 2021, Governor Baker signed legislation that transferred the remaining uncommitted CSFRF funds to the state's Federal COVID-19 Response Fund, which is subject to legislative appropriation. The legislation reserved $200 million for the administration to address critical needs as a result of the COVID-19 pandemic. Also on June 28, Governor Baker filed a plan to invest $2.9 billion in CSFRF funding to support key priorities including housing and homeownership, economic development and local downtowns, job training and workforce development, health care, and infrastructure. The remaining $2 billion would remain in the state’s Federal COVID-19 Response Fund, and the Administration looks forward to working closely with the Legislature to allocate these resources in a fiscally responsible and compliant manner.
On July 19, 2021, Governor Baker announced a plan to invest $186 million in CSFRF funding for critical priorities including support for hospitals, health and human services, mental health, and workforce development. This plan is part of the $200 million provided to the administration as described above.
On August 31, 2021, the Commonwealth filed its first annual Recovery Plan Performance Report with US Treasury, which can be accessed here: SFRF Recovery Plan Performance Report 2021. The report describes the Commonwealth's actual and planned uses of funds, as well as ongoing efforts to engage the community in deliberation on allocation of these funds, including discussion of the Governor's $2.9 billion proposal described above. The report also discusses potential approaches the Commonwealth might take to ensuring equity in the distribution of funding, incorporating evidence and evidence-based interventions into deploying the funds, and targeting services toward disproportionately impacted communities.
Additional information about the Commonwealth's use of these funds will be added to this page as it becomes available.
Coronavirus Local Fiscal Recovery Fund: $3.4 Billion
This section provides general information about the CLFRF. For resources for municipalities and counties on how to apply for CLFRF funding, please visit the Division of Local Services website.
Municipalities and counties in Massachusetts received $3.4 billion in CLFRF funding. Funding is allocated to municipalities and counties in several ways:
- Municipalities: ARPA identifies two ways of allocating CLFRF funding to municipalities, depending on whether the municipality is considered a “metropolitan city” by the federal government. Metropolitan cities are usually communities with a population of at least 50,000. Communities that are not metropolitan cities are called "nonentitlement units of government" (NEUs).
- The 38 metropolitan cities in Massachusetts received a combined $1.6 billion in CLFRF funding. Metropolitan cities must apply to the federal government for these funds.
- The 313 nonentitlement units of government (NEUs) in Massachusetts received a combined $385 million in CLFRF funding. NEUs must request these funds from the Commonwealth. The Commonwealth receives these funds from the federal government and passes them on to municipalities as requested, but the Commonwealth has no control over the allocation amounts, eligible uses, or other requirements of these funds.
- Counties: ARPA allocates CLFRF funding to all counties. In Massachusetts, however, many counties have been abolished and no longer have functioning local governments.
- The five functional counties in Massachusetts received a combined $393 million in CLFRF funding. Functional counties must apply to the federal government for these funds. Alternatively, functional counties may transfer their entire allocation to the Commonwealth. The Commonwealth has no ability to alter these allocations.
- The eight abolished counties and Nantucket County in Massachusetts were allocated a total of $946 million in CLFRF funding. The federal government has directed the Commonwealth to reallocate these funds to municipalities in the non-functional counties on a per capita basis. The Commonwealth has not yet received guidance from the federal government on the timing and process for distributing these funds.
The tool below displays CLFRF allocations by municipality and county. Use the arrows at the bottom to toggle between:
- A map view of allocations by municipality (including reallocations from non-functional counties);
- A table view of allocations by municipality; and
- A map and table view of allocations to functional counties.
About the Coronavirus Relief Fund
(below chart updated monthly)
The federal Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) provided Massachusetts with a total of approximately $2.7 B through the new Coronavirus Relief Fund (CvRF) to use for expenditures related to the COVID-19 public health emergency.
Payments from the CvRF may only be used to cover costs that:
• Are necessary expenditures incurred due to the public health emergency with respect to COVID–19;
• Were not accounted for in the budget most recently approved as of March 27, 2020 for the State or government; and
• Were incurred during the period that begins on March 1, 2020 and ends on December 31, 2021.
The City of Boston received approximately $121 M directly, and Plymouth County received approximately $91 M, leaving approximately $2.5 B for Commonwealth agencies and other local government entities in Massachusetts. The Commonwealth’s portion of the CvRF is being distributed across local entities (at least $761 M, of which $502 M is available to municipalities, with the remaining going to school districts, local housing agencies, local boards of health, and other local entities) and state agencies ($1.7 B).
Information about CvRF funding distributed to municipalities can be found in the municipalities section of this page.
CvRF Spending by State Agencies
The Commonwealth’s approach is to allocate the CvRF to respond to the public health emergency, provide economic support to businesses, and support local efforts to combat COVID-19.
The table below displays actual obligations and expenditures of CvRF by state agencies. This table is updated monthly.
Use the drop-down lists to filter for specific spending categories, purposes, payees, or state agencies. Click the arrows in the bottom right corner to view the table in full-screen mode.
About the FEMA Public Assistance Program
The Federal Emergency Management Agency (FEMA) provides funding for the Public Assistance (PA) Grant Program that reimburses state, local, and tribal governments, as well as certain types of private non-profit organizations for eligible costs incurred during a declared federal disaster. The COVID-19 pandemic was declared a federal major disaster in Massachusetts on March 27, 2020 with an incident period starting January 20, 2020 (DR-4496-MA).
Recent Changes to FEMA PA
There have been several changes to FEMA PA policies during the COVID-19 pandemic, which impact how much money entities approved for Public Assistance, which include state and local governments along with non-profit healthcare providers, will receive.
FEMA PA typically provides reimbursements at a cost share of 75 percent of total eligible costs, with the applicant being responsible for the remaining 25% (non-federal cost share). On January 21, 2021, the President of the United States issued a memo that instructed FEMA to increase the reimbursement rate for certain eligible COVID-19 costs submitted to FEMA PA from 75 percent to 100 percent for costs incurred between January 20, 2020 and September 30, 2021. On February 2, 2021, The President of the United States issued a second memo expanding the 100 percent reimbursement rate to all eligible emergency response costs.
Changing eligibility guidance:
The eligibility guidelines for FEMA PA have changed multiple times throughout the COVID-19 public health emergency, with the first notable change taking place in fall 2020. As a result of the fall 2020 changes, costs incurred by state and local governments that were presumed to be reimbursable were no longer eligible for FEMA PA. Most notably, PPE procured for use by public employees other than first responders (e.g., teachers or municipal administrative staff) and cleaning and sanitation costs for public buildings not used for direct responses to COVID-19 were determined to be ineligible for FEMA PA reimbursement.
However, a memo issued in February 2021 indicated that FEMA PA should cover costs incurred to facilitate the safe reopening and operation of all eligible facilities (once limited to health care and emergency work settings, now interpreted to include schools, public buildings, etc.). On April 5, 2021, FEMA issued Policy FP-104-21-0003 describing the impact of these changes on the program. Notably, the expanded eligibility guidelines highlighted in this April policy update only applied to expenses incurred between January 21, 2021 and September 30, 2021. Any expense incurred between January 20, 2020 and January 20, 2021 could still be reimbursed by FEMA at the revised rate of 100 percent; however, such expenses were subject to the FEMA PA eligibility standards that were in effect prior to this expansion.
In August 2021, President Biden issued an Executive Order that extends the expanded eligibility guidelines to cover the entirety of the disaster. This allows for retroactive 100% reimbursement of eligible safe opening and operating costs prior to January 2021, back to the beginning of the pandemic.
Expedited payment for vaccine distribution:
On January 25, 2021, FEMA issued a memo on prioritized approval for vaccine related costs. On February 4, 2021, the Commonwealth was approved for a $426 million application for funding to support vaccine distribution, of which fifty percent, about $213 million, was granted as an advance.
Impact of FEMA PA changes on the Commonwealth:
The Commonwealth has been approved for nearly $640 million in FEMA PA applications for state agencies as of August 2021. The new 100 percent reimbursement rate will result in an extra $160 million in reimbursement revenue for these applications compared to the 75 percent rate, as well as additional revenue associated with applications not yet submitted.
FEMA PA Awards Received by the Commonwealth
(below chart updated weekly)
The tool below provides information about FEMA PA applications that have been obligated to state agencies. Use the arrows at the bottom to toggle between:
- A pie-chart view of awarded amounts by category; and
- A table view of individual projects with awarded amounts and payment amounts.
In general, to receive FEMA reimbursement, the state, local, and tribal government, or private non-profit must incur costs, then complete a Streamlined Project Application in the FEMA Grants Portal, as well as upload sufficient documentation to submit the claimed costs. Once an applicant has submitted their application, FEMA will review the application and will scope and cost the project into a Project Worksheet (PW). Once the PW has progressed through each level of approval in the FEMA PA process, the applicant's PW is ultimately obligated.
The Massachusetts Emergency Management Agency (MEMA) is the Commonwealth’s applicant and primary point of contact with FEMA. All Massachusetts entities submit FEMA applications through the FEMA Grants Portal with assigned MEMA project coordinators to provide technical assistance throughout the life cycle of the grant. When a project is obligated, MEMA then receives the funds from FEMA and passes it through to the applicant if the applicant is not a state agency. FEMA reimbursement for state agencies is deposited in the general fund.
COVID-19 Funding Sources for Municipalities
Coronavirus Relief Fund Municipal Program (CvRF-MP)
(below map updated weekly)
The federal Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) provided Massachusetts with a total of approximately $2.5 billion through the new Coronavirus Relief Fund (CvRF) to use for expenditures related to the COVID-19 public health emergency.
The Commonwealth has made available up to approximately $502 M in CvRF funds to Massachusetts cities and towns through the Coronavirus Relief Fund Municipal Program (CvRF-MP). Funding for CvRF-MP is being distributed in three rounds.
- In Round 1, which occurred in May and June of 2020, 258 municipalities received approximately 95 million in payments.
- In Round 2, which occurred in October 2020, 267 municipalities received approximately $224 million.
- A third round, which is structured as a reimbursement “reconciliation period” round, is currently accepting applications until October 29, 2021.
What determines how much money a city or town gets?
- Total Eligible Amount – Each city or town is eligible for an amount of funding determined by its population (except for Boston and municipalities in Plymouth County, who received CvRF funds directly from the federal government). Click here for a list of the Total Eligible Amounts for each municipality.
- Eligible expenses – The federal government has rules for how CvRF money can be spent. Expenses must:
- Be necessary as a result of the COVID-19 public health emergency;
- Not be included in the city or town’s budget as of March 27, 2020; and
- Occur between March 1, 2020 and December 31, 2021.
Some municipalities may not request their Total Eligible Amount of funding because they do not have enough eligible expenses. The federal government does not allow CvRF funds to be used to make up for lost revenue.
Why have some towns spent more/less than they have received?
CvRF-MP started as an advance lump sum payment program. This meant that cities and towns requested funding in Round 1 and Round 2 of the program based on both reimbursement for expenses that had already occurred (on or after March 1, 2020), and anticipation of future expenses (initially through December 30, 2020 until recent federal legislation extended the deadline). Municipalities report actual spending to A&F on a quarterly basis.
The tool below displays CvRF-MP funding by municipality. Use the arrows at the bottom to toggle between:
- A map view of funding and expenditures by municipality;
- A table view of funding and expenditures by municipality; and
- A pie-chart view of expenditures by spending category.
Click the arrows in the bottom right corner to view the tool in full-screen mode.
This tool will be updated weekly until the program is concluded.
Overview of COVID-Related Federal Funds to Municipalities
In addition to funding received through Massachusetts’ Coronavirus Relief Fund – Municipal Program, municipalities have been recipients of various federal funds to respond to the COVID-19 pandemic. Some funds were distributed directly from the federal government to municipalities, while other sources flowed through the Commonwealth.
The tool below displays various federal funding sources distributed to municipalities. Use the arrows at the bottom to toggle between the map view and the table view. Click the arrows in the bottom right corner to view the tool in full-screen mode.
Further information about each funding source can be found below the tool.
ARPA Local Contingency: On June 4, 2021, Governor Baker announced that $109 million from the Coronavirus State Fiscal Recovery Fund would be distributed to four communities who are among the hardest-hit by the COVID-19 pandemic, and who received disproportionately small amounts of federal funding through the CLFRF compared to other hard-hit communities. These four communities are Chelsea, Everett, Methuen, and Randolph.
Assistance to Firefighters Grants (AFG): The Assistance to Firefighters Grant Program focuses on enhancing the safety of the public and firefighters with respect to fire and fire-related hazards. Supplemental funding in fiscal year 2020 provides financial assistance directly to eligible fire departments, non-affiliated emergency medical service organizations, and state fire training academies for critical personal protective equipment (PPE) and supplies needed to respond to the COVID-19 pandemic.
Community Development Block Grant (CDBG): The Massachusetts Community Development Block Grant Program is a federally funded, competitive grant program designed to help small cities and towns meet a broad range of community development needs. Massachusetts and entitlement municipalities received additional CDBG funding to support economic and community development efforts in response to the COVID-19 pandemic. Massachusetts allocated a portion of their CDBG dollars to non-entitlement communities that did not receive CDBG funding directly from the federal government.
Coronavirus Local Fiscal Recovery Fund (CLFRF): The federal American Rescue Plan Act (ARPA) provided $3.4 billion to municipalities and counties in the Commonwealth. Funds can be used to respond to the public health emergency, including negative economic impacts; to provide premium pay to essential workers; to replace lost revenue; or to invest in water, sewer, and broadband infrastructure. Please see above for additional information on CLFRF allocations.
Coronavirus Relief Fund Municipal Program (CvRF-MP): The CARES Act provided Massachusetts with a total of approximately $2.7 B through the new Coronavirus Relief Fund (CvRF) to use for expenditures related to the COVID-19 public health emergency. The Commonwealth has made available up to approximately $502 M in CvRF funds to Massachusetts cities and towns through the Coronavirus Relief Fund Municipal Program (CvRF-MP). Please see above for additional information about CvRF-MP and the Coronavirus Relief Fund.
Coronavirus Relief Fund (CvRF) – Boston/Plymouth: The City of Boston and Plymouth County received CvRF funds directly from the federal government. As a result, Boston and municipalities in Plymouth County do not receive funding through CvRF-MP.
Election Security Grants: Funding under the Help America Vote Act (HAVA) supports improvements to voting systems and voting access. Supplemental funds were provided under the CARES Act for Election Security Grants to help states prevent, prepare for, and respond to the coronavirus in the 2020 election cycle. Massachusetts has used the funds for costs of expanded voting by mail, costs of PPE and social distancing measures for in-person voting, and communications about changes in the voting process for both the state primary and the general election. Some of this funding was distributed to municipalities to address similar costs.
Emergency Solutions Grant (ESG): The Emergency Solutions Grant assists homeless households and households at risk of homelessness by supporting the services necessary to help them quickly regain stable housing after experiencing a housing crisis. Massachusetts and eligible municipalities received additional ESG funding to support homelessness services in response to the COVID-19 pandemic.
FEMA Reimbursement: The Federal Emergency Management Agency (FEMA) provides funding for the Public Assistance (PA) Grant Program that reimburses state, local, and tribal governments, as well as certain types of private non-profit organizations for eligible costs incurred during a declared federal disaster. Costs related to the COVID-19 public health emergency are being reimbursed at 100 percent for costs incurred between January 20, 2020 and September 30, 2021.
Housing Opportunities for Persons with AIDS (HOPWA): The HOPWA program provides housing assistance for people living with HIV/AIDS. The supplemental funds provided under the CARES Act are to be used by HOPWA grantees to maintain operations and to fund rental assistance, supportive services, and other necessary actions in response to the COVID-19 pandemic.
Justice Assistance Grants (JAG): The Coronavirus Emergency Supplemental Funding (CESF) Program provided additional Justice Assistance Grant (JAG) funding to assist eligible states, local units of government, and tribes in preventing, preparing for, and responding to the coronavirus. Eligible expenditures included overtime, equipment, hiring, supplies, training, travel expenses, and addressing medical needs of inmates. Some municipalities received funding directly through the federal program; others were able to apply for funding through the Massachusetts Executive Office of Public Safety and Security.
Shared Streets Program: Partially funded through the Coronavirus Relief Fund, the Massachusetts Department of Transportation’s Shared Streets and Spaces program provided grants as small as $5,000 and as large as $300,000 for cities and towns to quickly implement or expand improvements to sidewalks, curbs, streets, on-street parking spaces and off-street parking lots in support of public health, safe mobility, and renewed commerce in their communities.
COVID-19 Funding Sources for Local Education Agencies
Overview of COVID-Related Federal Funds to Local Education Agencies (LEAs)
Similar to municipalities, school districts and other Local Education Agencies (LEAs) in Massachusetts have received various federal funds to respond to the COVID-19 pandemic. Most of these funds are distributed via the Commonwealth's Department of Elementary and Secondary Education (DESE) to support both distance learning and school reopening costs.
The tool below shows the federal funding distributed to LEAs. Use the arrows at the bottom to toggle between the map view and the table view. Click the arrows in the bottom right corner to view the tool in full-screen mode.
Further information about each funding source, as well as links to additional resources about these programs, can be found below the tool.
Elementary and Secondary School Emergency Relief Fund (ESSER): The ESSER I Fund, authorized under section 18003 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), provides districts with emergency relief funds to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools. Districts must provide equitable services to students and teachers in non-public schools as required under the CARES Act.
The Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act provides supplemental funding through the ESSER II Fund. This funding is intended to help school districts safely reopen schools, and measure and effectively address significant learning loss. In addition, in an effort to build capacity of public school districts and communities to facilitate integrated coordination of school and community-based resources, DESE is providing an additional $10,000 to each district for student mental health services and supports.
The American Rescue Plan Act (ARPA) provides a third round of funding for ESSER (ESSER III). ESSER III requires that LEAs spend 20 percent of funding to address learning loss, and includes new maintenance of equity provisions.
Remote Learning Technology Essentials Grants: The purpose of the competitive Remote Learning Technology Essentials Program is to provide supplemental funds to support LEAs in addressing remaining remote learning technology needs and to ensure that every student has adequate access to technology for use in remote learning environments during the 2020-21 school year. Funds under this program, in addition to those made available under other federal grant programs, may be used to support technology needs addressed following the March 13, 2020 COVID-19 emergency.
School Reopening Grants: The purpose of the Coronavirus Relief Fund (CvRF) School Reopening Grants is to provide eligible school districts and charter schools with funding to support costs to reopen schools. This funding of $225 per student based on FY2021 foundation enrollment is intended to supplement other resources that the Governor is providing to cities and towns for COVID-19 response efforts as well as funds made available by DESE through the Elementary and Secondary School Emergency Relief Fund (ESSER) grants and the Remote Learning Technology Essentials (RLTE) grants.
Compliance with COVID-19 Federal Funding
FFO’s Role in Compliance
The Commonwealth of Massachusetts Executive Office for Administration and Finance (A&F) Federal Funds Office (FFO) has been charged by the Governor with overseeing COVID-related federal funding in a manner that optimizes federal funding, targets the administration’s priorities, and minimizes compliance risk.
Since its inception in late spring 2020, FFO has developed a multi-faceted compliance strategy for COVID-related federal funding. FFO recognizes the impact of COVID-19, including tightened budgets, new responsibilities driven by the pandemic, and a shift to working in a virtual environment. These impacts bring various challenges, such as:
- Management of a virtual team;
- New fraud and compliance risks;
- New review of cybersecurity infrastructure;
- New methods and procedures to conduct compliance monitoring;
- New digital structures to document compliance and maintain records for audit and meet record retention requirements; and
- Evolving federal guidance related to COVID fund reporting and compliance.
FFO also recognizes the Commonwealth and subrecipients have common goals, including:
- Providing necessary services to residents that meet their needs during this emergency;
- Maximizing those services while minimizing fraud, waste, and abuse;
- Preventing misuse of funds through heightened scrutiny and clear communication of rules and regulations related to federal funds; and
- Ensuring funds are recorded and documented accurately and transparently.
To meet these common goals and address shared challenges, FFO’s compliance strategy has centered on:
- Ensuring compliance with the Coronavirus Relief Fund (CvRF); and
- Providing best practices on federal grants management to ensure that Commonwealth agencies and subrecipients are well-positioned for different types of future audits
With the passage of the American Rescue Plan Act (ARPA), FFO will continue this strategy with an additional focus on compliance with the Coronavirus State Fiscal Recovery Fund.
Compliance with the Coronavirus Relief Fund
The Commonwealth of Massachusetts received approximately $2.5 B in aid from the federal Coronavirus Relief Fund (CvRF), which is being administered by the US Department of the Treasury. The Department of the Treasury Office of Inspector General (OIG) is responsible for monitoring and oversight of the receipt, disbursement, and use of CvRF payments as authorized by the CARES Act. Treasury OIG was also assigned authority to recover funds if it is determined a recipient of a CvRF payment failed to comply with requirements of the CARES Act.
Coronavirus Relief Fund Guidance
CvRF is designed to provide ready funding to address unforeseen financial needs and risks created by the COVID-19 public health emergency. Treasury has provided detailed guidance and FAQs on eligible uses of CvRF which have been revised multiple times since the onset of the public health emergency. Broadly, governments may use Fund payments for eligible expenses subject to the restrictions set forth in section 601(d) of the Social Security Act. Payments must be used to cover costs that are:
- Necessary expenditures incurred due to the public health emergency with respect to COVID-19;
- Not accounted for in the governments’ most recently approved budgets as of March 27, 2020; and
- Incurred during the period that begins on March 1, 2020 and ends on December 31, 2021.
Necessary due to COVID-19
Expenditures must be used for actions taken to respond directly to the public health emergency or to second order effects caused directly by the public health emergency. Provided examples 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.”
The statute also specifies that expenditures using Fund payments must be “necessary.” Treasury understands this term 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. Thus, expenditures must not only be necessary to respond to the public health emergency, but must be necessary in light of all options available to a government to respond to the particular necessity at hand.
Unbudgeted as of March 27, 2020
A cost meets the requirement of “costs not accounted for in the budget most recently approved as of March 27, 2020” if either (a) the cost cannot lawfully be funded using a line item, allotment, or allocation within that budget or (b) the cost is for a substantially different use from any expected use of funds in such a line item, allotment, or allocation.
Incurred during the Eligible Period
Costs incurred prior to March 1, 2020 are not eligible uses of CvRF even if the payment itself was not necessary until the eligible period. Similarly, costs that will not be incurred until after the eligible period are not eligible uses of CvRF.
Prepayment of costs is only allowable if supported by documentation that such payments are the standard business practice of a government or other recipient.
Treasury OIG has provided guidance on oversight and reporting of CvRF. Recipients of CvRF payments are required to maintain and make available to the Treasury OIG upon request all documents and financial records sufficient to establish compliance with the CARES Act. To facilitate this process, the Federal Funds Office is requiring state agencies and their subrecipients to supply documentation upon request that demonstrates CvRF funds have been used in an eligible manner. Records to support compliance with the CARES Act may include, but are not limited to, copies of the following:
- General ledger and subsidiary ledgers used to account for (a) the receipt of Coronavirus Relief Fund payments and (b) the disbursements from such payments to meet eligible expenses related to the public health emergency due to COVID-19;
- Budget records for 2019 and 2020;
- Payroll, time records, and human resource records to support costs incurred for payroll expenses related to addressing the public health emergency due to COVID-19;
- Receipts of purchases made related to addressing the public health emergency due to COVID-19;
- Contracts and subcontracts entered into using Coronavirus Relief Fund payments and all documents related to such contracts;
- Grant agreements and grant subaward agreements entered into using Coronavirus Relief Fund payments and all documents related to such awards;
- All documentation of reports, audits, and other monitoring of contractors, including subcontractors, and grant recipient and subrecipients;
- All documentation supporting the performance outcomes of contracts, subcontracts, grant awards, and grant recipient subawards;
- All internal and external email/electronic communications related to use of Coronavirus Relief Fund payments; and
- All investigative files and inquiry reports involving Coronavirus Relief Fund payments.
Coronavirus Relief Fund Desk Reviews
Since the inception of the CARES Act Coronavirus Relief Fund – Municipal Program (CvRF-MP), the Executive Office for Administration and Finance (A&F) has received applications from 315 municipalities. A&F has distributed nearly $350 million and the CvRF-MP is to be closed out this fall. As a prime recipient of CvRF funds, the Commonwealth has an obligation to report to the federal government quarterly about the Commonwealth’s disbursements and uses of CvRF proceeds. In order to ensure funds are being spent appropriately; accurate and quality federal reporting; and compliance with sub-recipient monitoring policy guidance of the Commonwealth’s Office of the Comptroller, the Federal Funds Office (FFO) has been conducting desk reviews of CvRF-MP expenditures since December 2020.
The following summary outlines ANF’s objective and methodology for these reviews.
The objective of the desk review is to evaluate the sub-recipient, or municipal, documentation supporting the uses of CvRF proceeds as reported to the FFO, and assess internal controls, the risk of unallowable use of funds, or any risk of fraud, waste, or abuse.
Desk Review Scope and Methodology
To ensure a representative and thorough sample, the FFO samples a percentage of municipalities from groups of municipalities segmented by total eligible amount of CvRF funds. In total, the FFO will sample approximately one-third of eligible municipalities across four rounds of desk reviews.
For each municipality selected for a desk audit, the FFO randomly selects one reported expenditure item for review. Upon selection, municipalities are notified through a letter, requesting them to send an invoice and other documentation that demonstrates CvRF eligibility and supports information reported to the FFO. If a payroll expenditure is selected, corresponding timesheets are requested.
Upon receipt of documentation, FFO evaluates the recipient’s framework for federal funds management including recordkeeping, documentation, and control structure. FFO also tests for assurance that relevant state and municipal policies are being applied. FFO requests follow-up documentation, or a meeting as needed, with the municipalities before issuing desk review results.
If there are findings on compliance with CvRF, the FFO team will initiate a formal remediation process to ensure enhanced policies and procedures are incorporated moving forward and recommend compliance best practices.
For more information about this process please contact the Assistant Director of Federal Funds for Compliance, Brendan Dutch.
Summary of Desk Reviews to Date
Desk reviews have been ongoing since December 2020 and thus far have included 38 municipalities across the Commonwealth, totaling $36.3 M in CvRF. Through this process FFO has identified some weaknesses in municipal federal funds management that are largely attributable to the fluid nature of federal guidance. FFO is working with these municipalities to introduce more robust internal controls and ensure effective fund management. When there are instances of Compliance concerns, the municipalities are expected to work with FFO to correct reporting and management deficiencies in order to avoid recoupment of their awards for non-compliance.
Federal Grants Management Best Practices
FFO has held a number of webinars and compiled various materials to support agencies and municipalities in managing COVID-related stimulus funds.
Compliance Resources for Municipalities
- Municipal Compliance Webinar Deck
- Webinar Recording
- Municipal CvRF Guidance & FAQs
- Compliance Preparation – To prepare for long-term compliance activities related to federal funds, municipalities should lean on existing systems, policies, and procedures.
- Internal controls best practices – To properly manage federal funds, municipalities should ensure strong internal controls plans are in place
- Risk management best practices – The pandemic work environment combined with the new demands imposed by the virus response increase and pose new risks to government service delivery.
- Other Resources
Compliance Materials for State Agencies
- Internal Controls Best Practices
- Other Resources
- Office of the Comptroller COVID-19 Revenue and Grants
- Office of the Comptroller Internal Control Plan Update Guidance
- Office of the Comptroller Internal Control Guide
- Office of the Comptroller Cyber Security Tips
- AGA's Internal Control Tool
- AGA's Fraud Prevention Tool
- AGA's Subrecipient Monitoring Guide
- Office of the Comptroller Subrecipient Monitoring Policy
State House, Room 373
Boston, MA 02133