Making Sense of the CARES, CRRSA, and ARPA Acts
In response to the 2019 Novel Coronavirus (COVID-19), the United States Congress passed the Coronavirus Aid, Relief, and Economic Security Act of 2020 (P.L. 116-136), also known as the CARES Act, to relieve the pandemic’s financial impacts. It included over $2 trillion in direct assistance to government entities, small business, and individuals.
Title V of the CARES Act created the Coronavirus Relief Fund. This Fund provided $150 billion in direct assistance to state, local, and tribal governments.
Between 2020-2021, Congress passed the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSA) and the American Recovery Plan Act (ARPA), which authorized additional funds to expand direct assistance programs nationwide.
COVID-19 Relief Funding may only be applied to expenditures which are deemed "necessary", were incurred due to the public health emergency caused by COVID-19, and were not accounted for in the most recently approved budget (as of March 27, 2020 when the CARES Act was signed into law).
The Federal government is a significant source of grant and other assistance funding to state, local, and tribal governments. Federal regulations lay out requirements to ensure that all recipients of federal financial assistance appropriately monitor and manage federal fund use.
The Coronavirus Relief Fund qualified as “other financial assistance” under the federal financial assistance categories in the federal regulations (U.S. Dept. of Treasury, 2020a). As such, requirements of the Single Audit Act and Uniform Guidance – specifically regarding internal controls, subrecipient monitoring and management, and audit requirements – apply.