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Immediate Action Required to Obligate COVID-19 Stimulus Funding Before December 31, 2024

By Keeley Ann Hines, Gregg Evans, on November 5th, 2024

As the world continues to recover from the unprecedented impacts of the COVID-19 pandemic, governments are faced with the critical task of obligating available stimulus funding effectively before the deadline of December 31, 2024. The need to allocate these resources efficiently is not only imperative to support sustained economic recovery, enhance public health infrastructure, and ensure long-term resilience against future crises, but to ensure each local government is able to take full advantage of their allocated awards.

To meet the definition of an obligation as of December 31, 2024, for COVID-19 funding spending by a government, several criteria must be satisfied. First, the government must have a legally binding agreement in place, such as a contract or agreement, which specifies the terms and conditions under which the funds will be used. This agreement should clearly outline the scope of work, deliverables, and timelines for the expenditure. The definition of an obligation is not by met adopting a budget, passing a resolution, or a written or oral intention to enter into a contract.

Second, there must be documented evidence that the government has taken concrete steps to commit the funds. This can include issuing signing contracts or interagency agreements, and/or making formal commitments to third-party vendors or service providers. Additionally, the funds should be accounted for in the government’s financial system, ensuring transparency and accountability in the allocation and use of the resources.

Lastly, the government should regularly monitor the progress of the funded projects to ensure that the obligations are being met and that the funds are being utilized effectively, efficiently, and timely in accordance with documented commitments.

Failure to obligate COVID-19 stimulus funds by the December 31, 2024, deadline could have significant consequences. Unspent funds may be subject to reallocation or claw back by the federal government, meaning that local governments could lose out on critical resources intended to support their recovery efforts. This would not only hinder the progress of ongoing projects but also limit future opportunities for economic development and public health improvements.

Moreover, the inability to obligate the funds could signal inefficiencies in the local government’s financial management and planning processes. This could lead to a loss of public trust and confidence in the government’s ability to manage resources effectively. It might also result in increased scrutiny from oversight bodies and could potentially impact future funding allocations from federal or state sources.

Therefore, it is imperative for governments to take proactive measures to ensure that all available stimulus funds are obligated within the stipulated timeframe. By doing so, they can maximize the impact of these resources, foster sustainable development, and ensure a more equitable and robust recovery for all citizens.

If you need further guidance or have any questions on this topic, we are here to help. Please do not hesitate to reach out to discuss your specific situation.

This material has been prepared for general, informational purposes only and is not intended to provide, and should not be relied on for, tax, legal or accounting advice. Should you require any such advice, please contact us directly. The information contained herein does not create, and your review or use of the information does not constitute, an accountant-client relationship.

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