Commerce issues additional guidance for CARES CRF reimbursements

To ensure timely reimbursements to cities using CARES Coronavirus Relief Funds (CRF), the Department of Commerce issued new detailed guidance on how to properly submit invoices.

The following information was provided by Tony Hanson, Deputy Assistant Director at the Department of Commerce:

The detailed breakdown

Every invoice must be accompanied with three documents in order to be processed for payment by Commerce. Those three documents are:

1. A completed A-19 certification form;
2. A completed A-19 activity report; and
3. A detailed breakdown of the costs submitted.

Documents 1 and 2 are templates provided by Commerce that need to be completed by local governments. Document 3, the detailed breakdown, is not a Commerce template and seems to be the area that causes the most delays in reimbursement.

So, what is Commerce looking for with a detailed breakdown of costs? Commerce needs to see a document that lists the individual costs that add up to the total amounts reported on the A-19 activity report, under each corresponding sub-category.

Example: A Grantee submits an A-19 activity report that requested reimbursement of $150.50 as follows:

The detailed breakdown for this activity report would list all of the individual costs that totaled the $100 submitted under 2B as well as the individual costs that totaled the $50.50 submitted under 3D, such as:

It needs to clearly demonstrate how the amounts submitted on the A-19 activity report were calculated. This document can be a PDF or Excel spreadsheet, but the expenses listed should be generated from your accounting system. Consider including the following expense information:

• Expense date
• Expense description or title
• Amount, the corresponding A-19 activity report category/sub-category (i.e. 2B, 3D, etc.)
• A transaction number or similar identifier to easily locate the expense within your accounting system

If you have concerns with reporting the information described, don’t hesitate to contact your Commerce Project Manager. We will work with you to determine other options.

Activity report – Budget category 6, other

There are five primary budget categories listed on the A-19 activity report. Almost all eligible expenses should fall under one of these five budget categories. They are:

1. Medical expenses
2. Public health expenses
3. Payroll expenses for public employees dedicated to COVID-19
4. Expenses to facilitate compliance with COVID-19 measures
5. Economic supports

Budget category 6 is for other expenses that don’t fall under categories 1-5. There should seldom be an expense that doesn’t fit somewhere under categories 1-5. Commerce included budget category 6 as an option assuming that there may be a few rare instances where an eligible expense just doesn’t fit under any of the other categories. Commerce anticipated that category 6 would hardly be used, if at all, but that doesn’t seem to be the case and previous guidance has not been clear on the matter.

However, this category is being heavily used. So far, we have not seen an expense submitted under budget category 6 that couldn’t fit under a different budget category. Commerce will be working with grantees to resubmit corrected A-19 activity reports, if expenses are reported under budget category 6 that could have been reported under another category.

Commerce wants to try our best to capture the expenditure data in a way that tells the most accurate story and gives the best information on how these funds are being utilized. Expenditures that are reported under budget category 6 start to get lost and can skew the data. Especially when there are expenses listed under budget category 6 that belong in another category. Then we start to lose part of the story and the usefulness of the data becomes less meaningful. By limiting the use of this category, it will help strengthen the quality of the spending data.

Your help addressing these two items will help Commerce process invoices more quickly and be able to tell a clearer story of what our state is doing with this resource.

For any questions, please contact:
Tony Hanson, Deputy Assistant Director
Department of Commerce, Local Government Division
tony.hanson@commerce.wa.gov
Phone: (360) 725-3005