CARES Act Funding

Frequently Asked Questions for Local Government

As part of the Coronavirus Aid, Relief, and Economic Security (CARES) Act, your municipality might be eligible for funding to be used to upgrade your technology to assist your response to the COVID-19 pandemic. What follows are frequently asked questions and guidance regarding CARES Act eligibility and reimbursements.

Note: This information is not intended as legal guidance. Please talk to your state representative for specific eligibility, utilization, and application details.

Update: Section 1001 extends the date by which state and local governments must make expenditures with CARES Act Coronavirus Relief Fund awards from Dec. 30, 2020, to Dec. 31, 2021.


Q. What is the CARES Act?

A. The Coronavirus Aid, Relief, and Economic Security (CARES) Act was passed by Congress and signed into law by President Trump on March 27, 2020. This over $2 trillion economic relief package provides fast and direct economic assistance for American workers, families, and small businesses, and preserves jobs for our American industries. It also established a $150 billion Coronavirus Relief Fund to provide payments to State, Local, and Tribal governments navigating the impact of the COVID-19 outbreak. As of June 2020, the U.S. Department of the Treasury (the Treasury) has made payments from the Fund to states and eligible units of local government; the District of Columbia and U.S. Territories (the Commonwealth of Puerto Rico, the United States Virgin Islands, Guam, American Samoa, and the Commonwealth of the Northern Mariana Islands); and Tribal governments.

Q. For what types of expenses can local governments utilize CARES Act funding?

A. The CARES Act requires that the payments from the Coronavirus Relief Fund only be used to cover expenses that:

1. Are necessary expenditures incurred due to the public health emergency concerning the Coronavirus Disease 2019 (COVID–19), and

2. Were not accounted for in the budget most recently approved as of March 27, 2020 (the date of enactment of the CARES Act) for the state or government, and

3. Were incurred during the period that begins on March 1, 2020, and ends on December 30, 2020.


Q. What is a “necessary expenditure?”

A. Expenditures must be used for actions taken to respond to the public health emergency by addressing medical or public health needs; or responding to second-order effects of the emergency. An expenditure will be deemed reasonably necessary for its intended use in the reasonable judgment of the government officials responsible for spending Fund payments.

Q. What does it mean for an expense to have been “incurred?”

A. According to the U.S. Treasury, for a cost to be considered to have been incurred, performance or delivery must occur during the covered period, but payment of funds need not be made during that time.

Q. How are funds being allocated?

A. Amounts paid to states, the District of Columbia, U.S. Territories, and eligible units of local government were based on population as provided in the CARES Act. The CARES Act directs the Treasury to use U.S. Census Bureau data for the most recent year for which data is available. The amount of any payments made to states was reduced by the aggregate amount of payments disbursed to eligible local governments within the state that provided the required certifications to the Treasury.

Q. What types of municipalities are eligible for federal funding?

A. A unit of local government eligible for receipt of direct payment included a county, municipality, town, township, village, parish, borough, or another unit of general government below the state level with a population that exceeds 500,000. Eligible local governments were required to submit the certification required by the CARES Act to the Treasury by 11:59 pm EDT on Friday, April 17, 2020, to receive payment.

Q. How can municipalities that did not receive direct funds apply for CARES Act funding?

A. The federal government distributed funding allotments to each state, which developed individual processes for distributing funds at the municipal level. Talk to your state representative for application guidance. You may need to submit a proposal for funding approval.

Q. Can municipalities use CARES Act funding to purchase software?

A. Yes. Per the terms of the CARES Act, local governments in need of software specifically to be used to help them respond to the COVID-19 health emergency may be eligible for CARES Act reimbursement, as long as the purchase was not accounted for in the municipality’s budget as of March 27, 2020, and the purchase is incurred between March 1 and December 30, 2020. Examples of software solutions that can help municipalities respond to citizen needs during the COVID-19 pandemic include:

  • Emergency mass notification software that allows for the distribution of alerts, warnings, and updated mandates
  • A content management system or low-code development software that supports the migration of manual workflows to digital services to enable remote citizen self-service
  • Live meeting software to enable remote participation by staff and citizens in public meetings
  • Cloud-based agenda and meeting management software to facilitate remote collaboration and approval on documents
  • Cloud-based employee management software to facilitate remote hiring, onboarding, and performance reviews
  • Cloud-based parks and recreation management software that enables contactless payment, online membership management, and online facility reservations and scheduling
  • Secure online payment gateway software
  • Mobile and online citizen request and work order management technology to facilitate business continuity of public works requests

Q. What can a municipality do to give itself the best possible chance of being approved for funding?

A. To put yourself in the best position to be eligible for funding:

1. Clearly state how the new software addresses your new needs for online administrative workflows and remote citizen access to government services. Start by explaining the specific challenges you are facing ensuring business continuity and citizen service during the COVID-19 crisis. Be sure to clarify how the hurdle is the direct result of the pandemic.

2. Next, describe how you intend to use the new software to ensure business continuity during the pandemic.

  • Describe any relevant software feature deficiencies that are creating barriers to accomplishing tasks
  • Explain what common features your existing software lacks that, if available, would expedite administrative workflows
  • If your need is to implement a new system, rather than replace an existing one, explain how the use of the software in place of manual, paper-based workflows will help you overcome challenges and better serve citizens.

3. Finally, specify the remaining two components critical to be eligible for funding:

  • That the technology purchase was not accounted for in the budget most recently approved as of March 27, 2020, and
  • That your goal is to incur costs associated with the purchase before December 30, 2020

Q. How long will CARES Act funding be Available?

A. CARES Act funding is available for eligible purchases, not previously budgeted for by March 27, 2020, to cover purchases made between March 1 and December 30, 2020. 

Q. Will CivicPlus® support multi-year agreements?

A. Yes, CivicPlus can accommodate requests for multi-year agreements, as long as your local procurement and contracting rules allow for multi-year agreements. Talk to your state representative for guidance on eligibility and maximizing reimbursement on such contracts. It is important to note that CARES funding may be used only for expenditures necessary to address the current COVID-19 public health emergency.

Q. Can a municipality apply for CARES Act funding for past expenses?

A. Past expenses may be eligible for CARES Act funding if they:

  1. Are Necessary expenditures incurred due to the public health emergency concerning the Coronavirus Disease 2019 (COVID–19) and
  2. Were not accounted for in the budget most recently approved as of March 27, 2020 and
  3. Were incurred during the period that begins on March 1, 2020

Q. Are other funding options available to support local governments’ COVID-19 response or mitigate associated financial burdens?

A. Yes. The federal government has issued the following COVID-19-related grants:

1. Emergency Management Performance Grant Program – COVID-19 Supplemental.

FEMA will award funding to support planning and operational readiness for COVID-19 preparedness and response, development of tools and strategies for prevention, preparedness, and response, and ongoing communication and coordination among federal, state, local, tribal, and territorial partners throughout the response. Read More >

2. Help America Vote Act (HAVA) Election Security Supplement.

Due to concerns among state and local election officials regarding the COVID-19 pandemic and its impact on upcoming primaries and the November general election, the U.S. Election Assistance Commission (EAC) is allowing the use of HAVA funds to cover costs municipalities are incurring as a result of the pandemic. Such expenditures include those necessary to protect the health and safety of poll workers, voters, and staff. Also, the Office of Management and Budget issued guidance on administrative relief for grantees impacted by the pandemic.
Read More >

3. Homeland Security Grant Program (HSGP).

(HSGP) plays an important role in the implementation of the National Preparedness System by supporting the building, sustainment, and delivery of core capabilities essential to achieving the National Preparedness Goal of a secure and resilient nation. The HSGP is comprised of three grant programs: State Homeland Security Program (SHSP), Urban Area Security Initiative (UASI), and Operation Stonegarden (OPSG). Read More >