The U.S. Treasury published more guidance on the funding stating that a per capita distribution of funds was not allowable. It further explained that direct citizen assistance should have a determination process.
‘Governments have discretion to determine how to tailor assistance programs they establish in response to the COVID-19 public health emergency,’ the document said. ‘However, such a program should be structured in such a manner as will ensure that such assistance is determined to be necessary in response to the COVID-19 public health emergency and otherwise satisfies the requirements of the CARES Act and other applicable law.’
‘For example, a per capita payment to residents of a particular jurisdiction without an assessment of individual need would not be an appropriate use of payments from the Fund.’
Guidelines indicated that governmental entities could distribute relief through programs and would have scope and authority to shape programs to fit their needs.