![]() ![]() US Treasury provides further guidance in its FAQs, specifically FAQ 2.12: In its Interim Final Rule, US Treasury authorizes a county and municipality to expend ARP funds to support a vaccination incentive reward program. The ARP presents a slightly more complicated analysis. ARP Eligibility for Employee Vaccination Incentive Rewards This authority generally allows a local government to create an incentive program that includes current full and part-time employees that fall into both the newly vaccinated category (employees vaccinated after the incentive program launched) and the already vaccinated category (employees vaccinated before the incentive program launched), subject to the ARP limitations discussed below. ![]() There is broad state law authority for NC counties and municipalities to provide vaccination incentive rewards to current employees as employee fringe benefits. State Law Authority for Employee Vaccination Incentive Rewards In other words, local officials need to ensure that any proposed expenditure of ARP funds is authorized by state law and is allowable under the ARP. Using ARP Funds for Local Government Employee Vaccination Incentive RewardsĪs discussed in previous posts, North Carolina local governments must expend ARP funds for an ARP-eligible expense that the local government has state law authority to undertake. Things get more complicated if a local government wants to use ARP funds to also provide vaccination incentive rewards to employees who have already been vaccinated. US Treasury guidance indicates that a vaccination incentive reward program for not-yet-vaccinated employees is an ARP-eligible use. 1319 American Rescue Plan Act of 2021 (ARP) monies to fund the vaccination incentive rewards. I’ve been asked by several local officials whether they may use their Coronavirus State and Local Fiscal Recovery Funds of H.R. ![]() Incentives may take many forms-ranging from allowing an employee to take paid time off to receive the vaccine to providing bonuses, gift cards, gift certificates, or other tangible items (vaccination incentive rewards) to employees who provide evidence of vaccination. A related issue is how to pay for the vaccination incentives. Please visit our main category page to access more recent posts.įor local governments considering offering COVID-19 vaccination incentives to local government employees, my colleague Diane Juffras authored a comprehensive blog on the employment law issues here. Note that the information below has not been updated since the release of the Final Rule and some of it may no longer be accurate. (Treasury has also published these helpful resources: overview of the Final Rule and a Compliance and Reporting Guidance (updated 11/15/21).) As always, consult your local attorney with questions. Please review the Final Rule to learn more about the updated CSLFRF program requirements. The Final Rule makes several key changes to the Interim Final Rule, including expanding the eligible uses of CSLFRF and easing the administrative burden for some program requirements. Department of the Treasury issued the Final Rule, which governs the eligible uses of Coronavirus State and Local Fiscal Recovery Funds (“SLFRF”) under the American Rescue Plan Act (“ARPA”).
0 Comments
Leave a Reply. |