On December 20, 2023, GFOA along with the National Association of Counties (NACo) and the National League of Cities (NLC) submitted comments in response to the U.S. Treasury’s Interim Final Rule (IFR)to amend the definition of “obligation” with respect to the Coronavirus State and Local Fiscal Recover Fund (SLFRF). The IFR primarily focused on three issues: amending the definition of obligation with respect to costs associated with compliance and recordkeeping, the application of the obligation deadline to subrecipients, and the amendment and replacement of contracts and subawards. In the collective comments, GFOA expressed concerns with the increased limitation the definition of obligation the IFR creates, as well as the IFR not allowing for the pre-obligation of salaries for programmatic staff not associated with compliance and recordkeeping, among other issues.

• Publication date: December 2023