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Vermont Office of the State Auditor
Use of Federal Tax Loss For Purposes of Businesses’ Eligibility for COVID-19 Financial Assistance
The program guidance issued by ACCD on April 27, 2021 for the Economic Recovery Bridge Grant program uses 2020 federal tax loss to establish eligibility for grants consistent with the requirements of H.315 (Act 9). Focusing on tax loss may help target limited resources to businesses that need assistance to remain viable. However, clarification is needed in the program guidance to avoid reliance on a tax-based measure that is not representative of losses associated with the COVID-19 public health emergency and to prevent grant awards that exceed business need.
Vermont Office of the State Auditor
Use of Federal Tax Loss for Purposes of Business Eligibility for COVID-19 Financial Assistance
The Economic Recovery Bridge Grant program in H.315 uses 2020 federal tax loss to establish eligibility for grants. Focusing on tax loss may help target limited resources to businesses that need assistance to remain viable. However, federal tax loss could include some deductions that increase 2020 losses but overstate the businesses’ need for financial assistance.
Vermont Office of the State Auditor
Proposed Gap Recovery Grants
Similar to the Economic Recovery Grant (ERG) programs, the Gap program requires that businesses demonstrate economic loss due to COVID-19 but does not define economic loss. If ACCD uses revenue loss to measure economic loss for businesses that were in operation prior to the pandemic, the Gap program will be exposed to the same risk the Joint Fiscal Office pointed out in its November 2020 memo to the Joint Fiscal Committee regarding the ERG program.
Vermont Office of the State Auditor
Guidelines for Vermont Emergency Economic Recovery Grants
Act 115 of 2019 established the Vermont Emergency Economic Recovery Grants program and affords the Agency of Commerce and Community Development (ACCD) and the Department of Taxes (Department) significant discretion for developing guidelines to implement the $152 million program, but the law also requires certain procedures and standards. The guidelines developed by ACCD and the Department – specifically the first-come, first-served distribution of public dollars and the absence of an evaluation of need in the application process – may not be consistent with the legislation. This approach does...