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Vermont 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 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 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 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...
Vermont State Auditor

COVID-19 Audit Provisions

Memorandum: The Office requests the legislature add an explicit requirement in all future bills authorizing the expenditure of COVID-19 funds. The State Auditor’s Office must have access to records that relate to eligibility for and use of economic recovery grant funds.
Vermont State Auditor

S.350 Memo

Memorandum: There is desire to inject the CARES Act funding into the community as soon as possible. However, some aspects of this bill raise concerns about risk that deserve your consideration. Creating the program and appropriating $50 million before the Tax Department has established “a formula for determining the amount of grant awards” is a significant delegation of authority without any guidance.
Vermont State Auditor

Proposed Vermont Economic Injury Disaster Loan Program

Memorandum: The recently issued U.S. Treasury Coronavirus Relief Fund FAQ1 has implications for the Governor’s proposed Economic Injury Disaster Loan (EIDL) program. As proposed, the Vermont EIDL program to be administered by the Vermont Economic Development Authority (VEDA) establishes a perpetual revolving loan fund. However, the FAQ indicates that all loan repayments subsequent to December 30, 2020 must be returned to the U.S. Treasury.
Vermont State Auditor

Office of the State Auditor’s Focus on COVID-19 Expenditures

Memorandum: Auditor Office has begun to examine the State's distribution and spending of more than $1.3 billion of federal funding that has been or is expected to be received via the federal pandemic response/stimulus acts – including the CARES Act.
Vermont State Auditor

Risk Alert – State Governmental Entities Seeking Small Business Administration Payroll Protection Program Loans

Memorandum: The state recognized that some sheriff departments sought and received loans through SBA. Other state governmental entities may have also received PPP loans or may be considering applying for them.