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AS OF JUNE 24, 2021 <br />Similarly, pre -project development uses and costs for broadband projects should be tied <br />to an eligible broadband project or reasonably expected to lead to such a project. For <br />example, pre -project costs associated with planning and engineering for an eligible <br />broadband infrastructure build -out is considered an eligible use of funds, as well as <br />technical assistance and evaluations that would reasonably be expected to lead to <br />commencement of an eligible project (e.g., broadband mapping for the purposes of <br />finding an eligible area for investment). <br />Al! funds must be obligated within the statutory period between March 3, 2021 and <br />December 31, 2024, and expended to cover such obligations by December 31, 2026. <br />7. Non -Entitlement Units (NEUs) <br />Answers to frequently asked questions on distribution of funds to NEUs can be found in <br />this FAQ supplement, which is regularly updated. <br />8. Ineligible Uses <br />8.1. What is meant by a pension "deposit"? Can governments use funds for routine <br />pension contributions for employees whose payroll and covered benefits are eligible <br />expenses? <br />Treasury interprets "deposit" in this context to refer to an extraordinary payment into a <br />pension fund for the purpose of reducing an accrued, unfunded liability. More <br />specifically, the interim final rule does not permit this assistance to be used to make a <br />payment into a pension fund if both: (1) the payment reduces a liability incurred prior to <br />the start of the COVID-19 public health emergency, and (2) the payment occurs outside <br />the recipient's regular timing for making such payments. <br />Under this interpretation, a "deposit" is distinct from a "payroll contribution," which <br />occurs when employers make payments into pension funds on regular intervals, with <br />contribution amounts based on a pre -determined percentage of employees' wages and <br />salaries. In general, if an employee's wages and salaries are an eligible use of Fiscal <br />Recovery Funds, recipients may treat the employee's covered benefits as an eligible use <br />of Fiscal Recovery Funds. <br />8.2. May recipients use Fiscal Recovery Funds to fund Other Post -Employment Benefits <br />(OPEB)? [6/8] <br />OPEB refers to benefits other than pensions (see, e.g., _Governmental Accounting <br />Standards Boarcl, "Other Post-Emplarnent Benefits"). Treasury has determined that <br />Sections 602(c)(2)(B) and 603(c)(2), which refer only to pensions, do not prohibit <br />CSFRF/CLFRF recipients from funding OPEB. Recipients of either the CSFRF/CLFRF <br />may use funds for eligible uses, and a recipient seeking to use CSFRF/CLFRF funds for <br />27 <br />