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simple metric with readily available maps for use. However, Treasury recognizes that QCTs do <br />not capture all underserved populations, including for reasons noted by commenters. By allowing <br />recipients to also presume that low-income households were disproportionately impacted, the <br />final rule provides greater flexibility to serve underserved households or communities. Data on <br />household incomes is also readily available at varying levels of geographic granularity (e.g., <br />Census Tracts, counties), again permitting flexibility to adapt to local circumstances and needs. <br />Finally, Treasury notes that, as discussed further below, recipients may also identify other <br />households, populations, and communities disproportionately impacted by the pandemic, in <br />addition to those presumed to be disproportionately impacted. <br />Additionally, Tribal and territorial governments may face both disproportionate impacts <br />of the pandemic and administrability challenges with operationalizing the income -based <br />standard; therefore, Treasury has presumed that services provided by these governments respond <br />to disproportionate pandemic impacts. Given a lack of regularly published data on household <br />incomes in most territories,32 as well as a lack of poverty guidelines developed for these <br />jurisdictions,33 it may be highly challenging to assess disproportionate impact in these <br />communities according to an income- or poverty -based standard. Similarly, data on incomes in <br />Tribal communities are not readily available.34 Finally, as described in the sections on Public <br />Health and Negative Economic Impacts, Tribal communities have faced particularly severe <br />health and economic impacts of the pandemic. Similarly, available research suggests that <br />32 For instance, the American Community Survey does not include all territories. U.S. Census Bureau, Areas <br />Published, https://www.census.gov/programs-surveys/acs/geography-acs/areas-published.html (last visited <br />November 9, 2021). <br />33 U.S. Department of Health and Human Services, supra note 19. <br />34 For instance, data from the American Community Survey is based on geographical location rather than Tribal <br />membership. U.S. Census Bureau, My Tribal Area, https://www.census.gov/Tribal/Tribal_glossary.php. <br />39 <br />