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2021, the sector remained 485,000 jobs below its pre -pandemic leve1.226 In addition, some <br />nonprofits may have experienced declines in volunteer staffing during the pandemic.227 <br />At the same time, nonprofits provide a host of services for their communities, including <br />helping Americans weather the multitude of challenges presented by the pandemic. The ARPA <br />and the interim final rule recognized this dichotomy nonprofits as entities that have themselves <br />been negatively impacted by the pandemic and as entities that provide services that respond to <br />the public health and negative economic impacts of the pandemic on households and others —by <br />creating two roles for nonprofits. <br />First, under Sections 602(c)(1)(A) and 603(c)(1)(A), recipients may "respond to the <br />public health emergency or its negative economic impacts," by, among other activities, providing <br />"assistance to ... nonprofits." The interim final rule defined assistance to nonprofits to include <br />"loans, grants, in -kind assistance, technical assistance or other services, that responds to the <br />negative economic impacts of the COVID-19 public health emergency," and "nonprofit" to mean <br />a tax-exempt organization under Section 501(c)(3) of the U.S. Internal Revenue Code.228 <br />Second, as discussed above, ARPA and the interim final rule provided that nonprofit <br />organizations may also receive funds as subrecipients of a recipient government (i.e., a <br />government that received SLFRF funds); subrecipients carry out an eligible use of SLFRF funds <br />on behalf of a recipient government (e.g., a recipient government that would like to provide food <br />assistance to impacted households may grant funds to a nonprofit organization to carry out that <br />eligible use). Recipients generally have wide latitude to award funds to many types of <br />226 Chelsea Newhouse, COVID-19 JOBS UPDATE, NOVEMBER 2021: Nonprofits add just 5,000 jobs in <br />November, Center for Civil Society Studies at Johns Hopkins University (December 10, 2021), <br />http://ccss.jhu.edu/november-2021-jobs/ <br />227 Elizabeth T. Boris et al. supra note 209 at p. 38. <br />228 § 35.3 Definitions. <br />154 <br />