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Public Comment: Eligible Assistance to Impacted and Disproportionately Impacted <br />Nonprofits: A few commenters asked Treasury to be more explicit in the final rule that recipients <br />may use funds to provide relief directly to nonprofit organizations and to explain how nonprofits <br />might qualify themselves for assistance and what expenses SLFRF funds may be used to <br />cover.230 Commenters requested that Treasury note that the pandemic is leading to a changing <br />financial landscape for nonprofits. <br />Treasury Response: Eligible Assistance to Impacted and Disproportionately Impacted <br />Nonprofits: The interim final rule provided for, and the final rule maintains, the ability for <br />recipients to provide direct assistance to nonprofits that experienced public health or negative <br />economic impacts of the pandemic. Specifically, recipients may provide direct assistance to <br />nonprofits if the nonprofit has experienced a public health or negative economic impact as a <br />result of the pandemic. For example, if a nonprofit organization experienced impacts like <br />decreased revenues or increased costs (e.g., through reduced contributions or uncompensated <br />increases in service need), and a recipient provides funds to address that impact, then it is <br />providing direct assistance to the nonprofit as a beneficiary under Subsection (c)(1) of Sections <br />602 and 603. Direct assistance may take the form of loans, grants, in -kind assistance, technical <br />assistance, or other services that respond to the negative economic impacts of the COVID-19 <br />public health emergency. <br />A recipient may identify a negative economic impact experienced by a nonprofit, or class <br />of nonprofits, and design and implement a response to that negative economic impact, see <br />section Standards: Designating a Negative Economic Impact. The final rule provides a non- <br />23° While not stated specifically in the interim final rule, the Department does not require or have a preference as to <br />the payment structure for recipients that transfer funds to subrecipients (e.g., advance payments, reimbursement <br />basis, etc.). Ultimately, recipients must comply with the eligible use requirements and any other applicable laws or <br />requirements and are responsible for the actions of their subrecipients or beneficiaries. <br />156 <br />