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during a labor dispute, as this would not constitute responding to the public health or negative <br />economic impacts of the pandemic. Further, recipients must ensure that its hiring practices do not <br />violate conflict -of -interest policies.245 Total compensation for a hired employee that is <br />substantially in excess of typical compensation for employees of their experience and tenure <br />within the recipient's government, without a corresponding business case, may indicate a <br />potential conflict -of -interest in fact or appearance. <br />Providing additional funding for employees who experienced pay cuts and furloughs. In <br />recognition of the economic hardship caused by pay cuts and furloughs, additional funds may be <br />provided to employees who experienced pay cuts or were furloughed since the onset of the <br />pandemic on January 27, 2020. Recipients must be able to substantiate that the pay cut or <br />furlough was substantially due to the public health emergency or its negative economic impacts <br />(e.g., fiscal pressures on state and local budgets) and should document their assessment. As a <br />reminder, this additional funding must be reasonably proportional to the negative economic <br />impact of the pay cut or furlough on the employee, which would include taking into account <br />unemployment insurance (UI) benefits that a furloughed employee may have received during the <br />furloughed period. Treasury presumes that additional funds beyond the difference in pay had the <br />employee not received a pay cut or been furloughed would not be reasonably proportional. <br />Recipients may also provide premium pay to certain employees, as detailed further in <br />section Premium Pay. <br />245 As part of accepting the Award Terms and Conditions for SLFRF, each recipient agreed to maintain a conflict -of - <br />interest policy consistent with 2 C.F.R. § 200.318(c)112 that is applicable to all activities funded with the SLFRF <br />award. Pursuant to this policy, decisions concerning SLFRF must be free of undisclosed personal or organizational <br />conflicts of interest, both in fact and in appearance. A recipient may not use control over SLFRF for their own <br />private gain. Furthermore, no employee, officer, or agent may participate in the selection, award, or administration <br />of a contract supported by a federal award if he or she has a real or apparent conflict of interest. <br />183 <br />