Agenda - Council - 09/13/2022 - Laserfiche WebLink

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revenue compared to the counterfactual estimate. The interim final rule invited comments on whether Treasury should revise its presumption to "take into account other factors, including actions taken by the recipient as well as the expiration of the COVID-19 public health emergency, in determining whether to presume that revenue losses are 'due to' the COVID-19 public health emergency." Treasury received a substantial number of comments on the revenue loss provisions set forth in the interim final rule. These comments largely pertained to the following topics: the overall methodology for calculating revenue loss; the definition of "revenue"; whether revenue should be aggregated or calculated on some alternative basis (e.g., source -by -source or fund -by - fund); the appropriate calculation dates (i.e., fiscal year or calendar year); the presumption that all revenue loss is due to the pandemic; the base year; and the definition of "government services." Overall Methodology for Calculating Revenue Loss As noted above, the interim final rule provided a formula for recipients to calculate revenue loss by comparing actual revenues received during a given time -period with a counterfactual amount of revenue based on revenues in the base year and an adjustment for expected growth in revenue each year. Public Comment: Treasury received many public comments on the overall methodology for calculating revenue loss. Some recipients, including smaller governments, have expressed concern regarding the burden associated with the calculation of revenue loss, particularly the burden involved in calculating the amount of general revenue, given that the definition of general revenue in the interim final rule does not always align with the definition of revenue already 239