Last week, the U.S. Department of the Treasury published new guidance for how state and local governments can use the $150 billion in relief funds provided by the CARES Act. The guidance provides some flexibility to recipients to address “second-order effects” of the COVID-19 pandemic. On a long, but “nonexclusive” list of eligible expenditures, Treasury included expenditures related to small business grants to reimburse costs from related interruptions and costs related to a payroll protection program. State, territorial and tribal governments, as well as municipal governments with populations greater than 500,000 were eligible for these relief funds, which had to be requested by April 17. Generally, funds can cover necessary expenses incurred between March 1 and December 30 that were not part of the government’s budget in effect on March 27, 2020.