On yesterday's webinar with HUD Staff, Jesse Handforth Kome said that covering loss of revenue alone is not a valid use of CDBG-CV. I believe she specifically mentioned reduced fundraising as an example of what would not be eligible. You have to look at specifically how the money would be used to determine eligibility, and tie it back to costs of preventing, preparing, and responding to COVID.
In this and other HUD webinars, they indicated that the use of CDBG-CV should be tied to increased expenses rather than loss of revenue. So, CDBG-CV could be used to hire more staff due to increased demand for an existing program, launch a new program not previously contemplated, make physical changes for social distancing, cover additional costs for cleaning/sanitization, PPE and supplies, etc.
