Mobility Management and the CARES Act

Federal COVID Policy and Mobility Management

In late March President Trump signed the Coronavirus Aid, Relief and Economic Security Act (“CARES”) into law.  This $2 trillion relief legislation provided $25.0 billion in relief for urban and rural public transit systems impacted by the COVID-19 pandemic. For FTA funded 5311 and 5307 public transportation systems, these dollars will provide coronavirus-related reimbursements.

However, for mobility management providers, it may not be as clear where benefits may exist in the CARES Act legislation. This blog looks to clarify where the passed relief and assistance programs could benefit mobility management professionals:

Section 5307 and Section 5311

Mobility management is one of many eligible activities under FTA’s formula grant programs – Section 5307 (urban public transit), Section 5310 (enhanced mobility for elderly individuals and persons with disabilities) and Section 5311 (rural public transit).

The CARES Act included nearly $25.0 billion in relief for urban and rural public transit systems impacted by the COVID-19 pandemic. For FTA funded 5311 and 5307 public transportation systems, these dollars will provide coronavirus-related reimbursements. Recipients of those funds can use this influx of CARES Act funding to continue to support mobility management activities.

Section 5310

While many Section 5310 recipients also receive funding through either Section 5307 or 5311 – not all do. The distinction is critical to be aware of for your system given the CARES Act did not direct any additional funding specifically to Section 5310 recipients.

For those 5310 recipients who also receive 5307 or 5311 funding – the things they may have been accustomed to funding through Section 5310 instead can be funded through their CARES Act Section 5307 or 5311 dollars. Note: in general, pretty much anything that can be funded through Section 5310 – including mobility management – is also eligible for 5307 or 5311.

However, the story is quite different for the 5310 recipients who receive no other FTA funding, and use 5310 to support mobility management activities. Given that the CARES Act does not directly include funding for this group, recipients of Section 5310 may need to think creatively to avoid large funding gaps, layoffs, or other harmful economic impacts from the pandemic.

Existing support options

NCMM has identified a number of options for mobility managers and their agencies to continue to support the important work of mobility management during this time:

Support directly identified within the CARES Act:

• Paycheck Protection Plan: Private nonprofits can seek Small Business Administration (SBA) funding through the CARES Act “Payroll Protection Program” (PPP). The CARES Act allocates $350 billion to the PPP, which is intended to aid small businesses with under 500 employees make payroll and cover expenses from February 15 to June 30. Small businesses may qualify for up to $10 million in loans. These loans may be used for payroll, rent, utilities, interest payments on mortgages and debt obligations.

• Loan Forgiveness: Under the CARES Act, if the employer maintains payroll for the covered period, then the portion of the loans used for covered payroll costs, interest on mortgage obligations, rent, and utilities would be forgiven. This proposal would be retroactive to Feb. 15, 2020, and would encourage employers to rehire workers who were laid off or reinstate salaries that were cut due to the virus outbreak.

Ideas for coordinated support across 5307, 5310, and 5311 to leverage CARES Act funding:  

• Nonprofit Section 5310 subrecipients could consider entering into contractual relationships with Section 5307 or 5311 recipients under which the public transit agency uses some of its CARES Act or “regular” formula funds to cover activities that might otherwise have been spent through Section 5310;
• Mobility managers should brainstorm how they may be able to adapt their role to provide coronavirus-related support from 5311 or 5307 operators for helping with their services.

NCMM acknowledges that while the provisions and relief opportunities above may be applicable, they do not provide the scale of support that to mobility managers is likely needed during this unprecedented time. NCMM highly encourages all mobility managers to consider how you and your organization can adapt and creatively serve your community during this pandemic.

We encourage you to check out the NCMM COVID-19 Webpage for additional guidance from the CDC, FTA, and NCMM Partners.