Agudath Israel of America commends the Trump Administration and Congress for their determined and tireless efforts to bring relief to the American people from the manifold ravages of the COVID-19 pandemic. We are particularly grateful that they have worked to incorporate within the CARES Act, and subsequent regulation and guidance, provisions that include faith-based institutions as beneficiaries of the vital programs the federal government will implement to address the severe economic fallout the nation is expected to experience.
Our Washington Office, headed by Rabbi Abba Cohen, Vice President for Government Affairs, has worked closely and cooperatively with White House and federal agency officials, Congressional leaders, and other faith-based nonprofits. Together, they have sought to ensure that houses of worship, religious schools and community charities are able to participate fully in the law’s newly-designed loan programs, educational assistance and other essential initiatives. The goal of these mutual efforts was to help these entities pay salaries and health care benefits, maintain facilities, and address other critical necessities, as our shuls, yeshivos and day schools, and tzedaka institutions are in dire need of this assistance.
We are pleased that not only does the legislation and subsequent administrative material, taken together, make such eligibility explicit but they also provide that participation can be enjoyed without compromise of religious mission, beliefs, activities or autonomy. At the same time, we note that the application of some of these programs within the faith based context is novel and complicated. Thus, in the coming weeks and months, we will continue to monitor implementation to determine whether assistance levels are adequate and whether the letter and spirit of the law are being upheld. If necessary, we will continue to make a strong push, in legislation and regulation, for a full measure of funding and broader standards for full participation of our institutions.
It is imperative that our government provide substantial relief to our nonprofit sector, including our religious organizations. Indeed, as federal and state programs are squeezed, nonprofits will be called upon to step up and help address society’s most pressing needs. During this crisis, it is crucial that our government do whatever it can to partner with this sector, assist it, and protect it from the same adverse economic winds that will plague other parts of the economy, particularly as its own income sources dry up and its own burdens increase.
We provide the following links for important information relating specifically to the rights of faith-based entities participating in CARES Act programs (and we will add to this list as appropriate):
Equitable Participation of Nonpublic Schools in the CARES Act Education Stabilization Fund: CARES Act, https://www.congress.gov/116/bills/hr748/BILLS-116hr748enr.pdf
Sections 18002-3, 18005 (Regulations Pending)
Interim Final Rule – Religious Liberty, Religious Employers and Nondiscrimination: https://home.treasury.gov/system/files/136/PPP–IFRN%20FINAL.pdf; Interim Final Rule – Affiliation Rules for Faith-Based Organizations, https://www.sba.gov/document/policy-guidance–ppp-affiliation-interim-final-rule
FAQs on Participation of Faith-Based Organizations in SBA’s PPP and EIDL Programs: https://www.sba.gov/document/support–faq-regarding-participation-faith-based-organizations-ppp-eidl