Guidance

Public health ringfenced grant 2022 to 2023: local authority circular

Published 7 February 2022

Applies to England

This circular sets out:

  • allocations of the local government public health grant for 2022 to 2023

  • the conditions that will apply to that grant

  • guidance intended to assist local authorities

Background

In 2022 to 2023, the total public health grant to local authorities will be £3.417 billion.  

The grant will be ringfenced for use on public health functions. This may include public health challenges arising directly or indirectly from COVID-19.

The Secretary of State has determined, pursuant to section 31 of the Local Government Act 2003, to pay grants to relevant authorities in the amounts indicated for the financial year 2022 to 2023.

This circular is accompanied by 4 annexes:

  • Annex A – Public health ringfenced grant determination and conditions 2022 to 2023

  • Annex B – Public health grant allocations for 2022 to 2023

  • Annex C – Public health reporting categories for 2022 to 2023

  • Annex D – Assurance letter

The grant

The 2022 to 2023 grant will be paid in quarterly instalments:

  • Quarter 1 – Friday 8 April 2022

  • Quarter 2 – Friday 8 July 2022

  • Quarter 3 – Friday 7 October 2022

  • Quarter 4 – Friday 6 January 2023

Pursuant to section 31(4) of the Local Government Act 2003 the Secretary of State has attached conditions to the payment of the grant, which are set out under ‘Grant conditions’, ‘Reporting’ and ‘Financial management’ in Annex A (below) and are unchanged from 2021 to 2022. When assessing whether local authorities have complied with these conditions, the Department of Health and Social Care (DHSC) will continue to look at the primary purpose of local authorities’ spending.

The department’s presumption is that the grant will be spent in-year. If at the end of the financial year there is any underspend, local authorities may carry these over, as part of a public health reserve, into the next financial year. In using those funds the next year, local authorities will still need to comply with the grant conditions. The department may consider reducing future grant amounts to local authorities that report significant and repeated underspends.

Reporting of grant expenditure

Local authorities will need to forecast and report against the sub-categories in the Revenue Account (RA) and Revenue Outturn (RO) returns to the Department for Levelling Up, Housing and Communities (DLUHC) which will share data with DHSC. The main and primary purpose of all spend from the grant is public health.

Given that the RO return is used as a way of monitoring the usage of the grant, it is important that both the finance contacts and public health teams responsible for this section of financing are content with the figures submitted. Local authorities will need to ensure that the figures are verified and in line with the purpose set out in the grant conditions. A list of the reporting categories is at Annex C. Local authorities’ chief executives (or Section 151 officers) and directors of public health will also need to return a statement confirming that the grant has been spent in accordance with the conditions. The required statement is at Annex D.

Year-end reporting

At the end of the financial year, local authorities will need to submit a more detailed RO return to DLUHC. Local authorities must record expenditure against each of the prescribed functions categories which are classified in Annex C, to demonstrate that they are undertaking activity in these areas.

The full value of the grant must be accounted for in the RO returns. As such, the closing value of a local authority’s public health reserve minus the opening value of the public health reserve when added to the net spend reported in the year must be greater than or equal to the value of the grant for the year.

Where income relating to public health activities is received from other sources than the ringfenced grant, and such income is recorded on the RO return as public health, then the corresponding expenditure should also be recorded as public health, and any income not spent at the year-end should be carried forward in the public health reserve.

Guidance on reporting and categorisation of spend is available to local authorities in the Service Reporting Code of Practice (SeRCOP) on how activity should be recorded against the sub-categories.

Enquiries

Enquires about this circular should be addressed to DHSC at phgfinance@dhsc.gov.uk.

Annex A: Determination under section 31 of the Local Government Act 2003 of a ringfenced public health grant to local authorities for 2022 to 2023

Public health ringfenced grant determination 2022 to 2023: No 31/5900

The Secretary of State for Health and Social Care (‘the Secretary of State’), in exercise of the powers conferred by section 31 of the Local Government Act 2003, makes the following determination:

Citation

This determination may be cited as the ‘Public health ringfenced grant determination 2022 to 2023: No 31/5900’.

Purpose of the grant

This grant can be used for both revenue and capital purposes.

The purpose of the grant is to provide local authorities in England with the funding required to discharge the public health functions detailed in paragraphs 2 to 4 below under ‘Grant conditions’.

Grant conditions

Pursuant to section 31(4) of the Local Government Act 2003, the Secretary of State determines that the grant will be paid subject to the conditions set out under ‘Grant conditions’, ‘Reporting’ and ‘Financial management’ below.

The ringfence on the grant will remain in 2022 to 2023.

Determination

The Secretary of State determines as the authorities to which the grant is to be paid and the amount of grant to be paid in the financial year 2022 to 2023, the authorities and the amounts for the financial year 2022 to 2023 are set out in the exposition book.

Before making this determination the Secretary of State obtained the consent of the Treasury.

Signed by authority of the Secretary of State for Health and Social Care

Simon Reeve
Deputy Director – Public Health Systems and Workforce
Department of Health and Social Care

Grant conditions

1.      In this determination:

-      ‘an authority’ means an upper-tier or unitary local authority identified in the Appendix

-      ‘the department’ means the Department of Health and Social Care

-      ‘financial year’ means a period of 12 months ending 31 March 2023

-      ‘NHS body’ means an NHS body within the meaning of section 75 of the National Health Service Act 2006

-      ‘grant’ means the amounts set out in the ‘Ringfenced public health grant determination 2022 to 2023’

-      ‘Upper tier and unitary local authorities’ means:

  • a county council in England
  • a district council in England, other than a council for a district in a county for which there is a county council
  • a London borough council
  • the Council of the Isles of Scilly
  • the Common Council of the City of London

Use of the grant

2.      Pursuant to Section 31 of the Local Government Act 2003, the Secretary of State hereby determines that the public health grant shall be paid towards expenditure incurred, or to be incurred, by upper-tier and unitary local authorities in the financial year 2022 to 2023. The relevant authorities are shown in the exposition book.

3.      Subject to paragraph 5, the grant must be used only for meeting eligible expenditure incurred or to be incurred by local authorities for the purposes of their public health functions as specified in Section 73B(2) of the National Health Service Act 2006 (‘the 2006 Act’).

4.      The functions mentioned in that subsection are:

(a) functions under section 2B, 111 or 249 of, or Schedule 1 to, the 2006 Act

(b) functions by virtue of section 6C of the 2006 Act

(c) the Secretary of State’s public health functions exercised by local authorities in pursuance of arrangements under section 7A of the 2006 Act

(d) the functions of a local authority under section 325 of the Criminal Justice Act 2003 (co-operating with the police, the probation service and the prison service to assess the risks posed by violent or sexual offenders)

(e) such other functions relating to public health as may be prescribed

5.      A local authority may use the grant to contribute to a fund made up of:

  • (a)      contributions by the authority from both the public health grant and other sources of funding – for example, from other local authority funding, or from payments made by a private sector or civil society organisation; or

  • (b)      contributions by the authority and one or more of any of the following bodies:

    • (i) another local authority

    • (ii) an NHS or other public body

    • (iii) a private sector or civil society organisation

provided the conditions specified in paragraph 6 are met.

6.       The conditions referred to in paragraph 5 are that:

  • (a)      the fund must be one out of which payments are made towards expenditure incurred in the exercise of, or for the purposes of, the functions described in paragraph 3

  • (b)      if payments are made out of the fund towards expenditure on other functions of a local authority or the functions of an NHS body, other public body, or a private sector or civil society organisation, the authority must be of the opinion that those functions have a significant effect on public health or have a significant effect on, or in connection with, the exercise of the functions described in paragraph 3

  • (c)      the authority must be satisfied that, having regard to the contribution from the public health grant, the total expenditure to be met from the fund and the public health benefit to be derived from the use of the fund, the arrangements provide value for money

7.       A local authority must, in using the grant:

  • have regard to the need to reduce inequalities between the people in its area with respect to the benefits that they can obtain from that part of the health service provided in exercise of the functions referred to in paragraph 3

  • have regard to the need to improve the take up of, and outcomes from, its drug and alcohol misuse treatment services, based on an assessment of local need and a plan which has been developed with local health and criminal justice partners

8.       The public health grant will only be paid to local authorities to support eligible expenditure. Grant carried over to the following year is governed by the grant conditions.

Eligible expenditure

9.       Eligible expenditure means expenditure incurred by an authority or any person acting on behalf of an authority, between 1 April 2022 and 31 March 2023, for the purposes of carrying out the public health functions referred to in paragraphs 3 and 4.

10.      If an authority incurs any of the following costs, those costs must be excluded from eligible expenditure:

  • a)  contributions in kind

  • b)  payments for activities of a political or exclusively religious nature

  • c) depreciation, amortisation or impairment of fixed assets owned by the authority

  • d)  input VAT reclaimable by the authority from HM Revenue and Customs

  • e)  interest payments or service charge payments for finance leases

  • f)  gifts, other than promotional items, with a value of no more than £10 in a year to any one-person subject to the exception in paragraph 11

  • g) entertaining (entertaining for this purpose means anything that would be a taxable benefit to the person being entertained, according to current UK tax regulations)

  • h)  statutory fines, criminal fines or penalties

11.      Expenditure on promotional items in fulfilment of the local authority’s health improvement duty under Section 2B of the 2006 Act, such as products, goods or services which are given for health improvement purposes, may form part of eligible expenditure. This could include, for example, vouchers for gym or fitness classes, nicotine patches or other expenditure which corresponds with the health improvement objectives of the public health grant.

12.      An authority must not deliberately incur liabilities for eligible expenditure before there is an operational need for it to do so.

13.      For the purpose of defining the time of payments, an authority shall account for its spend from the grant using the accrual basis of accounting (for an explanation of accrual accounting please refer to the CIPFA Code of Practice on Local Authority Accounting in the United Kingdom.)

Payment arrangements

14.      Grants will be paid in quarterly instalments by DHSC.

Reporting

End-of year reporting

15.      Each authority shall prepare a return setting out how the grant has been spent using the Revenue Outturn (RO) form at the end of the financial year covering the period 1 April 2022 to 31 March 2023. In accordance with existing practice, this will be submitted to DLUHC which will share the information with DHSC. A list of the lines of expenditure (categories) that will need to be reported on is at Annex C below. The RO form must provide details of eligible expenditure in the period, against each relevant category.

16.      The returns must be certified by the authority’s chief executive (or the authority’s S151 officer) and the director of public health that, to the best of their knowledge, the amounts shown on the statement relate to eligible expenditure on public health and that the grant has been used for the purposes intended, as set out in this determination. Chief executives have been provided with a statement of assurance for their signature at Annex D. This should be submitted to DHSC at phgfinance@dhsc.gov.uk.

17.      The Secretary of State may require a further external validation to be carried out by an appropriately qualified independent accountant or auditor of the use of the grant where the RO return referred to in paragraph 16 above fails to provide sufficient assurance to the Secretary of State that the grant has been used in accordance with these conditions.

18.      While the grant should not be used for interest or service charge payments or finance leases it can be used for capital spend on items that do not entail borrowing or a finance lease. Capital expenditure should be noted as a Capital Expenditure from Revenue Account (CERA) payment on the RO form and details provided on the Capital Outturn Return (COR) form issued by the DLUHC. Further guidance will be supplied with the forms that DLUHC send out.

19.      In accordance with existing practice, local authorities should send the RO to DLUHC.

Financial management

20.      Each authority must maintain a robust system of internal financial controls and inform the department promptly of any significant financial control issues raised by its internal auditors in relation to the use of the public health grant.

21.      If an authority identifies any overpayment of the grant, the authority must repay this amount within 30 days of it coming to their attention.

22.      If an authority has any grounds for suspecting financial irregularity in the use of any grant paid under this funding agreement, it must notify the department immediately, explain what steps are being taken to investigate the suspicion and keep the department informed about the progress of the investigation. For these purposes, ‘financial irregularity’ includes fraud or other impropriety, mismanagement, and the use of the grant for purposes other than those for which it was provided.

External audit arrangements

23.      Appointed auditors are responsible for auditing the financial statements of each authority and for reaching a conclusion on an authority’s overall arrangements for securing economy, efficiency and effectiveness in the use of resources. The use of, and accounting for, the public health grant and the arrangements for securing economy, efficiency and effectiveness in doing so fall within the scope of the work that appointed auditors may plan to carry out, having regard to the risk of material error in the authority’s accounts and significance.

Records to be kept

24.      Each authority must maintain reliable, accessible and up-to-date accounting records with an adequate audit trail for all expenditure funded by grant monies under this determination.

25.      Each authority and any person acting on behalf of an authority must allow a) the Comptroller and Auditor General or appointed representatives and b) the Secretary of State or appointed representatives free access at all reasonable times to all documents (including computerised documents and data) and other information as is connected to the grant payable under this determination, or to the purposes for which grant was used, subject to the provisions in paragraph 27.

26.      The documents, data and information referred to in paragraph 26 are such as the Secretary of State or the Comptroller and Auditor General may reasonably require for the purposes of the Secretary of State’s or the Comptroller and Auditor General’s financial audit or that any department or other public body may reasonably require for the purposes of carrying out examinations into the economy, efficiency and effectiveness with which any department or other public body has used its resources. An authority must provide such further explanations as are reasonably required for these purposes.

27.      Paragraphs 25 and 26 do not constitute a requirement for the examination, certification or inspection of the accounts of an authority by the Comptroller and Auditor General under section 6(3) of the National Audit Act 1983. The Comptroller and Auditor General will seek access in a measured manner to minimise any burden on the authority and will avoid duplication of effort by seeking and sharing information with the Audit Commission.

Breach of conditions and recovery of grant

28.      If an authority fails to comply with any of these conditions, or any overpayment is made under this grant, or any amount is paid in error, or if an authority’s chief executive or S151 officer and director of public health are unable to provide reasonable assurance that the RO form, in all material respects, fairly presents the eligible expenditure, in the relevant period, in accordance with the definitions and conditions in this determination, or any information provided is incorrect, the Secretary of State may reduce, suspend or withhold grant payments or require the repayment of the whole or any part of the grant monies paid, as may be determined by the Secretary of State and notified in writing to the authority. Such sum as has been notified will immediately become repayable to the Secretary of State who may set off the sum against any future amount due to the authority from central government.

Underspends

29.      If there are funds left over at the end of the financial year they can be carried over into the next financial year. Funds carried over should be accounted for in a ringfenced public health reserve. All the conditions that apply to the use of the grant will continue to apply to any funds carried over. However, where there are large underspends the department reserves the right to reduce allocations in future years.

Annex B: Public health allocations to unitary and upper-tier local authorities in England for 2022 to 2023

Ecode Class Local authority 2022 to 2023 £
E5030 LB Barking and Dagenham London Borough 17,787,080
E5031 LB Barnet London Borough 18,317,993
E4401 MD Barnsley Metropolitan Borough Council 17,803,270
E0101 UA Bath and North East Somerset Council 9,645,471
E0202 UA Bedford UA 9,158,513
E5032 LB Bexley London Borough 10,270,791
E4601 MD Birmingham City Council 95,969,930
E2301 UA Blackburn with Darwen Borough Council 15,486,170
E2302 UA Blackpool Borough Council 19,231,130
E4201 MD Bolton Metropolitan Borough Council 22,645,903
E1204 UA Bournemouth, Christchurch and Poole Council 20,615,825
E0301 UA Bracknell Forest Borough Council 4,390,747
E5033 LB Brent London Borough 22,884,034
E1401 UA Brighton and Hove Council 21,661,464
E0102 UA Bristol Council 34,587,808
E5034 LB Bromley London Borough 15,611,290
E0402 UA Buckinghamshire County Council 22,255,251
E4202 MD Bury Metropolitan Borough Council 12,260,090
E4702 MD Calderdale Metropolitan Borough Council 14,001,872
E0521 SC Cambridgeshire County Council 28,383,915
E5011 LB Camden London Borough 28,388,401
E0203 UA Central Bedfordshire UA 13,120,489
E0603 UA Cheshire East UA 17,404,551
E0604 UA Cheshire West and Chester UA 17,187,409
E4701 MD City of Bradford Metropolitan District Council 43,873,324
E5010 LB City of London 1,702,931
E2701 UA City of York Council 8,371,906
E0801 UA Cornwall County UA 27,079,909
E1801 UA County of Herefordshire District Council 9,588,577
E4602 MD Coventry City Council 23,205,450
E5035 LB Croydon London Borough 22,843,088
E0920 SC Cumbria County Council 19,552,031
E1301 UA Darlington Borough Council 8,830,879
E1001 UA Derby City Council 20,516,032
E1021 SC Derbyshire County Council 43,803,459
E1121 SC Devon County Council 29,828,282
E4402 MD Doncaster Metropolitan Borough Council 25,300,354
E1203 UA Dorset Council 14,613,377
E4603 MD Dudley Metropolitan Borough Council 22,015,827
E1302 UA Durham County UA 50,985,154
E5036 LB Ealing London Borough 25,932,879
E2001 UA East Riding of Yorkshire Council 11,617,924
E1421 SC East Sussex County Council 28,862,221
E5037 LB Enfield London Borough 18,023,601
E1521 SC Essex County Council 65,616,076
E4501 MD Gateshead Metropolitan Borough Council 17,225,309
E1620 SC Gloucestershire County Council 25,262,809
E5012 LB Greenwich London Borough 24,687,667
E5013 LB Hackney London Borough 35,871,044
E0601 UA Halton Borough Council 10,765,366
E5014 LB Hammersmith and Fulham London Borough 23,257,665
E1721 SC Hampshire County Council 54,412,013
E5038 LB Haringey London Borough 21,501,773
E5039 LB Harrow London Borough 11,627,344
E0701 UA Hartlepool Council 9,360,216
E5040 LB Havering London Borough 11,622,333
E1920 SC Hertfordshire County Council 51,317,172
E5041 LB Hillingdon London Borough 18,538,744
E5042 LB Hounslow London Borough 16,781,892
E2101 UA Isle of Wight Council 7,935,405
E4001 UA Isles of Scilly Council 135,454
E5015 LB Islington London Borough 28,134,585
E5016 LB Kensington and Chelsea Royal Borough 22,166,253
E2221 SC Kent County Council 71,692,652
E2002 UA Kingston Upon Hull City Council 25,342,646
E5043 LB Kingston upon Thames Royal Borough 10,758,706
E4703 MD Kirklees Metropolitan Borough Council 27,018,385
E4301 MD Knowsley Metropolitan Borough Council 18,088,653
E5017 LB Lambeth London Borough 34,398,993
E2321 SC Lancashire County Council 72,216,243
E4704 MD Leeds City Council 47,126,190
E2401 UA Leicester City Council 28,248,079
E2421 SC Leicestershire County Council 26,231,341
E5018 LB Lewisham London Borough 26,064,007
E2520 SC Lincolnshire County Council 34,847,318
E4302 MD Liverpool City Council 46,524,906
E5047 LB London Borough of Richmond upon Thames 9,873,728
E0201 UA Luton Borough Council 16,172,112
E4203 MD Manchester City Council 55,245,576
E2201 UA Medway Borough Council 18,075,001
E5044 LB Merton London Borough 11,089,220
E0702 UA Middlesbrough Borough 17,730,663
E0401 UA Milton Keynes Council 12,126,218
E4502 MD Newcastle upon Tyne Metropolitan District Council 24,939,221
E5045 LB Newham London Borough 32,612,030
E2620 SC Norfolk County Council 42,261,485
E2003 UA North East Lincolnshire Council 11,886,950
E2004 UA North Lincolnshire Council 9,700,023
E2801 UA North Northamptonshire 18,070,429
E0104 UA North Somerset Council 9,878,861
E4503 MD North Tyneside Metropolitan Borough Council 12,970,217
E2721 SC North Yorkshire County Council 22,971,763
E2901 UA Northumberland County UA 17,365,625
E3001 UA Nottingham City Council 35,458,795
E3021 SC Nottinghamshire County Council 43,159,631
E4204 MD Oldham Metropolitan Borough Council 17,699,198
E3120 SC Oxfordshire 32,569,217
E0501 UA Peterborough City Council 11,568,619
E1101 UA Plymouth City Council 15,939,960
E1701 UA Portsmouth City Council 18,605,485
E0303 UA Reading Borough Council 10,316,321
E5046 LB Redbridge London Borough 14,576,152
E0703 UA Redcar and Cleveland Borough Council 12,189,359
E4205 MD Rochdale Metropolitan Borough Council 18,045,482
E4403 MD Rotherham Metropolitan Borough Council 17,209,222
E2402 UA Rutland County Council District Council 1,365,933
E4206 MD Salford Metropolitan District Council 22,601,388
E4604 MD Sandwell Metropolitan Borough Council 25,815,878
E4304 MD Sefton 22,624,314
E4404 MD Sheffield City Council 35,232,257
E3202 UA Shropshire County UA 12,775,141
E0304 UA Slough Borough Council 7,850,908
E4605 MD Solihull Metropolitan Borough Council 11,828,642
E3320 SC Somerset County Council 21,881,436
E0103 UA South Gloucestershire Council 9,824,950
E4504 MD South Tyneside Metropolitan Borough Council 14,189,571
E1702 UA Southampton City Council 17,876,318
E1501 UA Southend-on-Sea Borough Council 10,072,833
E5019 LB Southwark London Borough 29,504,155
E4303 MD St Helens Metropolitan Borough Council 15,065,126
E3421 SC Staffordshire County Council 41,240,954
E4207 MD Stockport Metropolitan Borough Council 16,746,917
E0704 UA Stockton-on-Tees Borough Council 14,852,048
E3401 UA Stoke-on-Trent City Council 23,657,848
E3520 SC Suffolk County Council 31,670,071
E4505 MD Sunderland City Council 25,157,100
E3620 SC Surrey County Council 39,637,031
E5048 LB Sutton London Borough 10,476,200
E3901 UA Swindon Borough Council 10,592,008
E4208 MD Tameside Metropolitan Borough Council 16,129,988
E3201 UA Telford and Wrekin Council 13,168,141
E1502 UA Thurrock Council 11,911,171
E1102 UA Torbay Borough Council 10,084,483
E5020 LB Tower Hamlets London Borough 37,371,659
E4209 MD Trafford Metropolitan Borough Council 13,169,837
E4705 MD Wakefield Metropolitan District Council 25,484,391
E4606 MD Walsall Metropolitan Borough Council 18,707,049
E5049 LB Waltham Forest London Borough 17,001,881
E5021 LB Wandsworth London Borough 29,412,008
E0602 UA Warrington Borough Council 12,902,103
E3720 SC Warwickshire County Council 24,274,105
E0302 UA West Berkshire District Council 6,143,051
E2802 UA West Northamptonshire 19,107,223
E3820 SC West Sussex County Council 36,244,321
E5022 LB Westminster City Council 33,323,332
E4210 MD Wigan Metropolitan Borough Council 27,094,821
E3902 UA Wiltshire County UA 18,014,674
E0305 UA Windsor and Maidenhead Royal Borough Council 4,966,845
E4305 MD Wirral Metropolitan Borough Council 30,988,507
E0306 UA Wokingham District Council 5,689,649
E4607 MD Wolverhampton Metropolitan Borough Council 21,753,407
E1821 SC Worcestershire County Council 31,217,923

Notes

  1. The 10 Greater Manchester local authorities (Bolton, Bury, Manchester, Oldham, Rochdale, Salford, Stockport, Tameside, Trafford and Wigan) are piloting business rate retention for public health and no longer receive a grant. The funding values quoted for these areas are notional allocations only.

Annex C: categories

Categories for reporting local authority public health spend from 2022 – that is, Revenue Account Budget (RA) 2022 to 2023 and Revenue Outturn (RO) 2022 to 2023.

Prescribed functions:

1)       sexual health services – STI testing and treatment

2)       sexual health services – Contraception

3)       NHS Health Check programme

4)       local authority role in health protection

5)       public health advice to NHS Commissioners

6)       national child measurement programme

7)       prescribed children’s 0 to 5 services

Non-prescribed functions:

8)       sexual health services – advice, prevention and promotion

9)       obesity – adults

10)  obesity – children

11)  physical activity – adults

12)  physical activity – children

13)  treatment for drug misuse in adults

14)  treatment for alcohol misuse in adults

15)     preventing and reducing harm from drug misuse in adults

16)     preventing and reducing harm from alcohol misuse in adults

17)  specialist drugs and alcohol misuse services for children and young people

18)  stop smoking services and interventions

19)  wider tobacco control

20)  children 5 to 19 public health programmes

21)  other children’s 0 to 5 services non-prescribed

22)     health at work

23)     public mental health

24)  miscellaneous, can include, but is not exclusive to:

  • nutrition initiatives

  • accidents prevention

  • general prevention

  • community safety, violence prevention and social exclusion

  • dental public health

  • fluoridation

  • infectious disease surveillance and control

  • environmental hazards protection

  • seasonal death reduction initiatives

  • birth defect preventions

25) test, track and trace and outbreak planning

26) other public Health spend relating to COVID-19