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American Rescue Plan
UPDATE FROM TREASURY 4/29/2022
“If you have contacted Treasury by email or by phone with a technical issue regarding your report submission and you do not receive a response by the April 30, 2022, due date, please know that the Treasury Portal will remain open for your submissions after the deadline to accommodate those who are experiencing technical issues.”
Please email firstname.lastname@example.org if you are having a technical issue. National League of Cities might also be able to help with Treasury. The email address for help from NLC is SLFRFhelp@nlc.org.
Project & Expenditure Report Templates Available
The Department of Treasury published a set of answers to frequently asked questions related to State and Local Fiscal Recovery Funds.
On April 1, 2022, the U.S. Treasury released Project and Expenditure Report templates for the State and Local Fiscal Recovery Funds (SLFRF) program, authorized by the American Rescue Plan Act (ARPA) of 2021. The Project and Expenditure Report is due from all SLFRF recipients by April 30, 2022. A program User Guide was also released to assist in the submission of information. We also encourage you to review Treasury’s webinar on Compliance and Reporting from March 21, along with the presentation materials from that session.
Additionally, Treasury released a webinar on April 7, 2022 walking through, step-by-step, the submission of the State and Local Fiscal Recovery Funds (SLFRF) Project and Expenditure report for Non-Entitlement Units (NEUs) that are selecting the standard allowance under the revenue loss provision. We recommend reviewing this brief (23 minute) webinar to ensure that all required steps to submit your report are taken.
A new document has been released as of 4/28/2022 to help recipients understand and apply the final rule. This document addresses many of the questions received by the Department since the Final Rule was released and also includes many FAQs that were available in connection with the interim final rule (although numbering may have changed) because they remain applicable under the final rule. Answers to frequently asked questions that are unique to the interim final rule remain available at Interim Final Rule: Frequently Asked Questions. Treasury anticipates updating this document as additional guidance is developed. Treasury appreciates you sharing this announcement with others in your government and with members of your community as appropriate."
Compliance and Reporting Guidance
Compliance and Reporting Guidance
On February 28, 2022, the U.S. Treasury released updated Compliance and Reporting Guidance (Reporting Guidance) for the State and Local Fiscal Relief Fund (SLFRF) program. This Reporting Guidance includes updates to reporting requirements to reflect the final rule that Treasury adopted on January 6, 2022. These updates take effect for the next Project and Expenditure Report that all state, local, and Tribal governments need to submit by April 30, 2022.
Single Audit Alternatives for NEUs
The Office of Management and Budget has released an Addendum 3 to the 2021 Single Audit Compliance Supplement. Addendum 3 includes a simplified Single Audit process designed for entities that would otherwise not be required to undergo an audit pursuant to 2 CFR Part 200, Subpart F, if it was not for the expenditures of State and Local Fiscal Relief Funds (SLFRF) directly awarded by Treasury as part of the American Rescue Plan.
Addendum 3 includes a simplified Single Audit process (an "Attestation") for those direct recipients that are considered exempt from the Single Audit if it was not for the expenditures of SLFRF funds. This alternative is intended to reduce the burden of a full Single Audit on eligible recipients (estimated at more than 10,000 entities). This alternative applies to fiscal year audits beginning after June 30, 2020.
To support Non-Entitlement Units (NEUs) with SLFRF reporting, Treasury has posted an instructional webinar on YouTube (dated March 10, 2022). The webinar includes helpful information on using the Treasury portal such as how to create an account and submit supporting documents.
To access the updated Reporting Guidance and learn more about the SLFRF program, please visit https://www.treasury.gov/SLFRPReporting website.
If you have questions or need additional information, please send an email to SLFRP@treasury.gov.
Additional Guidance from the U.S. Treasury
On January 6, 2022, the U.S. Treasury issued the final rule implementing the Coronavirus State and Local Fiscal Recovery Funds (SLFRF) program under the American Rescue Plan. The final rule – which takes effect on April 1, 2022 – provides state, local, and Tribal governments with even broader flexibility to pursue a wider range of uses to respond to local public health and economic needs – as well as greater simplicity so they can focus on responding to the needs in their communities and maximizing the impact of their funds.
Prior to April 1, 2022, recipients may take actions and use funds in a manner consistent with the final rule, and Treasury will not take action to enforce the Interim final rule if a use of funds is consistent with the terms of the final rule, regardless of when the SLFRF funds were used. Please see the Statement Regarding Compliance with the Coronavirus State and Local Fiscal Recovery Funds Interim Final Rule and Final Rule for more information.
Recipients are especially encouraged to consult the Overview of the Final Rule, which is a user guide that boils the rule text down into an easy-to-understand summary. The Overview of the Final Rule includes a non-exhaustive list of projects that recipients can undertake with these funds without undergoing additional independent analysis.
The Maryland Municipal League wishes to thank the National League of Cities for their regular updates on Coronavirus State and Local Fiscal Recovery Funds (SLFRF).
On December 14, 2021, the U.S. Treasury released a new Agreements and Supporting Documents User Guide for Non-Entitlement Units of Government (NEUs). This thirteen page document provides NEUs with information on how to use Treasury's Portal to submit information in accordance with the Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Compliance & Reporting Guidance. You'll find the U.S. Treasury's complete December 14 announcement regarding NEU Portal Notification here.
On November 15, 2021, the U.S. Treasury released an update of their Frequently Asked Questions (FAQs) document including much anticipated updates on Compliance & Reporting responsibilities.
For additional information, including guidance specific to Non-entitlement Units of local government, visit the U.S. Department of Treasury's Coronavirus State and Local Fiscal Recovery Funds page.
ARPA Educational Webinars for NEUs
All educational webinars related to American Rescue Plan Act (ARPA) Coronavirus Local Fiscal Recovery Funds (CLFRF) can now be found on the State of Maryland's Open Data Portal page for Non-Entitlement Unit recipients of CLFRF funds. Topics include Compliance & Reporting (February 24, 2022), Understanding the Final Rule (January 26, 2022), and Uniform Guidance Compliance Requirements (December 14).
The State of Maryland's ARP-NEU Landing Page remains the go-to resource for non-entitlement units seeking ARPA CLFRF information relevant to Maryland's cities and towns, including an NEU Question Submission Portal and biweekly "virtual office hours."
Local Fiscal Recovery Funds Playbook (NLC)
The National League of Cities recently released an ARPA Local Fiscal Recovery Funds Playbook that provides a helpful summary of resources and process related to the American Rescue Plan Act.
What is Your Municipality Using ARPA Funds For?
Existing resources showing what local governments are doing around the country have been created by the National League of Cities and the U.S. Department of the Treasury.
Compliance and Reporting Guidance Update
As announced on September 30, 2021, the U.S. Treasury has extended the deadline for submission of the first Project and Expenditure Reports, which were originally due on October 31, 2021, as follows:
- For States, U.S. territories, metropolitan cities and counties, and Tribal Governments,
the report will now be due on January 31, 2022 and will cover the period between award
date and December 31, 2021.
- For non-entitlement units of government (NEUs), the Project and Expenditure report will
now be due on April 30, 2022 and will cover the period between award date and March
Further instructions will be provided at a later date, including updates to this Compliance and Re-porting guidance as well as a user guide to assist recipients to gather and submit the information through Treasury's Portal.
ARPA Community Engagement Tool
The ARPA Engagement Package by Polco connects leaders with residents, local businesses, and
each other. With high-quality standardized surveys, the Polco engagement platform, and online
reporting dashboards - this comprehensive package uncovers community needs and helps align funds with economic priorities. Learn more here.
American Rescue Plan Spending: Recommended Guiding Principles
For many jurisdictions, the funding provided under ARPA is substantial and could be transformational for states and local governments in their pandemic rescue and recovery efforts. Elected leaders will need to decide how to best use the additional funding consistent with the ARPA requirements, which are very broad.
Resource Guide from the Government Finance Officers Association (GFOA)