Treasury Releases Compliance & Reporting Guidance for ARPA State and Local Fiscal Recovery Funds

Bottom Line Up Front

  • On June 17th, the Treasury Department released compliance requirements, reporting guidance, and deadlines for the Coronavirus State and Local Fiscal Recovery Funds authorized by the American Rescue Plan Act.
  • Please visit the Treasury Department’s website for more information about the State and Local Fiscal Recovery Funds and Reporting Guidance. 

$350 billion was allocated as Coronavirus State and Local Fiscal Recovery Funds in the American Rescue Plan Act. The funds are intended to provide emergency recovery aid for states, metropolitan cities, counties, territories, and tribal governments to help contain the impacts COVID-19 has had and continues to have on their communities. 

On June 17th, the Department of Treasury released “Compliance and Reporting Guidance” for the ARPA State and Local Fiscal Recovery Funds (“SLFRF”). This document provides recipients additional detail and clarification on the reporting and compliance for the administration of the Fiscal Recovery funds. This guidance should be read in conjunction with the Award Terms and Conditions and the Interim Final Rule. 

Compliance Overview

Recipients of the SLFRF are responsible for developing their own effective compliance systems which must adhere to the SLFRF statute, Award Terms and Conditions, the Interim Final Rule, and reporting requirements. In order to ensure they are aware of their compliance responsibilities, the Treasury has outlined expectations and best practices via: 

  1. Key Principles
  2. Statutory Eligible Uses
  3. Treasury’s Rulemaking
  4. Uniform Guidance
  5. Award Terms and Conditions 

Reporting Overview with Deadlines

There are three types of reporting requirements for the SLFRF: 

  1. Interim Report

A one-time report, required by all recipients except Non-Entitlement Units of local government (“NEUs”). The state or territory that distributed NEU funding will have a section to report on behalf of NEUs. This report will need to provide an initial overview of the status and uses of funding. 

  • For all recipients except NEUs
    • August 31, 2021, with expenditure summary by category
  1. Project and Expenditure Report

Required by all recipients. This will be used to report on any projects, expenditures, contracts, or sub-awards over $50,000. 

  • For Metropolitan cities and counties that received more than $5 million in SLFRF:
    • October 31, 2021, and then 30 days after the end of each quarter following 
  • For Metropolitan cities and counties with a population below 250,000 who received less than $5 million in SLFRF: 
    • October 31, 2021, and then annually following
  • NEUs
    • October 31, 2021
  1. Recovery Plan Performance Report

Required only for states, territories, metropolitan cities, and counties with a population that exceeds 250,000. This report will need to provide information on projects being funded with the SLFRF and show KPIs for project success measurement. It will also need to be published on the organization’s public-facing website on the same date that it is submitted to the Treasury. 

  • Metropolitan cities and counties with a population of over 250,000 
    • August 31, 2021, and then following the initial deadline annually by July 31st. 
*Source: U.S. Treasury Department’s Compliance and Reporting Guidance

Additional Information and Links

Upcoming Webinars Regarding the New Guidance: 

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