Treasury Releases ARPA State and Local Recovery Funding Compliance and Reporting Requirements/Deadlines

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Guidance Includes Four Key Principles to Know

Today, the U.S. Treasury Department released compliance requirements and reporting deadlines for the Coronavirus State and Local Fiscal Recovery Funds provided by the American Rescue Plan Act. The Treasury Department advises that the compliance and reporting requirements should be read in conjunction with the Award Terms and Conditions.

Under the ARPA, states, territories, metropolitan cities, counties and tribal governments will receive funds directly from the U.S. Treasury. Local governments that are deemed non-entitlement entities, or NEUs, will receive the funds through the state government.

The guidance provides four key principles that should be reviewed and considered:

  1. Recipients and sub-recipients must ensure the funds are used in compliance with the Interim Final Rule;
  2. Many Coronavirus State and Local Fiscal Recovery Funds projects will respond to the COVID-19 public health emergency and meet urgent community needs;
  3. Coronavirus State and Local Fiscal Recovery Funds projects should advance shared interests and promote equitable delivery of government benefits and opportunities to underserved communities and
  4. Transparency and public accountability for Coronavirus State and Local Fiscal Recovery Funds: Award funds and the use of the funds are critical to upholding program integrity and trust in all levels of governments.

Reporting Deadlines:
Metropolitan cities and counties that received more than $5 million:

  • Interim Report by Aug. 31, with expenditure summary by category
  • Project and Expenditure Report by Oct. 31, and then 30 days after the end of each quarter thereafter
  • States and metropolitan cities and counties with a population exceeding 250,000 must also submit a Recovery Plan Performance Report by Aug. 31, and annually thereafter by July 31.


Metropolitan cities and counties with a population below 250,000 who received less than $5 million:

  • Interim Report by Aug. 31, with expenditure summary by category
  • Project and Expenditure Report by Oct. 31, and then annually thereafter

NEUs

  • Interim Report not required
  • Project and Expenditure Report by Oct. 31, and then annually thereafter

[View source.]

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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