American Rescue Plan Act Compliance and Reporting Guidance Updated

March 7, 2022

The updated Compliance and Reporting Guidance reflects the final rule and provides additional details and clarification.

The U.S. Department of Treasury released updated American Rescue Plan Act (ARPA) Compliance and Reporting Guidance for State and Local Fiscal Recovery Funds (SLFRF) on Feb. 28. The updated guidance reflects the SLFRF final rule and provides additional details and clarification.

ARPA requires all SLFRF recipients to file a Project and Expenditure Report. This report is filed quarterly for metropolitan cities (generally those with populations over 50,000) and annually for non-entitlement units, or NEUs (generally those with populations under 50,000). Metropolitan cities filed their first Project and Expenditure Report by Jan. 31, 2022, and NEUs will file by April 30, 2022.

Read the updated Compliance and Reporting Guidance (pdf)

Revenue loss: Standard allowance vs. calculation

The final rule offers a standard allowance for revenue loss of up to $10 million, allowing recipients to select between the standard amount of revenue loss or complete a full revenue loss calculation.

Recipients that select the standard allowance may use that amount — in many cases their full award — for government services, with streamlined reporting requirements. The new guidance clarifies that municipalities must report whether they are electing the standard allowance in their April 30 Project and Expenditure Report. The choice they indicate on that report cannot be changed later.

New deadline for quarterly reports

For municipalities that must file quarterly reports, the reports will cover one calendar quarter and must be submitted to the Treasury by the last day of the month following the end of the period covered. This is a change from the Treasury’s previous position. Under the old rules, a quarterly filer had 30 calendar days after the end of each calendar quarter to file a report.

List of required information expanded

In the updated guidance, the Treasury added a new piece of required information that applies to all local governments’ Project and Expenditure Reports. Local governments should report the program income earned and expended to cover eligible project costs, if applicable.

New Expenditure Categories added

The updated guidance provides an expanded set of Expenditure Categories to reflect the broader flexibility introduced by the final rule. Appendix 1 of the updated guidance includes the new Expenditure Categories. For comparison purposes, it also includes a reference to the previous Expenditure Categories used for reporting under the interim final rule.

Recipients that submitted Project and Expenditure Reports in January will have the opportunity to update their previously selected Expenditure Category, if appropriate.

Subrecipient or beneficiary?

Recipients are accountable to Treasury for oversight of their subrecipients. Local governments should note that subrecipients do not include individuals and organizations that received SLFRF funds as end users. Such individuals and organizations are beneficiaries and not subject to audit pursuant to the Single Audit Act and 2 C.F.R. Part 200, Subpart F.

And more

These new requirements are also worth noting:

  • Local governments must provide detailed information to the Treasury if aid is provided to impacted industries other than travel, tourism, and hospitality.
  • Local governments that pursue water and sewer projects must provide additional reporting data to the Treasury once the project starts.

More information on these and other requirements can be found in the updated Compliance and Reporting Guidance dated Feb. 28, 2022.

Watch the League of Minnesota Cities website for an upcoming webinar on reporting requirements under the American Rescue Plan Act.

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