Deadlines Extended for American Rescue Plan Act Reporting

October 4, 2021

New deadlines for the ARPA Project and Expenditure Report are Jan. 31 for cities over 50,000 in population and April 30 for cities under 50,000 in population.

The U.S. Treasury has provided updated timelines for the Project and Expenditure Report required of all American Rescue Plan Act (ARPA) State and Local Fiscal Relief Fund recipients.

As a result of state and local government feedback, Treasury indicated on Sept. 30 that the submission deadlines for the initial Project and Expenditure Report have been revised. States, territories, counties, metropolitan cities (generally cities above 50,000 in population), and tribal governments will report project and expenditure data on Jan. 31, 2022, instead of Oct. 31, 2021.

The first Project and Expenditure Report deadline for non-entitlement units of local government (NEUs) will be April 30, 2022, instead of Oct. 31, 2021. As a reminder, NEUs are units of government typically serving populations of less than 50,000.

Three ARPA reports

Funding recipients are required to meet compliance and reporting responsibilities. This ensures an equitable, transparent, and responsible recovery for all Americans.

Reporting under ARPA calls for three reports.

  • Interim Report (required for states, U.S. territories, and local governments designated as metropolitan cities that received direct distribution from the U.S. Treasury).
  • Recovery Plan Performance Report (required only for states and U.S. territories and local units of government with a population above 250,000).
  • Project and Expenditure Report (required for all recipients of State and Local Fiscal Relief Funds).

The Interim Report is a one-time report that was due on Aug. 31, 2021. It was required of the 21 metropolitan cities in Minnesota but was not required of NEUs.

The Recovery Plan Performance Report provides the public and the Treasury with information regarding the projects recipients are undertaking with ARPA funding, and delineates plans to ensure program outcomes are achieved in an effective, efficient, and equitable manner. This reporting requirement applies only to states, territories, and metropolitan cities and counties that exceed 250,000 residents. This is not required for NEUs.

Report required for NEUs

The Project and Expenditures Report is required for all recipients, which includes NEUs. This report lists projects funded by ARPA State and Local Fiscal Relief funds. For each project, the recipient will be asked to select the appropriate expenditure category based on the scope of the project.

Recipients will be asked to report on the project’s obligations and expenditures as well as the project status each reporting period. Recognizing the disproportionate impact of the pandemic-related recession on low-income communities, recipients must report whether certain types of projects are targeted to economically disadvantaged communities. Subawards will be reported as well as specific programmatic data based on the type of project.

More information

Treasury will provide recipients with user guides prior to the Project and Expenditure Report deadlines. Further instructions will be provided at a later date, and they may include updates to existing guidance.

For more information on reporting requirements and important guidance, cities can visit Treasury’s website. Any specific questions regarding reporting or requests for additional information can be directed to the U.S. Treasury via email at

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