Eligible Expenditures

How to spend these appropriations will be a key question for our municipalities over the next several years. Certain spending categories, such as water and wastewater infrastructure, have broad eligibility. Others are less clear. 

On this page, we will provide clarity on eligible expenditures as information becomes available. 

Table of Contents
Allowable Uses as Noted in the Law
Use of funds:
  1. Respond to the COVID-19 emergency and address its economic effects, including through aid to households, small businesses, nonprofits, and industries such as tourism and hospitality.

  2. Provide premium pay to essential employees or grants to their employers. Premium pay couldn’t exceed $13 per hour or $25,000 per worker.

  3. Provide government services affected by a revenue reduction resulting from COVID-19.

  4. Make investments in water, sewer and broadband infrastructure.

Restrictions of Funds:
  • State and local governments cannot use the funds towards pensions or to offset revenue resulting from a tax cut enacted since March 3, 2021.

Transfer Authority
  • State and local governments could transfer funds to private nonprofit groups, public benefit corporations involved in passenger or cargo transportation, and special-purpose units of state or local governments, but only as allowed under state law and state constitutional provision.

Water and Wastewater

This category offers broad flexibility and clear eligibility. It also stands as an area of significant need in North Carolina.

ARP Infrastructure Report

The League encourages municipalities to consider investment into water and wastewater infrastructure. This recommendation is made understanding the constraints of the ARP and the realities of North Carolina’s existing infrastructure challenges. Making investments in infrastructure represents one of the most likely paths to a lasting funding legacy.


The need, the eligibility, and the potential, all covered in-depth in the ARP Infrastructure Report

Eligibility through the CWSRF and DWSRF

Local ARP funds are eligible to be spent on any project that is eligible under the federal Clean Water and Drinking Water State Revolving Funds. Examples of eligible project categories include water treatment, water transmission and distribution, and centralized wastewater treatment.

The eligibility handbooks for these programs are linked below:

  • CWSRF Eligibility Handbook

  • DWSRF Eligibility Handbook

Clean Water State Revolving Fund Eligibilities
Drinking Water State Revolving Fund Eligibilities
Premium Pay

NCLM Research Strategist Tammy DePhillip has detailed this spending category in our ARP blog, and you can read that full post here.

Key points covered:

  • What is the intention of this spending category?

  • What is considered premium pay?

  • Who is eligible for premium pay?

  • How is premium pay calculated?


Read More | Premium Pay: Who is Eligible and For How Much?

Replacement Revenue

An eligible use of ARP funds for cities and towns is the replacement of lost revenue due to the COVID-19 pandemic, and federal guidance provides a formula by which to determine that number. 

To help with the calculations, we have published an online calculator created by the Government Finance Officers' Association. That calculator can be found on our blog, here


Read More | Calculate Your Town's COVID-19 Lost Revenue

U.S. Treasury Guidance

  • The U.S. Treasury issued official interim guidance on allowable uses for ARP funds by local governments in May 2021. That guidance, as well as all subsequent updates, has been posted to our U.S. Treasury guidance page, here

  • A high-level fact sheet of allowable uses has been published by the U.S. Treasury, and can be read here.

  • NCLM's summary of Treasury's interim guidance on the State and Local Recovery Funds program can be read below.