Frequently Asked Questions

NCLM Answered FAQs
Can ARP funds be used to pay the regular salary and benefits for employees?

The regular salary and benefits  for public safety, public health, health care, human services, and similar employees can be funded with ARP to the extent that they are completing work directly related to the public health response. The allowed use of funds is under the “respond to public health emergency” eligible funding category in the U.S. Treasury guidance.


Can ARP funds be used to provide premium pay to employees?

Premium pay is in addition to an employee’s regular salary and benefits. In recognition of the health and safety risks of essential workers who have been and continue to be relied on to maintain continuity of operations, ARP funds can also be used to provide premium pay. Essential workers are those whose work involves regular in-person interactions or regular physical handling of items that were also handled by others. The allowed use of funds is under the “premium pay” eligible funding category in the U.S. Treasury guidance.

Is Council approval required to receive ARP funds?

To the best knowledge of both the N.C. League and the N.C. Office of State Budget and Management, Council approval is not a requirement of the American Rescue Plan. However, it may be required by the rules of your local government. Thus, it is included in the checklist to ensure that funds are received in a timely manner, should that step be needed in your city or town. 

What is the definition of "budget" for the purpose of the 75 percent cap of NEU, or non-CDBG, payments?

Treasury interprets the most recent budget as the NEU's most recent annual total operating budget, including its general fund and other funds, as of January 27, 2020. 

How many payment distributions will be received? When will the distributions be received?

Local governments will receive funds in two payments, with 50% provided beginning in May 2021 and the balance delivered 12 months later.


Will 2020 Census data change distribution amounts?

Distributions were calculated based on 2019 Census population data, Treasury provided no indication that distribution amounts will be changed to reflect 2020 Census data.


Can funds be used to match federal grants?

Funds are subject to any pre-existing limitations of Federal statue and regulations. Funds cannot be used as a non-Federal match for other Federal programs that restrict the use of Federal funds to meet matching requirements.


What is the best resource for information on how funds can be used?

Treasury’s Interim Final Rule provides guidelines and principles for determining the types of programs and services that funding can support. The guidance provides examples of allowable uses that recipients may consider. Within the categories of eligible uses, recipients have broad flexibility to decide how best to use this funding to meet the needs of their communities.

Is a DUNS number the same as the Federal Tax Identification Number or EIN?

No, these are different and both are needed to contract with the State to receive Coronavirus Local Fiscal Recovery Funds. A Data Universal Number System (DUNS) number is a unique nine-character number used by the federal government to track how federal money is allocated. This is distinct from Employer Identification Numbers, which are issued for the purpose of tax administration. Also, an entity’s legal name is the same as the one used for the Federal Tax Identification Number.

What is the Pre-Contracting May 24th deadline and what if we miss it?

The May 24th deadline is specific to NCPRO. Though the deadline is an important one to ensure your non-entitlement unit receives its funds efficiently and accurately, failure to meet the deadline does not disqualify a local government from receiving Coronavirus Local Fiscal Recovery Funds. NCPRO understands that local governments are operating under extraordinary circumstances and appreciates your help in facilitating the distribution of these funds.

Do Coronavirus Local Fiscal Recovery Funds need to be set up in a new or unique bank account?

No, but it is essential that you have a way to track the expenditure and use of these funds separately from all other funds you manage, including any other Coronavirus Relief Funds you have already received. The U.S. Department of Treasury is already advising that most of the provisions of the Uniform Guidance (2 CFR Part 200) apply to the Coronavirus Local Fiscal Recovery Funds program, including the Cost Principles and Single Audit Act requirements. NCPRO is compiling more information and guidance, and the Treasury will make its Assistance Listing available at for detail on the specific provisions of the Uniform Guidance that do not apply to this program.

I have been asked to resubmit the Substitute W-9 Form because the information entered doesn’t match what’s on file with the Internal Revenue Service. Can you clarify?

All tax identification numbers and titles (SSN; EIN; ITIN; DUNS; and legal name) provided to the State must match what is on file with the IRS. One common example here is that the legal name entered into the State’s Substitute W-9 Form must exactly match the legal name provided to the IRS. For example, if a municipality’s legal name on an IRS Form W-9 is “Springfield, Town of” then it must appear exactly the same way on the State’s Substitute W-9 Form. An entry of “Town of Springfield” on the State’s form in this example would not match the legal name on file with the IRS and would cause the NC Office of the State Controller to reject this form for correction. For any questions about the State’s Substitute W-9 Form, or any resubmission questions, contact NCPRO. Please do not contact the NC Office of the State Controller or submit any documents to the OSC.   

My municipality’s financial information, including the Vendor Electronic Payment Form, is already on file with the Office of the State Controller. Do I need to re-submit the forms again just for the ARP? 

Yes. The N.C. Pandemic Recovery Office has asked that every municipality submit the requested forms, even if they are resubmissions, to ensure that the State can meet the Federal timeline for dispersing Local Fiscal Recovery Funds. Please select the “Change/Update” box at the top of the form and write your current information in the “New Information” box, and the Office of the State Controller will ensure that this is the information used for ARP fund distribution.

Questions about the Vendor Electronic Payment Form should be directed to N.C. PRO at or the League at


Below is an extensive list of FAQs, as compiled by the U.S. Treasury.


NCLM will continue to share resources for assistance in interpreting the Treasury guidance. For questions specific to North Carolina municipalities, please do not hesitate to contact us at for guidance.


U.S. Treasury FAQs - Nonentitlement Units
U.S. Treasury FAQs - Full State and Local ARP Funding Program