ARP Update for the New Year, from UNC SOG
As we move into 2022, here is where things stand with the American Rescue Plan.
Below is an update on the American Rescue Plan (ARP) and Coronavirus State and Local Fiscal Relief Fund (CSLFRF) from the UNC School of Government. We thank UNC for their continued partnership on the ARP, and we urge our local leaders to take advantage of their regular ARP Office Hours.
ARP Office Hours dates and login information is available on our Events page.
ELIGIBILITY DETERMINATIONS. We are still awaiting the Final Rule from US Treasury. Local governments may continue to make expenditure decisions based on the Interim Final Rule and US Treasury FAQs. (But be cautioned that there are several grey areas where we need more guidance from US Treasury, particularly related to compliance provisions.) We have blog posts here covering several specific eligibility issues. And there are great resources from the NCLM and NCACC.
POTENTIAL NEW LEGISLATION: FLEXIBILITY ACT. We also are still waiting to see if the US House enacts H5735, which, among other things, would expand general government eligible expenditures. (The US Senate passed it as S3011.)
UG COMPLIANCE. All local governments must adopt several policies and procedures to comply with the Uniform Guidance requirements. We will continue to roll out sample policies this winter. Current samples/templates include:
2. project file checklist/eligibility determination worksheet
3. reporting template (to track all required project data)
4. allowable costs sample policy and implementation tools
Future samples/templates will cover subawards, procurement, property management, program income, document retention, and general internal controls. (Look for these in the coming weeks).
REPORTING. US Treasury has put out detailed guidance on what local governments must report on in the Project and Expenditure report. You will be reporting on obligations, expenditures, and other relevant data at the project level. As per above, this reporting template is a tool to help local governments track all the relevant data.
Counties and Metropolitan Cities ONLY: Your first Project and Expenditure Report is due by January 31, 2022. Look for more info from US Treasury on how to access the portal and the specific reporting format in the coming days.
NEUs (municipalities under 50,000 population) ONLY: Your first Project and Expenditure Report is not due until April 30, 2022, but you need to register for the reporting portal as soon as possible. US Treasury sent an email to the designated administrator in your unit with further instructions. More info is available here.
OFFICE HOURS. We will continue to hold weekly Office Hours for the foreseeable future. Feel free to join at any time to ask questions and learn about what other local governments are doing or considering. We do not record the Office Hours but will start to do some polling that we will make available more generally. We will be using some Office Hours to introduce new sample policies and/or cover other updates and hot topics.