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  • Writer's pictureNCLM

Treasury Releases Reporting, Compliance Instructions for ARP Funds

The U.S. Treasury published an up-to-date and detailed document Thursday outlining reporting requirements of all recipients of American Rescue Plan funds, including both metropolitan and non-entitlement units.

The document, titled “Coronavirus State and Local Fiscal Recovery Funds Guidance on Recipient Compliance and Reporting Responsibilities,” provides information and clarification on the compliance and reporting responsibilities of all local governments. A few important summarized notes from the document are below:

1. Balance promptness with patience and prudence

Treasury makes a point to note that while funds are expected to be used quickly to provide economic relief to all communities, funds must also be used judiciously, as strict documentation practices will be required. Expenses must be eligible and must be properly reported.

From the document:

Swift and effective implementation is vital, and recipients must balance facilitating simple and rapid program access widely across the community and maintaining a robust documentation and compliance regime.”

2. Reporting requirements

Beginning on page 16, Treasury provides detailed instructions on what information will be needed for annual Project and Expenditure Reports, which are required of all ARP fund recipients.

Information will be required in each of the following areas:

  • Projects

  • Expenditures

  • Project status

  • Project demographic distribution

  • Subawards

  • Civil rights compliance

  • Programmatic data, for the following expenditure categories

    • Payroll for public health and safety employees

    • Household assistance

    • Small business economic assistance

    • Aid to travel, tourism, and hospitality or other impacted industries

    • Rehiring public sector staff

    • Education assistance

    • Premium pay

    • Revenue replacement

  • Programmatic data, for the following infrastructure-related categories

    • All infrastructure

    • Water and sewer

    • Broadband

    • Distribution information

Additional reporting instructions—including information on allowable activities, administrative costs, matching and earmarking requirements, and cash management—can be found on pages 6-9, and reporting information relevant specifically to metropolitan cities can be found beginning on page 12.

3. A User Guide will be provided soon

On page 20, when detailing reporting requirements of expenses used to offset pandemic-related revenue loss, Treasury notes that “additional instructions and/or template to be provided in user guide.”

That user guide will be provided on this site immediately once published.

The entire document can be found here in the link below. Additionally, U.S. Treasury’s webpage on this reporting and compliance can be found here. This information has been included on our ‘U.S. Treasury Guidance’ page.

Download PDF • 1000KB


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