It’s hard to believe we’re just a about three months shy of the second anniversary of the American Rescue Plan Act, otherwise known as ARPA. In two more years, or on December 31, 2024, State and Local Fiscal Recovery Funds or SLFRF – a part of ARPA – must be obligated. Then, two years later – by December 31, 2026 – SLFRF must be fully spent. Are you on track to meet these deadlines?
A report entitled, A Comparison of Fiscal Recovery Funds Utilization, notes: “The eligible uses of SLFRF are intentionally broad to provide state and local governments with substantial flexibility to respond to pandemic impacts in their community, including general operating support to offset revenue losses while also encouraging them to make investments that support long-term growth, opportunity, and equity.”
As noted by the Treasury Department, “Recipients may use SLFRF funds to:
- Replace lost public sector revenue, using this funding to provide government services up to the amount of revenue lost due to the pandemic
- Respond to the far-reaching public health and negative economic impacts of the pandemic, by supporting the health of communities, and helping households, small businesses, impacted industries, nonprofits, and the public sector recover from economic impacts
- Provide premium pay for essential workers, offering additional support to those who have and will bear the greatest health risks because of their service in critical sectors
- Invest in water, sewer, and broadband infrastructure, making necessary investments to improve access to clean drinking water, to support vital wastewater and stormwater infrastructure, and to expand affordable access to broadband internet.”
You can find more details about categories and definitions on the National Conference of State Legislatures website. For information on how states are using funds, visit the Center on Budget and Policy Priorities. For information on allocations for cities and counties or how they are using funds, click here.
While you’re finalizing plans to ensure funds are obligated by the deadline, be sure to update your calendar with these quarterly Project and Expenditure Report deadlines: January 31, 2023 (for the period October 1 – December 31, 2022); April 30, 2023 (for January 1 – March 31); July 31, 2023 (for April 1 through June 30); and October 31, 2023 (for July 1 – September 30).
If you’re only required to submit an annual project and expenditure report, the next deadline is April 30, 2023. This covers the period from April 1, 2022 through March 31, 2023. An annual report is required from Tribal governments allocated less than $30 million; metropolitan cities and counties with less than 250,000 residents and less than $10 million in funding; and Non-Entitlement Units (NEUs) with less than $10 million in funding.
For additional information, refer to these resources:
- S. Department of the Treasury Compliance and reporting guidelines and deadlines and Overview of the Final Rule
- National Association of Counties ARPA Investment Tracker
- General Finance Officers Association Recommended Guiding Principles
- National League of Cities ARPA Local Relief Frequently Asked Questions
- Project and Expenditure Report User Guide(July 2022)
You can find additional resources on our website (go to the right of the screen and click “ARPA Downloads.”)
If you need any accounting, tax, or audit assistance with your SLFRF or other funds, please give RBT CPAs a call. We’re a leader in the Hudson Valley and beyond, known for our professionalism and integrity. We believe we succeed when we help you succeed. Contact us today.