March 24, 2022
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ARPA ALERT: Updated NACo Analysis of Treasury's Final Rule for the ARPA Fiscal Recovery Fund
On Tuesday, March 22, the National Association of Counties (NACo) released a major update regarding an analysis of the ARPA Final Rule which goes into effect on April 1, 2022. The new analysis includes, but is not limited to the following:

  • Clarifying information on eligible/ineligible uses that NACo has received from Treasury, including capital expenditures;
  • Updated information regarding the provisions relating to revenue loss allocations and the election process of taking the $10 million standard allowance or using the updated revenue loss formula that will be required on the April 30 Project and Expenditure Report;
  • Detailed information regarding the treatment of loans; and
  • Reporting requirements and background information on federal uniform guidance / 2 CFR Part 200.

To access the updated analysis from NACo on the Final Rule, click here.

For a concise summary of the Final Rule, please click here

Project and Expenditure Reporting Deadline is April 30, 2022:

Treasury is now accepting Project and Expenditure reports from Tier 1, and Tier 2 recipients through the reporting portal. As applicable to counties, this includes:

  • Tier 1 – Counties with a population that exceeds 250,000 residents; and
  • Tier 2 – Counties with a population below 250,000 residents YET still received more than $10 million in recovery funds.

Counties with a population below 250,000 residents who received less than $10 million in recovery funds (deemed as Tier 5 recipients by Treasury) must also complete their first Project and Expenditure Report that is also due on April 30, 2022, and then annually thereafter. However, the Treasury submission portal is not yet open for Tier 5 recipients to submit a report. Treasury is likely to open the portal for this group by the end of March. 

Project and Expenditure Reporting Guidance:
Treasury’s updated Reporting Guidance contains an expanded set of Expenditure Categories to reflect the broader flexibility on expenditures introduced by the Final Rule. Counties who submitted Project and Expenditure Reports in January will have the opportunity to update their previously selected Expenditure Category, if appropriate.

Updated Reporting Guidance also states that additional programmatic data for Capital Expenditures is optional in the April 2022 Project and Expenditure Report and is required for the July 2022 Project and Expenditure Report (for Tier 1 and Tier 2 counties).

Counties can access the “Reporting Guidance for the Recovery Fund” on Treasury’s website by clicking here.

For a detailed guide on navigating and using Treasury’s portal to submit Project and Expenditure Reports, please click here.

Treasury also posted a series of recorded webinars to assist recipients with understanding and complying with relevant reporting requirements and to assist recipients in accessing Treasury’s portal:

For technical questions regarding the Treasury reporting portal, please contact

Please contact SCAC Staff Attorney John Wienges with any questions.