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ARPA Alert: Reporting Deadlines, New Reporting Guidance, and Final Rule Information
PROJECT AND EXPENDITURE REPORTING DEADLINES
The first “Quarterly Project and Expenditure Report” is due by January 31, 2022, for counties with populations that exceed 250,000 residents or counties with a population below 250,000 residents that were allotted more than $10 million in Recovery Funds. These reports will cover the period between March 3, 2021, and December 31, 2021, and require the reporting of project, obligations, and expenditure data, subaward data, as well as certain other required programmatic data.
The following South Carolina counties are required to submit their first “Quarterly Project and Expenditure Report” by January 31, 2022, and on a quarterly basis following the first report:
The remaining 22 counties in South Carolina with populations below 250,000 residents and who were allotted less than $10 million are not required to submit a “Project and Expenditure Report” by January 31, 2022. The first reporting deadline for these counties will be on April 30, 2022, and these counties will be required to submit a report annually afterward.
ARPA FINAL REPORT INFORMATION
On January 6, 2022, Treasury adopted a final rule implementing the Coronavirus State and Local Fiscal Recovery Funds (SLFRF). The final rule takes effect on April 1, 2022, and recipients must comply with the rule once it takes effect. Until that time, the interim rule remains in effect, and recipients may take actions and use funds in a manner consistent with the interim final rule if a use of funds is consistent with the terms of the final rule, regardless of when the SLFRF funds were used. This means that Treasury will not take action to enforce uses of the interim final rule to the extent that the recipient wishes to change its planned uses of SLFRF funds in a manner consistent with the final rule. For additional details, please refer to the “Statement Regarding Compliance with the Coronavirus State and Local Fiscal Recovery Funds Interim Final Rule and Final Rule” which can be accessed on Treasury’s website.
Key highlights of the new guidance:
The final rule is effective April 1, 2022, but counties can take advantage of flexibility prior to that date.
- Allows counties to use up to $10 million of ARPA Recovery Funds as “loss revenue” for the provision of general government services without needing to use the Treasury revenue loss formula.
- Improves revenue loss calculation formula to include utility revenue and liquor store sales, at the option of counties, and the revenue loss growth rate is changed from 4.1 percent to 5.2 percent.
- Clarifies eligible use of funds for capital expenditures and written justification for certain projects.
- Presumes certain populations were “impacted” and “disproportionately impacted” by the pandemic and therefore are eligible to receive a broad range of services and support.
- Streamlines options for premium pay, by broadening the share of eligible workers who can receive premium pay.
- Authorizes re-hiring of local government staff, either at or above pre-pandemic levels.
- Allows Recovery Funds to be used for the modernization of cybersecurity, including hardware and software.
- Broadens eligible use of funds for water and sewer projects to include culvert repair, dam, and reservoir rehabilitation.
- Broadens eligible broadband infrastructure investments to ensure better connectivity to broader populations.
NEW REPORTING GUIDANCE