June 15, 2022
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ARPA Alert: Treasury's Updated Guidance on ARPA Reporting
Last week, Treasury released updated reporting guidance for the Project and Expenditure (P&E) Reports and a new template for the Recovery Plan Performance Report (Recovery Plan) ahead of the July 31, 2022, reporting deadline. The new requirements outlined below will impact all counties regardless of population size and award amount.
Key updates to the compliance and reporting guidance outlined by Treasury include:
  1. Additional programmatic data for capital expenditures: When using Recovery Funds for capital expenditures projects, counties need to report the type of expenditure based on a list of enumerated uses. Examples of enumerated uses are COVID-19 vaccination sites, job and workforce training centers, and public health data systems. A full list of enumerated uses is available on pages 27 to 28 of the updated guidance.
  2. Written justification for capital expenditures: Counties are required to provide a written justification for capital projects of any category that cost at least $10 million and for projects in the “other” (i.e., project not explicitly enumerated by Treasury) category that cost at least $1 million. Previously, counties needed to create a written justification for these projects but were not required to submit them as part of regular reporting.
  3. Description of labor requirements for capital expenditures: Counties are required to provide additional labor reporting. For projects that cost at least $10 million, counties will need to report on the strength of the project’s labor standards, including information on the presence of a project labor agreement, community benefits agreement, prevailing wage requirement, or local hiring. This new required information is outlined under Infrastructure Projects on pages 30-31 of the updated guidance.
  4. Project information for broadband projects: The updated guidance requires counties to provide detailed project information for broadband infrastructure investments. Counties need to report what kind of technology is involved in the project (i.e., fiber optic cables, coaxial cables, etc.), the total miles of fiber deployed over the project, and the total number of funded locations served broken out by both speed of connection and type of location (i.e., residential, business, or community). This new required information is outlined under Broadband Projects on pages 32-33 of the updated guidance.
  5. Moving of Recovery Plan Performance Report data into P&E Report: Under the updated guidance, some of the data that was previously only required for the Recovery Plan Performance Report (Recovery Plan) is now required for large counties (i.e., populations above 250,000 and/or above $10 million in awards) on their quarterly P&E Report. For example, large counties investing in housing security programs must now report the number of households receiving eviction prevention services. A full list of changes to programmatic data requirements for large counties is available on page 33 of the compliance and reporting guidance.
  6. Updated template for Recovery Plan: The updated guidance also provides a template for the Recovery Plan Performance Reports due for counties with a population of 250,000, or above, on July 31, 2022, reflecting the expenditure categories and other changes made by the Final Rule.

Counties are currently preparing to receive their second tranche of funding, which will be allocated by Treasury no earlier than 12 months after a county certified for its first tranche.

Earlier this month, Treasury released new information on the second tranche payment process and how counties can ensure they are prepared for quick certification.  

Counties should familiarize themselves with the information below as they prepare for second tranche payment certification:

  • Section 603 of ARPA provides payments to eligible local governments in two tranches, with the second tranche payment being made no earlier than 12 months after the first payment.
  • Consistent with this requirement, Treasury expects to provide second tranche payments to local governments approximately 12 months after their first payment.
  • In the coming weeks, Treasury will open the submission portal in a phased approach, allowing counties to access the portal for 30 days prior to their second tranche payment date.
  • Counties will receive a notification from Treasury by email letting them know that they can enter the portal. It is very important to make sure that the assigned point of contact is still available to receive future communications.
  • The point of contact is the individual designated in the portal during the first tranche submission who will receive email notifications on submission status, including any issues found during the verification and communication regarding payments.
  • The individual entering the portal for the second tranche submission will be the same individual with the registered ID.me who submitted for the first tranche allocation.
  • If that individual is no longer with the county and you need to designate a new individual, email [email protected] with the subject line "Entity Name - Update to Designated Individuals" and include the role that needs to be updated along with the full name, title, email and phone number of the new person designated.
  • After the email is received by the county, the point of contact will be able to update their entity information to include banking information in the portal.
  • In preparation for the second tranche payment, counties should ensure their SAM.gov entity registration is still active. All counties are required to have a SAM registration to receive their second tranche payment. Please note that the identification number for SAM.gov has been changed from the DUNS Number to the Unique Entity ID (UEI).