The U.S. Treasury Department released important clarifications on how to report revenue replacement and other expenditures in the Project and Expenditure Report for the American Rescue Plan Act (ARPA) Coronavirus State and Local Fiscal Recovery Fund.
1. Option to defer the choice of claiming $10 million standard revenue loss allowance
If a county has not decided whether or not to receive the standard allowance, Treasury will not commit the county to the reported choice in the January 31 report. Decisions made in the reporting on the standard allowance as part of the January 31 Project and Expenditure Report may be changed in the April 2022 Project and Expenditure Report when the Final Rule takes effect. More guidance on this will be released as that reporting period approaches.
If a county has nothing to report in the Revenue Replacement section and does not want to make any choice, the county may enter zero in the required fields and use the description box to explain that it has not yet allocated funds under revenue loss and will update the response in future reporting cycles. Treasury may choose to follow up in these cases for further details.
2. What to do if a county has no projects to report on the January 31 Project and Expenditure Report
If your county has not yet identified any projects to report, please know that maintaining a project list is a core requirement of the Recovery Fund program.
For the Project and Expenditure Report due January 31, 2022, Treasury will be offering an option to select “No Projects to Report” at this time. Selecting this option will require providing a written explanation and may result in additional compliance follow-up from Treasury. Please see the user guide for additional guidance. Information will also be provided in the Project Overview module of the Project and Expenditure Report. For additional support, please email SLFRP@treasury.gov
3. Additional resources and helpful information from Treasury
If you are unable to log in to Treasury’s State, Local, and Tribal Support portal after establishing your accounts or need assistance, please email email@example.com
Treasury has posted a series of recorded webinars to assist recipients to understand and comply with relevant reporting requirements and assist recipients in accessing Treasury’s portal:
As a reminder, the following counties are required to submit a Project and Expenditure Report to the Treasury by January 31, 2022:
Counties with populations that exceed 250,000 residents (referred to as Tier 1 recipients by Treasury)
Counties with populations below 250,000 residents and received more than $10 million in Recovery Funds (referred to as Tier 2 recipients by Treasury)
The Project and Expenditure Report will cover the period between March 3 and December 31, 2021, and requires the reporting of project, obligations and expenditure data, subaward data, as well as certain required programmatic data.
Please contact SCAC Staff Attorney John Wienges
with any questions.