Member Alert:
Treasury Issues Updated FAQs On Use of American Rescue Plan Act (ARPA) Funds
June 24, 2021
The U.S. Treasury has released updated an FAQ on the Coronavirus State and Local Fiscal Recovery Funds from the American Rescue Plan Act (ARPA), which you can access HERE.
 
Treasury has stated it intends to update its FAQs periodically to help clarify questions about the ARPA Interim Final Rule, and these updated documents do not reflect all of Treasury’s planned clarifications regarding ARPA guidelines.
 
The updated FAQ now includes additional clarification on points that have been raised by a number of stakeholders, including:
 
·        Demonstrating negative economic impact for household and business assistance
·        Use of funds for investment in outdoor spaces
·        Use of funds to address a backlog in court cases
·        Use of funds to assist business startups
·        Use of funds to prevent and respond to crime and support public safety
·        Use of funds for pre-project development for water/sewer/broadband infrastructure
·        Treatment of federal funds in intergovernmental revenue when calculating general revenue for the purpose of identifying revenue loss
·        The updated document also includes an appendix with a diagram of the Interim Final Rule’s definition of General Revenue within the Census Bureau’s classification structure, and an FAQ focused on how funds can support a holistic approach to public safety.
 
The new questions added to the FAQ are listed below: 
 
CSFRF/CLFRF FAQs Added June 23
 
·        In order to receive and use Fiscal Recovery Funds, must a recipient government maintain a declaration of emergency relating to COVID-19?
·        The Interim Final Rule states that “assistance or aid to individuals or businesses that did not experience a negative economic impact from the public health emergency would not be an eligible use under this category.” Are recipients required to demonstrate that each individual or business experienced a negative economic impact for that individual or business to receive assistance? 
·        Would investments in improving outdoor spaces (e.g. parks) be an eligible use of funds as a response to the public health emergency and/or its negative economic impacts?
·        Would expenses to address a COVID-related backlog in court cases be an eligible use of funds as a response to the public health emergency?
·        Can funds be used to assist small business startups as a response to the negative economic impact of COVID-19?
·        How can I use CSFRF/CLFRF funds to prevent and respond to crime, and support public safety in my community?
·        In identifying intergovernmental revenue for the purpose of calculating General Revenue, should recipients exclude all federal funding, or just federal funding related to the COVID-19 response? How should local governments treat federal funds that are passed through states or other entities, or federal funds that are intermingled with other funds?
·        May recipients use Funds for pre-project development for eligible water, sewer, and broadband projects?
·        [New appendix] Diagram of Interim Final Rule Definition of General Revenue within the Census Bureau’s Classification Structure of Revenue
 
We will continue to keep our members up to date on all ARPA guidance as it is released. 
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