American Rescue Plan Act Coronavirus State and Local Fiscal Recovery Fund: Important Deadlines and Updates for April 2024 and Beyond
If you have obligated and expended all your American Rescue Plan Act Coronavirus State and Local Fiscal Recovery funds (ARP/CSLFRF), congrats, you are done forever with this grant. April Fools! Even if you have obligated and expended all your ARP/CSLFRF funds, there is still more to do. And if you have not yet obligated or expended all your ARP/CSLFRF funds, there is even more to do. ARP/CSLFRF never ends! Ok, that is a bit of an exaggeration but meant to drive home the point that we are not quite done, despite our wishful thinking.
2024 is an important year – by December 31, 2024, every local government must obligate ALL their own ARP/CSLFRF funds. Before we get there, though, we must get through April 2024, which is the month that ALL local governments must complete a Project and Expenditure Report for US Treasury. This post summarizes important information related to these deadlines, addresses some frequently asked questions, and identifies resources to help local government officials navigate through the remainder of 2024.
April 2024 Project and Expenditure Report
All local governments must complete, certify, and submit a Project and Expenditure (P&E) report during the month of April. For units who received over $10 million in your own ARP/CSLFRF allocation, this is just the next installment of your quarterly reporting. For units that received between $0 and $10 million in your own ARP/CSLFRF funds, this fulfills your annual reporting requirement. (Note that you do not include any state grants or direct appropriations of state ARP/CSLFRF funds in your own P&E report. The State will report on these funds.)
FAQs for $0-$10 million local governments
Below are answers to some frequently asked questions for units that received between $0 and $10 million in their own ARP/CSLFRF allocation. Also included are links to resources related to select FAQs, including a portal infographic and portal tutorial guide.[1]
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- We fully obligated and expended all our ARP/CSLFRF funds before the last P&E report (in April 2023), do we need to complete the report this year? YES! You must complete the P&E report each year through the end of the grant term, or until Treasury issues formal close out instructions. If you have nothing new to report, you will simply log into the reporting portal, verify that you selected the standard allowance, and certify and submit the report with no other changes.
- We’ve had staff turnover in the past year, how do we access the portal? If the person who served as the Account Administrator for the reporting portal is no longer with the unit, you will need to assign a new employee or official for this role. That person must register through login.gov and then your manager, administrator, mayor, or other board member must email Treasury to have the person assigned as the new Account Administrator. Click on this infographic for detailed instructions and links to help you complete this process. If the Account Administrator is still with the unit but the Authorized Representative for Reporting is not, the Account Administrator must log into the portal and assign a new person as the Authorized Representative for Reporting. Treasury will then prompt that person to register through login.gov. This portal tutorial provides more specific step-by-step instructions.
- We did not (or we are not sure if we did or did not) select the Standard Allowance option in previous reports, can we select it now? YES! Treasury is allowing a unit to continue to select the Standard Allowance with the April 2024 P&E report. All units that received between $0 and $10 million should select the Standard Allowance. In the portal you will navigate to the Recipient Specific screen to verify you have selected the Standard Allowance or to select it. This portal tutorial walks you through the process.
- Is there a guide to the P&E portal? Treasury usually releases as updated guide before the April P&E report. As of this writing, Treasury has not updated the guide for April 2024. But Treasury did update the portal user guide in January 2024. Here is a link to that guide and to a tutorial video on the portal. (I’ll update this post if a new guide comes out in the next several days.) And, again, we’ve compiled a portal tutorial that addresses common portal issues.
- Can we make changes to projects we reported in the past and/or cancel projects and add new ones? Yes, and yes. The portal tutorial guides you through this process. We highly encourage any unit that received between $0 and $10 million and previously reported projects outside of the revenue replacement category (EC 6.1 or 6.2) to cancel those projects and instead report the same obligations and expenditures in the revenue replacement category. Any project that can be done in another category can be done as a revenue replacement project, with far fewer compliance and reporting requirements. In fact, all expenditures may be reported as a single revenue replacement project in the portal, even if they are separate projects for budgeting purposes.
- Wait, what is revenue replacement? Revenue replacement is one of the eligible ARP/CSLFRF categories. The grant allows all local governments to spend up to their full allocation (up to a total of $10 million) in this category — that’s the Standard Allowance! A local government may use monies in this category for almost any expenditure it has state law authority to engage in. There are three main ways to spend funds in this category. The simplest is to use ARP/CSLFRF funds to reimburse for past expenditures, dating back to March 3, 2021. The second is to use ARP/CSLFRF funds to cover future salaries and benefits of all (or almost all) local government employees. And the third is to use ARP/CSLFRF to directly fund new programs and projects. All of these can happen within the revenue replacement category. Here is a roadmap to help you navigate through the revenue replacement category. And here, here, here, and here are other pertinent blog posts. Finally, ncfinanceconnect.com has lots of resources, including sample policies and documentation templates to ensure you are following all the revenue replacement compliance requirements.
- If we’ve obligated and expended all our ARP/CSLFRF funds, can we be done reporting after this? Unfortunately, no. Although Treasury allows local governments to lock projects that are completed in the portal, local units must continue to complete the annual P&E report. Having said that, Treasury has added a question to the portal this year asking units if they are done and ready to close out. If you answer yes to this question, it does not mean you have closed out the grant. It simply will provide info to Treasury about who may be ready to close out. Treasury will follow-up in the future with specific instructions about how to close out the grant. Until then, be prepared to complete the annual P&E report. (The last possible report is April 2027). And, of course, retain ALL documentation related to the grant at least 5 years after expenditure of the last grant dollar.
FAQs for Over $10 million local governments
As stated above, for units that received over $10 million in their own ARP/CSLFRF allocation, the April 2024 P&E report is just the next quarterly report. There are a few important updates, though.
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- Do we need to indicate in our April 2024 P&E report estimated grant-related costs that we expect to obligate after December 31, 2024, under the new obligation definition? No. Treasury has extended the deadline to report on these estimated costs to the July 31, 2024 P&E report. If you are not sure what this is referring to, see below info on Treasury’s Interim Final Rule and FAQs on certain “exceptions” to the obligation deadline.
- If we’ve obligated and expended all our ARP/CSLFRF funds, can we be done reporting after this? Unfortunately, no. Although Treasury allows local governments to lock projects that are completed in the portal, local units must continue to complete the quarterly P&E reports. Having said that, Treasury has added a question to the portal this month asking units if they are done and ready to close out. If you answer yes to this question, it does not mean you have closed out the grant. It simply will provide info to Treasury about who may be ready to close out. Treasury will follow-up in the future with specific instructions about how to close out the grant. Until then, be prepared to complete the annual P&E report. (The last possible report is April 2027). And, of course, retain ALL documentation related to the grant at least 5 years after expenditure of the last grant dollar.
December 31, 2024 Obligation Deadline
Once we get through April, the next big deadline is December 31, 2024. All ARP/CSLFRF funds must be obligated by this date. An obligation happens when a local government hires an employee, issues a PO to a vendor, or enters a contractual relationship with another party whereby the local government legally commits to pay ARP/CSLFRF funds to the other party in exchange for goods or services. (It is when the preaudit requirement is triggered.)
Units that received between $0 and $10 million, should treat December 31, 2024, as both the obligation and expenditure deadline. (An expenditure occurs when the amount is due and owing to the other party.) Most, if not all, of these units can fully expend all their ARP/CSLFRF funds by this date using one or more of the three paths through the revenue replacement category detailed above.
For units that received over $10 million, Treasury is providing some relief from the obligation deadline. It issued an Interim Final Rule on an expanded definition of obligation in November 2023. We are still waiting on a final rule, but Treasury has recently provided more guidance on how to implement the IFR in its ARP/CSLFRF FAQs (see new Section 17). This new guidance significantly expands on the IFR relief from the obligation deadline and authorizes several different types of obligations after December 31, 2024, including for cost overruns and new staff to fill existing positions. More on this in an upcoming blog post.
ARP/CSLFRF Office Hours & Portal Triage Office Hours
We are still here to help. The School of Government will continue to hold weekly office hours to address ARP/CSLFRF and other finance-related questions. Additionally, during the month of April 2024, we’ve added Portal Triage Office Hours for $0-$10 million units, staffed by our LFNC Fellow, LaShonda Sousa. Feel free to drop in if you have any portal-related questions or difficulties.
Upcoming Regular ARP/Finance Office Hours
Thursday, April 4, 12-1pm (focus on expanded “obligation” definition)
Wednesday, April 10, 12-1pm
Friday, April 19, 8:30-9:30am
Wednesday, April 24, 8:30-9:30am
Monday, April 29, 8:30-9:30am
Zoom Link: https://zoom.us/j/95481909044?pwd=UlE2VHNhN2luS0JEYTJqeTZTMFRWdz09
Meeting ID: 954 8190 9044
Passcode: 779726
One tap mobile
+16469313860,,95481909044# US
+19292056099,,95481909044# US (New York)
Portal Triage Office Hours for the April 2024 Project & Expenditure Report ($0-$10 million units only)
Zoom Link: https://unc.zoom.us/j/94025737460
Note that this is a separate Zoom link from regular office hours.
Week 1 of April
Tuesday, April 2, 9:00-10:00 am
Wednesday, April 3, 12:00-1:00pm
Thursday, April 4, 2:00-3:00pm
Week 2 of April
Monday, April 8, 12:00-1:00pm
Tuesday, April 9, 9:00-10:00 am
Week 3 of April
Monday, April 15, 9:00-10:00 am
Wednesday, April 17, 12:00-1:00pm
Thursday, April 18, 3:00-4:00pm
Week 4 of April
Monday, April 22, 12:00-1:00pm
Tuesday, April 23, 9:00-10:00 am
Thursday, April 25, 3:00-4:00pm
Friday, April 26, 9:00-10:00 am
Week 5 of April
Monday, April 29, 9:00-10:00 am
[1] Special thanks to MPA student Elizabeth Wilkes and LFNC Fellow LaShonda Sousa for their help in compiling and creating the resources.
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