On Tuesday, January 25, the U.S. Treasury Department (Treasury) released important clarifications on how to report revenue replacement and other expenditures in the ARPA Project and Expenditure Report.
1. Option to defer choice of claiming $10 million standard revenue loss allowance: If a county has not decided whether or not to take the standard allowance, Treasury won’t commit them to their reported choice in the January 31st report.
- Decisions made in the reporting around the standard allowance as part of theJanuary 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 we approach that reporting period.
- If a county has nothing to report in the Revenue Replacement section and doesn’t want to make any choice, they may enter zero in the required fields and use the description box to explain that they have not yet allocated funds under revenue loss and will update their 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. If you have questions or need additional information, please send an email viaSLFRP@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 technical or other assistance, please send an email to covidreliefitsupport@treasury.gov for assistance.
- 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, the following counties are required to submit a Project and Expenditure Report the Treasury by January 31, 2022:
- Counties with populations that exceed 250,000 residents (referred to as Tier 1 recipients by Treasury)
- Counties with a population below 250,000 residents which received more than $10 million in Recovery Funds (referred to as Tier 2 recipient by Treasury)
The Project and Expenditure Report will cover the period between March 3, 2021, and December 31, 2021, and requires the reporting of project, obligations and expenditure data, subaward data, as well as certain required programmatic data.
Please note: Counties with populations below 250,000 residents and received less than $10 million in Recovery Funds, are not required to submit a report by January 31, 2022, and there will not be a report record available for you to do so. Your first reporting deadline to submit the Project and Expenditure Report will be April 30, 2022, and annually afterwards. A Project and Expenditure Report will be made available for your jurisdiction to complete ahead of your April 30, 2022, deadline.
To view NACo’s analysis of Treasury’s Final Rule for the Recovery Fund, click here.