U.S. Department of Treasury issued more Guidance on June 17, 2021. This guidance is related to Recipient Compliance and Reporting.
KEY REPORTING DATES:
August 31, 2021 – Interim Report
On May 11, 2021, the American Rescue Plan Act (ARPA) was signed into law, and many have received their first round of funding. Reporting requirements are coming up quickly for some recipients (State, U.S. territories, metropolitan cities, counties, and Tribal governments) are required to submit a one-time interim report with expenditures by Expenditure Category at the summary level from the date of award to June 30, 2021 through the State and Local Fiscal Recovery Funds (SLFRF) portal by August 31, 2021. This will be the “Interim Report” (page 13, Part 2 section A of guidance report) and not required for Non-entitlement Units (NEUs).
October 31, 2021 – Project and Expenditure Report (quarterly or annually)
This report is required for ALL recipients and will happen either quarterly or annually based on your recipient status.
Quarterly Reporting:
Quarterly reporting is required for States, U.S. Territories, and Tribal governments, and those metropolitan cities and counties that received more than $5 million in SLFRF funding. The first report will start October 31, 2021 (covering award date to 9/30/21), then happen once a quarter from then forward (30 days after the end of each calendar quarter) through March 31, 2027 (page 15, Part 2 section B of guidance report).
Annual Reporting:
Annual reporting is required for all metropolitan cities and counties that received less than $5 million in SLFRF funding and all NEUs. The state will assign all NEUs a unique identification code which will be needed to complete your report. Annual reporting will begin October 31, 2021 (covering award date to 9/30/21) then continue annually October 31st through October 31, 2026, with your last report happening on March 31, 2027 (page 16, Part 2 Section B of guidance report).
Reporting information for the Project Expenditure Report (quarterly or annually):
(page 16 to page 23, Part 2 Section B)
- Projects – New or existing eligible government services
- Expenditures – reported by project identifying, Current period obligation, Cumulative obligation, Current period expenditure, and Cumulative expenditure.
- Project Demographic Distribution – Identify whether or not the project is serving an economically disadvantaged community.
- Subawards – information for any obligations provided on contracts and grants awarded, loan issued, or transfers made to other government entities that were greater than or equal to $50,000. *Please note: you will need to provide additional subrecipients information such as, DUNS #, Award Number, Award Date, amount, description, etc, so please review this information to make sure you document, provide, and obtain the information before subawarding.
- Civil Rights Compliance – Title VI
- Required Programmatic Data (other than infrastructure projects) – payroll for public health and safety employees, Household Assitance, Small Business Economic Assistance, Aid to Travel, Tourism, and Hospitality or Other impacted industries, Rehiring Public Sector Staff, Education Assistance, Premium Pay, and Revenue replacement.
- Required Programmatic Data for Infrastructure Projects – All projects listed under the Water, Sewer, and Broadband Expenditure Categories
- Distribution to NEUs – States and Territories only
- NEU Documentation (NEUs only) – FIRST REPORT ONLY – Provide copy of signed award terms and conditions agreement, a copy of signed assurances of compliance with Title VI, and copy of actual budget documents validating the top-line budget total provided to State.
August 31, 2021 – Recovery Plan Performance Report (Recovery Plan):
(page 23 to page 30, Part 2 Section B)
All States, territories, metropolitan cities, and counties with a population that exceeds 250,000 residence, will need to be published to government agencies website and submitted to the Treasury by August 31, 2021 a Recovery Plan. This first report will cover from the Award Date through July 31, 2021. Then will happen every year after that on July 31st covering a July 1 to June 30th from that point forward through March 31, 2027. This report should include the following information:
- Executive Summary
- Use of Funds
- Promoting equitable outcomes
- Community Engagement
- Labor Practices
- Use of Evidence
- Table of Expenses by Expenditure Category
- Project Inventory
- Performance Report
- Required Performance Indicators and Programmatic Data
- Ineligible Activities: Tax Offset Provision (States and territories only)
