Overview of U.S. Treasury Final Rule for ARPA Fiscal Recovery Fund

March 25, 2022

The National Association of Counties (NACo) is pleased to release a refreshed presentation on the U.S. Treasury’s Final Rule for the ARPA Fiscal Recovery Fund.

The updated analysis includes, but is not limited to the following:

  • Deeper dive on the provisions around revenue loss allocations, including for the new standard allowance up to $10M and for those counties using Treasury’s formula to calculate their revenue loss above $10M
  • Clarifying information on eligible/ineligible uses, including for capital expenditures
  • Treatment of loans
  • Reporting requirements and background information on federal Uniform Guidance/2 CFR Part 200

Additionally, we wanted to make sure you and your members are aware of other relevant information pertaining to the upcoming Project and Expenditure (P&E) Report deadline on April 30, 2022.

  • One-time revenue loss election: Counties will have the option to make a one-time decision to calculate revenue loss according to the formula outlined in the final rule OR elect the $10 million revenue loss standard allowance, not to exceed the county’s award allocation. The option to make this one-time decision will be provided on the April 30 P&E Report.
  • Treasury acceptance of Project & Expenditure Reports: Treasury is now only accepting Project and Expenditure Reports from Tier 1, 2 and 3 recipients.
  • For Tier 4 (Tribal govts with less than $30 million) and Tier 5 counties with a population below 250,000 residents AND received less than $10 million in Recovery Funds, the first P&E Report is also due April 30, 2022, and then annually thereafter. HOWEVER, the Treasury submission portal is not yet open for recipients to submit a report. Treasury is likely to open the portal for this group by the end of month
  • Expenditure categories: Updated reporting guidance contains an expanded set of Expenditure Categories to reflect the broader flexibility introduced by the final rule. Counties who submitted Project and Expenditure Reports in January will have the opportunity to update their previously selected Expenditure Category, if appropriate.
  • Capital expenditures: Updated reporting guidance states that additional programmatic data for capital expenditures is optional in the April 2022 P&E Report and required for the July 2022 P&E Report.

Counties can access the Reporting Guidance for the Recovery Fund on Treasury’s Coronavirus State and Local Fiscal Recovery Funds website. To see a concise summary of the final rule for the Recovery Fund, please see the Overview Document.

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