American Rescue Plan Act: SLFRF Reports
We started this discussion with the premise that ARPA’s complexities are manageable, while the benefits are substantial, and the risks are controllable. We recommended local governments consider taking these six concrete steps:
- Take the money. Yes, it has federal strings, but it is once-in-a-generation federal help.
2. Make a plan. Engage local stakeholders, service providers, and residents.
3. Rehire your team. You need folks back in every authorized position more than ever.
4. Buy some modern technology. Help your teams manage all this.
5. Help your community. Equitably allocate funds to local subrecipients.
6. Just don’t forget those strings. Plan for transparency, reporting, and your auditors.
We dug further into how this massive funding can be put to work in every community and outlined our view of the best practices in managing and prioritizing SLFRF:
Quick housekeeping note: We have a variety of other resources focused on ARPA. Check out these helpful guides for more.
In this blog, we will take a closer look at the reporting requirements for SLFRF. While the reporting seems complex at first, we believe we can explain the rules more simply than you might expect and cut through some of the confusion and angst.
We will conclude this series with more on reporting, a look at the GFOA’s recommendations, using SLFRF to modernize government technology, and distributing funding to subrecipients in local communities.
Let’s get into it.
Beginning With the End in Mind: Reporting and Audit
Governments should be prepared to manage and report on SLFRF activity for an extended period of time, including four active program years, two additional payment years, and five years of potential post-program audits.
Planning, tracking, recording, reporting, and auditing the mass of details associated with this level of spending and activity outside the government’s accounting system is problematic, at best.
Adding the appropriate coding to the chart of accounts in the government’s financial system is a far better alternative, allowing the government to work with its existing budgeting, internal control, and reporting framework. In general, the chart of accounts should allow detailed SLFRF revenue, expenditure, and project tracking.
The Single Audit and Federal Uniform Guidance
Generally, governments must develop and implement policies, procedures, and maintain records to demonstrate that they used the proper criteria for determining the eligibility of beneficiaries and/or subrecipients.
Your organization, and if applicable, the subrecipient(s) administering a program on behalf of your organization, will need to maintain procedures for obtaining information evidencing a given beneficiary, subrecipient, or contractor’s eligibility, including a valid SAM.gov registration.
Recipients are accountable to the Treasury for oversight of their subrecipients, including ensuring their subrecipients comply with the SLFRF statute, SLFRF Award Terms and Conditions, Treasury’s Interim Final Rule, and reporting requirements, as applicable.
For-profit entities that receive SLFRF subawards are not subject to Single Audit requirements. However, they are subject to other audits as deemed necessary by authorized governmental entities, including the Treasury, the GAO, the PRAC, and the Treasury’s OIG.
Any funds not obligated or expended for eligible uses by the timelines above must be returned to Treasury, including any unobligated or unexpended funds that have been provided to subrecipients and contractors .
Reporting to the Treasury
On August 9th, 2021 the U.S. Department of Treasury published User Guide: Treasury’s Portal for Recipient Reporting. This 50-page document provides reporting instructions for state and local governments, expanding on their earlier SLFRF Compliance and Reporting Guidance. While not changing the rules, this new manual adds more clarity and detail to the requirements. A couple of points are worth repeating here:
On page 6, Key Concepts for Reporting
The following concept structure applies to all report types:
- Each recipient will have expenditures in several Expenditure Categories (EC), as further detailed in Appendix 1 of the Reporting Guidance.
- For each Expenditure Category you use funding for, you will have one or more projects.
- For each project, you will need to track obligations and expenditures, as well as any subawards made.
- Treasury will collect some programmatic data at both the expenditure category level as well as the project level.
On page 7, This diagram showing the SLFRF “Expenditure Categories” relate to our usual concepts of projects, obligations, and expenditures
Reporting requirements vary by government population and award size. We have identified the reporting for the four specified levels of governments here.
Following that list, we conclude for today with a summary of the mandated contents for each of the two reports a government may need to file by August 31, 2021. (We will discuss the third item, the Project and Expenditure Report, due on October 31, 2021, later.)
1. Metropolitan cities and counties with over 250,000 residents
- Interim Report: By August 31, 2021, with expenditure summary by category.
- Project and Expenditure Report: By October 31, 2021, and then 30 days after the end of each quarter.
- Recovery Plan Performance Report: By August 31, 2021, then annually by July 31.
- Metropolitan cities and counties with under 250,000 residents who received more than $5 million in SLFRF funding
- Interim Report: By August 31, 2021, with expenditure summary by category.
- Project and Expenditure Report: By October 31, 2021, and then 30 days after the end of each quarter.
- Recovery Plan Performance Report: Not required.
- Metropolitan cities and counties with under 250,000 residents who received less than $5 million in SLFRF funding
- Interim Report: By August 31, 2021, with expenditure summary by category.
- Project and Expenditure Report: By October 31, 2021, and then annually.
- Recovery Plan Performance Report: Not required.
- Non-Entitlement Governments
- Interim Report: Not required.
- Project and Expenditure Report: By October 31, 2021, and then annually.
- Recovery Plan Performance Report: Not required.
The mandated reports require specific narrative and financial information to be entered onto a portal developed by the Treasury. Bulk imports for states are provided, but local governments must key their data in. The following is summarized from the Treasury’s Compliance and Reporting Guidance.
A. Interim Report by August 31, 2021 (NEU’s do not report)
The interim report will include a recipient’s obligations and expenditures by expenditure category at the summary level. The interim report will cover activity from the date of award to July 31, 2021, and must be submitted to the Treasury by August 31, 2021.
B. Initial Recovery Plan Performance Report by August 31, 2021 (large governments)
The Recovery Plan provides the public and Treasury information on the projects that recipients are undertaking with program funding and how they are planning to ensure program outcomes are achieved in an effective, efficient, and equitable manner. The Treasury has created a sample template to assist governments in writing their Recovery Plan, which can be downloaded from www.treasury.gov/SLFRPReporting.
Recovery Plans must be posted on the public-facing website of the recipient by the same date the recipient submits the report to the Treasury. Reporting requirements include uploading a link to the publicly available document along with providing data in the Treasury reporting portal.
The initial Recovery Plan will cover the period from the date of award to July 31, 2021, and must be submitted to the Treasury by August 31, 2021. Thereafter, the Recovery Plan will cover a 12-month period and recipients will be required to submit the report to the Treasury within 30 days after the end of the 12-month period (by July 31). The Recovery Plan includes, at a minimum, the following information:
1. Executive Summary.
A high-level overview of the jurisdiction’s intended and actual uses of funding including, but not limited to: the jurisdiction’s plan for use of funds to promote a response to the pandemic and economic recovery, key outcome goals, progress to date on those outcomes, and any noteworthy challenges or opportunities identified during the reporting period.
2. Uses of Funds.
Describe in further detail your jurisdiction’s intended and actual uses of the funds, such as how your jurisdiction’s approach would help support a strong and equitable recovery from the COVID-19 pandemic and economic downturn.
3. Promoting equitable outcomes.
Describe efforts to promote equitable outcomes, including how programs were designed with equity in mind.
4. Community Engagement.
Describe how your jurisdiction’s planned or current use of funds incorporates written, oral, and other forms of input that capture diverse feedback from constituents, community-based organizations, and the communities themselves.
5. Labor Practices.
Describe workforce practices on any infrastructure projects being pursued
6. Use of Evidence.
The Recovery Plan should identify whether SLFRF funds are being used for evidence-based interventions and/or if projects are being evaluated through rigorous program evaluations that are designed to build evidence.
7. Table of Expenses by Expenditure Category.
Include a table listing the amount of funds used in each Expenditure Category. The table should include cumulative expenses to date within each category, and the additional amount spent within each category since the last annual Recovery Plan.
8. Project Inventory.
List the name and provide a brief description of all SLFRF funded projects. Projects are new or existing eligible government services or investments funded in whole or in part by SLFRF funding.
9. Performance Report.
The Recovery Plan must include key performance indicators for the major SLFRF funded projects undertaken by the recipient.
10. Required Performance Indicators and Programmatic Data.
While recipients have discretion on the full suite of performance indicators to include, a number of mandatory performance indicators and programmatic data must be included.
Want to learn more?
Click HERE to read our eBook covering what you need to know about ARPA (and how to use it).
Last Updated on January 27, 2022 by Stephanie Beer
Category: OpenGov Updates
