The American Rescue Plan Act (ARPA), which was signed into law by President Biden on March 11th, includes significant direct recovery funds for states, counties, municipalities, as well as Tribal governments and territories through its State and Local Fiscal Recovery Fund (SLFRF). The Department of Treasury has been tasked with administering the SLFRF grant program. Accordingly, the Department of Treasury is the agency responsible for putting forth regulatory language that clarifies how the funding program will work. This information can be found in the Interim Final Rule (IFR), the Compliance and Reporting Guidance, as well as a number of additional resources.
Recipients of SLFRF funds are required to submit varying periodic reports based on city population size. Treasury has now released further guidance on creating and submitting the Interim Report and the Annual Recovery Plan Performance Report in the Reporting Portal User Guide (Interim Report and Recovery Plan only), as a supplement to the Compliance and Reporting Guidance, which contains detailed information on reporting requirements. This guidance is directed towards metropolitan cities. Recipients should be sure to read this User Guide, which includes step-by-step instructions and helpful tips for submitting the required SLFRF reports using Treasury’s Portal. Treasury has also created this Recovery Plan Template. A forthcoming User Guide will provide information on submitting Project and Expenditure Reports.
The reporting portal for Interim Reports and Recovery plans was launched on Monday, August 9th. According to Treasury, the link to access the reporting portal was sent to recipient points of contact based on the contact information provided during the funding process. If you are a recipient and did not receive the email but should have, Treasury has advised recipients to contact them at SLFRP@treasury.gov.
Both the Annual Recovery Plan Performance Report and the Interim Report are due by August 31, 2021.
Three Key Takeaways Cities Should Take Note of From the Reporting Portal User Guide:
Annual Recovery Plan Performance Report vs. Interim Report
The Annual Recovery Plan Performance Report provides information on the recipient’s SLFRF projects and how they plan to ensure that the given outcomes are achieved in an effective, efficient, and equitable manner. This report will provide the recipient’s planned approach for the use of funds. The report should include performance indicators identified by the recipient and mandated performance indicators identified by Treasury. The recovery plan will cover the period of the date of the award to July 31, 2021, and must be submitted by August 31, 2021 (and annually thereafter). Recipients may use the Recovery Plan Template created by Treasury to complete their reports, and a PDF report will be submitted by recipients to the Treasury Reporting Portal. Recipients will be allowed to submit updates of the plan reflecting any significant changes. Treasury encourages recipients to prominently share the plan (and any relevant changes) with the public on the recipient’s government website. In addition to Treasury resources, NLC has created several resources to assist our members with planning the use of SLFRF funds, which can be found through NLC.org/Recovery.
The Interim Report provides an initial overview of the status and uses of funding for SLFRF programs. It is a one-time report due by August 31, 2021. It covers spending from March 3 to July 31, 2021, due August 31, 2021, and requires a breakdown by all Expenditure Categories. Recipients may refer to the comprehensive list of the expenditure categories in Appendix 1 of the Compliance and Reporting Guidance. The Interim Report is required even if no funds have been obligated or spent. The User Guide lists step-by-step instructions (with screenshots) for filling out the Interim Report within the portal. No changes will be allowed after submission, as changes will be captured in the next Project and Expenditure Report.
Who is required to submit these reports?
- Cities with a population that exceed 250,000 residents are required to submit the Annual Recovery Plan Performance Report AND the Interim Report.
- Metropolitan cities with a population below 250,000 residents which received more than $5 million in SLFRF funding, and Metropolitan cities with a population below 250,000 residents which received less than $5 million in SLFRF funding are NOT required to submit an Annual Recovery Plan Performance Report, but ARE required to submit an Interim Report.
- NEUs are not required to submit either of these reports. However, ALL cities will be required to submit quarterly or annual Project and Expenditure Reports, depending on city population size. Again, Treasury has not yet released user guides for completing Project and Expenditure Reports. Recipients may refer to a chart on page 6 of the User Guide which details report requirements and due dates for each recipient category.
- Recipients should refer to the Compliance and Reporting Guidance for detailed guidance (in addition the User Guide) before submitting reports.
SLFRF Recipient Organizations Must Designate Staff for Key Roles in Managing SLFRF Reports.
Recipients are required to designate staff or officials for the following three roles: Account Administrator, Point of Contact for Reporting, and an Authorized Representative for Reporting. Recipients must make these designations prior to accessing Treasury’s portal. One individual may be designated for multiple or all three roles. Recipients may also elect to designate multiple individuals for each role. According to the user guide, guidance on the process for designating individuals was emailed to all SLFRF recipients, and each designee must register with ID.me for gaining access to Treasury’s Portal.
Report Managing Roles:
- Account Administrator: This administrative role is responsible for maintaining the names and contact information of the designated individuals for SLFRF reporting, working within the recipient organization to determine its designees for the roles of Point of Contact for Reporting and Authorized Representative for Reporting, and making any changes or updates to the user roles as needed over the award period.
- Point of Contact for Reporting: This role is the primary contact for receiving official Treasury notifications about reporting on the SLFRF award and completing the SLFRF reports.
- Authorized Representative for Reporting: This role is responsible for certifying and submitting official reports on behalf of the SLFRF award recipient. Treasury will only accept reports or official communications submitted by the Authorized Representative for Reporting.
Upon login, recipients will be required to verify the names and contact information of the individuals designated for these key roles.
All reports will follow the same concept structure.
Recipients are required to submit these detailed reports to ensure that they are accountable, transparent, and focused on recovery, in accordance with the SLFRF reporting guidance principles. Further detailed instructions for report completion are included in Part 2 of the Compliance and Reporting Guide.
Each recipient will have expenditures in several expenditure categories detailed in the Compliance and Reporting Guidance (read this for detailed instructions on eligible uses). Within each expenditure category that funds are being used for, recipients will have one or more projects. Recipients must be sure to track the obligations and expenditures, as well as any subawards, for each project. In addition, Treasury will collect programmatic data at both the expenditure category level and the project level. The User Guide provides a visual flow-chart depiction of this structure in Figure 7 on page 7.
For recipients who are required to submit a Recovery Plan, it should be noted that they will not be required to enter their project inventory and other programmatic data directly into the portal until October 31, 2021.
This User Guide provides extensive, clear, instructions on how to submit the Annual Recovery Plan Performance and Interim Reports. It also includes several Frequently Asked Questions and Answers, and recipients should refer to the Guide for comprehensive technical instructions.
While NEUs do not have to submit the reports due on August 31, 2021, they should be aware of the reporting requirements for the Project and Expenditure Report due on October 31, 2021. Recipients should be sure to carefully track expenditures for all projects funded by SLFRF funds.
About the Author:
Megan Alberto is an Intern on NLC’s Federal Advocacy team.
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