The State and Local Fiscal Recovery Funds (SLFRF) program under the American Rescue Plan Act (ARPA) was a historic, first-of-its-kind direct investment in cities, towns and villages of all sizes. The SLFRF program was specifically set in place to help communities manage and recover from the COVID-19 pandemic. For many local governments, this was the first time receiving a direct federal grant, and understandably the reporting requirements and compliance obligations have come with a learning curve.
While the Department of Treasury has been tolerant of reporting missteps and corrections until now, the 12/31/2024 obligation deadline has passed, and every city, town and village must be in compliance before the 2024 reporting portal closes. The portal could close any day, but it will officially close by the end of March 2025 to allow Treasury time to launch the 2025 reporting cycle.
Below are common questions from cities — and what you need to know to stay compliant:
1. What happens if my city is not in compliance?
If your city is out of compliance — for example, if you missed submitting required reports or used funds on ineligible expenses — Treasury has been instructed to begin recoupment proceedings, and letters of recoupment are already being sent.
If your city remains out of compliance, you will be required to repay the SLFRF funds awarded to you under ARPA.
2. What should my city do if we’re not in compliance?
If you know you are behind, you must act now:
- Submit your 2024 report — the portal is still open for annual reporters but will close before April.
- If you remain noncompliant when the 2025 report opens, Treasury has been instructed to begin full recoupment proceedings.
3. We haven’t reported in a few years, and I can’t access 2022 or 2023 reports. How do I know which reports I need to fill out?
Good news — ARPA SLFRF reports are cumulative. If you submit the 2024 report (currently open in the Treasury portal) you will be brought back into compliance.
4. We’ve had staff turnover. How do I get access to the account?
- If you have access to your city’s Account Identifier – ensure that you have an active Login.gov account and input the Account Identifier and city’s zip code at portal.treasury.gov/compliance.
- If you don’t have access to your City’s Account Identifier – reach out to advocacy@nlc.org and NLC will work directly with Treasury to get you set up quickly.
5. I’ve already received a letter of recoupment. What can I do now?
If you are receiving a letter because you are out of compliance due to reporting, submit the 2024 report immediately.
For help, contact your state municipal league or NLC at advocacy@nlc.org.
6. I’ve received an Information Document Request (IDR) from the Department of Treasury. What am I supposed to do?
An Information Document Request means Treasury needs more details to confirm compliance. Respond to their request promptly and thoroughly and provide clear documentation.
For more information, see Treasury’s video on the subject here.
7. My city spent all of its funds in 2023. Do we still need to submit reports?
Yes. Even if funds are fully spent, you must continue submitting Project & Expenditure Reports until Treasury officially closes out your award.
For annual reporters, the 2025 report is due April 30, 2025. For quarterly reporters, the Q1 report was due on January 31, 2025. and the Q2 report is due on April 30, 2025.
Treasury and the Office of Management and Budget (OMB) are working on final closeout instructions, but until those are issued, cities must continue to report.
8. What happens if my city hasn’t obligated all of its funds?
The obligation deadline (12/31/2024) has passed.
- If your city has unobligated funds and is not taking Revenue Replacement, those funds must be returned to the federal government.
- If your city is claiming Revenue Replacement (up to $10 million per entity), you can report that in your April 2025 report, including how the funds will be used.
Note: taking Revenue Replacement is a two-step process. See this blog for more information.
9. Do I need to submit a 2025 report now that I’m back in compliance?
Yes. To stay compliant, you must submit the 2025 report. Failing to do so will return your city to non-compliance and could trigger recoupment.
10. Do you have any resources on how to fill out the reports?
Yes! NLC’s ARPA webpage has up-to-date reporting guides and resources, available here.
Cities must take steps now to resolve outstanding compliance and reporting issues. If you’re unsure of your status, log in and check, or contact Treasury for help at SLFRF@treasury.gov.
If you need help navigating these challenges, reach out to NLC at advocacy@nlc.org — we’re here to support you and help avoid penalties.
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