ARPA single audit guidance released
Townships that spend more than $750,000 of their State and Local Fiscal Recovery Funds through the American Rescue Plan Act (ARPA) in a fiscal year will not have to undergo the usually required federal single audit as long as any additional, non-ARPA federal award expenditures do not exceed $750,000. In addition, recipients must have received $10 million or less in ARPA allocation. (Less than 10% of townships received allocations greater than $750,000, and all but one Michigan township received less than $10 million). New guidance released by U.S. Treasury announced the alternative option for single audit requirements. Typically, a township that expends $750,000 or more in federal financial assistance within their fiscal year is required to engage the services of an auditor to conduct Single Audits as described in 2 C.F.R. 200, Subpart F, Audit Requirements. However, the new compliance information grants eligible local governments the option for their auditor or practitioner to follow “Alternative Compliance Examination Engagement” guidance, as outlined in “Section IV. New Information,” beginning on page 9 of the guidance document.
Having continued difficulties completing your township's ARPA 'Project and Expenditure' Report?
If your township has been unable to complete its filing of the first "Project and Expenditure" Report, it is recommended that you try to file something, and if tech issues persist, open a support ticket and save the number. A “record of attempting to file” will be helpful if U.S. Treasury does raise issues about late filing.
Treasury has stated that if someone was unable to meet the deadline by April 30, “recipients will be asked to provide a date by which the delayed reporting will be submitted so that Treasury can plan for incorporating the data.” For general support when completing the report, email Treasury at SLFRP@treasury.gov or call (844) 529-9527. For technical assistance, email covidreliefITsupport@treasury.gov.
- U.S. Treasury WEBINAR: State & Local Fiscal Recovery Funds: Project & Expenditure Reporting Pt. I
- U.S. Treasury webinar recording: State and Local Fiscal Recovery Funds Reporting for Non-entitlement units of governments
- February Township Focus cover story: Township use of APRA funds broadened, simplified
- U.S. Treasury Recipient Compliance and Reporting webpage Take action NOW to meet April 30 reporting deadline
- Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
- MTA FACT SHEET: How Can Townships Use American Rescue Act Funds? (revised January 14, 2022)
- WATCH NOW! MTA Q&A: ARPA Final Rule webinar
- U.S. Dept. of Treasury: Final Rule webinar recording and presentation
- Overview of the Final Rule
- National Association of Towns and Townships Special Report on Eligible Uses for the American Rescue Plan
IMPORTANT: Your township’s SAM.gov registration must be active for the reporting, and must be renewed annually. This is free of charge; townships do not need to pay a fee for this registration. We are again hearing of companies—some of whose communication appear to be affiliated with SAM.gov—reaching out to townships to renew the SAM.gov registration for a fee. Your township does not have to pay, or go through a third party, to renew your registration.
ARPA reporting reminders
U.S. Treasury Webinars
- U.S. Treasury Project and Expenditure Report Webinar
- Account Creation and Login - creation of account in Treasury’s Portal through ID.me or Login.gov
- User Roles - assignment and updates of user roles in Treasury’s Portal
Merit Network offers the following resources for townships considering using their ARPA funds to improve broadband access in their communities.
How Communities are using ARPA for Broadband
Next Century Cities highlights how communities across the country are using funds from the American Recovery Plan Act (ARPA) to fund broadband planning and pilots.
Rules for using ARPA funds for Broadband
The U.S. Treasury Department recently put out a final ruling on how State and Local Fiscal Recovery Funds (ARPA) can be used. Grants Office details increased flexibility in applying these funds toward broadband initiatives.
Report: Grant Opportunities
Grants Office, LLC, puts together a detailed report on current and upcoming state and federal grants that can be applied towards broadband projects. The report is updated quarterly (March report just posted!), and can be downloaded for free by completing the form at this page.
ARPA Final Rule GREATLY simplifies and broadens township's use of funds
Townships’ ability to put #AmericanRescuePlan dollars to use in their communities was clarified—and GREATLY broadened and simplified—under the The U.S. Department of the Treasury final rule. Previously, most general government services or projects could only be funded if the township could project or demonstrate “revenue loss” as defined in the ARPA and prior interim final rule. According to a final rule overview, recipients that select a new up-to-$10 million “standard allowance may use that amount—in many cases their full award—for government services, with streamlined reporting requirement,” without having to demonstrate any “revenue loss.” Because all but one township has an allocation less than $10 million, this means that your township can elect to use its full allocation for general township services, projects and uses. Additional changes streamline the premium pay use, and broaden the infrastructure and economic impact categories.
- U.S. Dept. of Treasury press release
- Final Rule (full text)
- Overview of the Final Rule
- Statement Regarding Compliance with the Coronavirus State and Local Fiscal Recovery Funds Interim Final Rule and Final Rule
MTA continues coalition work to leverage ARPA funding
As a member of a statewide coalition, MTA continues to work to gain support for a comprehensive plan to leverage the state’s nearly $6 billion in federal ARPA funding. The plan, From Rescue to Prosperity: A Roadmap to Michigan’s Future, focuses the state’s ARPA resources in a coordinated manner across five key areas: infrastructure, fiscal health, thriving communities, strong economy, and public health and safety. We encourage township officials to seek the support of their legislators as the plan would provide direct investment across multiple sectors and maximize the one-time ARPA dollars. Learn more about the plan here.
Guidance and resources for townships
- U.S. Treasury Compliance and Reporting Guidance
- NEW! MTA FACT SHEET: Clarifying ARPA Premium Pay Options
All townships that have requested ARPA funds must have a "Federal Procurement Conflict of Interest Policy" in place. The policy applies when procuring goods (apparatus, supplies, materials and equipment), services, and construction or repair projects funded in part or whole with federal financial assistance (direct or reimbursed), and also prohibits the receiving of gifts from suppliers, contactors, etc. for such purchases or projects. If your township has not already adopted such a policy, we recommend that you do so at your next upcoming board meeting. A sample policy is available here (a Microsoft Word version is also available).
Communities with Qualified Census Tracts have additional uses for ARPA funds to help offset impacts of the pandemic on certain populations, including low-income communities. A listing of all townships with QCTs is available here.
More than 98% of Michigan townships applied to access their American Rescue Plan funds
More than 98% of Michigan's "non-entitlement unit" townships (those under 50,000 population) applied and have received the first half of their allocation of federal COVID relief funding through the American Rescue Plan Act. The second half will be distributed no later than 12 months after the initial allocation.
Townships have time to make decisions on uses
The funding has very broad flexibility for its uses and does not have to be obligated until Dec. 31, 2024. The funds will be helpful in shoring up, expanding or simply funding your local services. State Treasury, for example, believes that most local units of government-using the formula for revenue loss-will have demonstrable lost revenue due to the pandemic. By showing lost revenue, your township can use the funds on most current township services, to the extent of that loss.
The American Rescue Plan Act contains $1.9 trillion for the coronavirus relief package with $350 billion allocated for state, local and tribal governments to mitigate the fiscal impacts of the COVID-19 pandemic and provide vital services. Local governments can use ARPA funds to cover costs incurred by Dec. 31, 2024, to:
• Provide government services affected by a revenue reduction during the pandemic (in the most recent full fiscal year prior to the emergency); thus, a local unit may use the money to replace the amount of revenue lost during the pandemic compared to the prior full fiscal year
• Make necessary investments in water, sewer and broadband infrastructure
• Respond to the COVID-19 emergency and address its negative economic impacts, including aid to households, small businesses, nonprofits, and industries such as tourism and hospitality
• Provide premium pay-up to $13 an hour or $25,000 per worker-in additional wages for essential employees performing an essential function in the pandemic
The ARPA prohibits the use of the funds for pension or to offset revenue loss due to a tax cut.
The ARPA also includes $10 billion to states for a Critical Infrastructure Projects Program, with Michigan expected to receive $250 million. The monies are to be used for projects that would directly enable work, education and health monitoring-including remote options-in response to COVID-19. Examples provided during the legislative discussion included water, sewer and broadband.