ARPA Follow-Up Necessary for Some Cities

Treasury Requests Documents by September 30, 2022

The U.S. Department of the Treasury requires non-entitlement units (NEUs) of local government to submit additional information and supporting documents to comply fully with the American Rescue Plan Act (ARPA) final rule. If city officials did not submit the additional items with the project and expenditure report that was due April 30, they will need to file those as soon as possible.

Treasury sent emails to the account administrator this month requesting the additional documentation. If the city did not change the account administrator when completing the project and expenditure report, the email went to the initial administrator – the mayor, although Treasury has the mayor associated with the clerk’s email address for several cities. Treasury requests cities submit the information as soon as possible.

The required agreements and support documents include copies of the following:

1. Signed award terms and conditions agreement the city submitted to the Department for Local Government (DLG) a year ago.
2. Signed assurances of compliance with Title VI of the Civil Rights Act of 1964 the city also submitted to DLG.
3. Actual budget documents that validate the top-line budget total provided to DLG. Note that this is not the budget certification form the city submitted; instead, Treasury wants the city’s actual FY 2020 budget (summary or all line items) in effect on Jan. 27, 2020, which should match the budget certification form total.

Once logged into Treasury’s reporting portal through either a Login.gov or ID.me account, the account administrator or authorized representative for reporting can upload these documents through a separate report. This NEU documentation report should appear near the project and expenditure report on the city’s “Compliance Reports” page. KLC recommends submitting PDFs because the portal may not support all file types.

Cities must also designate the following roles and responsibilities for the State and Local Fiscal Recovery Funds (SLFRF):

• SLFRF Account Administrator to assign the reporting roles and update contact information of the designated individuals. 
• SLFRF Point of Contact for Reporting to receive official communication from Treasury and complete the required reports. 
• SLFRF Authorized Representative for Reporting to certify and submit the reports and make any amendments, if necessary.

KLC recommends that NEUs, particularly smaller ones, assign the same person to all three roles. For example, in most cities the clerk or the treasurer will be responsible for all ARPA reporting; therefore, the clerk or treasurer may want to perform all three roles. The city should also have at least one other account administrator (e.g., assistant clerk or treasurer, manager or administrator, mayor, etc.) for redundancy.

Administrators can designate the reporting roles through the city’s account information once logged into the portal. Go here to view the screenshots of how to assign roles in Treasury’s portal.