April Showers Bring ARPA/SLFRF Reporting Deadlines

While not as much fun as May flowers, the next deadline to submit State and Local Fiscal Recovery Funds (SLFRF) reports to the Treasury is April 30, 2024. As mentioned in a companion article, this deadline remains in place despite an email sent by the Treasury about reporting administrative costs. However, the Treasury has extended the deadline for recipients to take the “standard allowance.”

The Treasury’s 2022 final rule authorized recipients to claim a “standard allowance” of up to $10 million allocated SLFRF funds to replace lost revenue due to COVID-19. Recipients that choose the “standard allowance” are not required to prove actual revenue loss.

To take the “standard allowance,” recipients must select the revenue replacement option in the Treasury portal on the annual April report. Initially, recipients were required to make the selection by the April 30, 2022, report deadline. On March 29, 2024, the Treasury updated its FAQs to provide more detail on expenditures and reporting. Section 3 of the FAQs updates guidance on revenue loss, including an extended deadline to dedicate SLFRF funds under the “standard allowance” category to April 30, 2025.

SLFRF funds categorized as revenue replacement under the “standard allowance” may be used for the general provision of government services. This means a city can use these funds for any general purpose except reducing low-income housing stock or any purpose that may violate state or federal law. SLFRF funds must be obligated by Dec. 31, 2024, which means that the funds are obligated by contract or other written agreement.

Recipients that take the “standard allowance” have less burdensome reporting requirements. Instead of submitting lengthy descriptions and documentation to meet the project report requirements, recipients reporting under the standard allowance category need only provide detailed narratives.

In April 2022, KLC presented a reporting webinar. The webinar presentation includes examples of reporting narrative recommendations. A copy of the PowerPoint presentation can be found here.

For questions on ARPA/SLFRF or any other municipal law matters, please contact the KLC Department of Municipal Law.