GAO-24-107301, COVID-19 Relief: States’ and Localities’ Fiscal Recovery Funds Spending as of March 31, 2024

Report — GAO-24-107301, COVID-19 Relief: States’ and Localities’ Fiscal Recovery Funds Spending as of March 31, 2024, dated 2024-12-31, issued by Government Accountability Office.

Full text

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GAO-24-107301 Fiscal Recovery Funds

The Coronavirus State and Local Fiscal Recovery Funds (SLFRF) program
allocated $350 billion to tribal governments, states, the District of Columbia, local
governments, and U.S. territories to help cover a broad range of costs stemming
from the health and economic effects of the COVID-19 pandemic.1 SLFRF was
established under the American Rescue Plan Act of 2021 (ARPA) and is
administered by the Department of the Treasury. SLFRF recipients must
regularly submit reports to Treasury on their use of the awards and the projects
undertaken with them.2 SLFRF recipients have until December 31, 2024, to
obligate their SLFRF awards and generally have until December 31, 2026, to
spend their awards.
The CARES Act includes a provision for us to monitor the use of federal funds to
respond to the COVID-19 pandemic.3 This report updates our October 2023 and
April 2024 reports on states’ and localities’ SLFRF spending and uses of
SLFRF.4 We will continue to review states’ and localities’ reported obligations
and spending, as well as their uses of SLFRF awards.

•
As of March 31, 2024—the most recent data available at the time of this
report—states reported obligating 84 percent ($163.7 billion) and spending 60
percent ($117.3 billion) of the SLFRF awards they received.
•
Localities reported obligating 76 percent ($95.8 billion) and spending 60
percent ($75.8 billion) of their awards during the same period.5
•
States and localities reported spending the largest share of their awards to
replace revenue lost due to the pandemic. As of March 31, 2024, 45 percent
($53.2 billion) of states’ reported spending and 68 percent ($51.5 billion) of
localities’ reported spending was used for this purpose.

Under ARPA, the SLFRF allocated the $350 billion across six groups of
recipients (see fig. 1). Localities included counties, metropolitan cities (which we
refer to as cities throughout this report), and non-entitlement units of local
government (NEU), which are smaller local governments typically serving
populations of less than 50,000.6

U.S. Government Accountability Office
COVID-19 Relief: States’ and Localities’ Fiscal
Recovery Funds Spending as of March 31,
2024
GAO-24-107301
Report to Congressional Committees
September 26, 2024
Why This Matters
Key Takeaways
How much in SLFRF
awards did states and
localities receive?

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GAO-24-107301 Fiscal Recovery Funds
Figure 1: Allocations of Coronavirus State and Local Fiscal Recovery Funds by Recipient
Type

Note: For purposes of our review, we excluded tribal governments, U.S. territories, and local governments in the
territories from our analysis.
aA metropolitan city is defined as the central city within a metropolitan area (i.e., a standard metropolitan
statistical area as established by the Office of Management and Budget) or any other city within a metropolitan
area that has a population of 50,000 or more. 42 U.S.C. §§ 803(g)(4), 5302(a)(4). A metropolitan city includes
cities that relinquish or defer their status as a metropolitan city for purposes of receiving allocations under
section 5306 of Title 42, United States Code, for fiscal year 2021.
bNon-entitlement units of local government (NEU) are local governments typically serving populations of less
than 50,000. 42 U.S.C. §§ 803(g)(5), 5302(a)(5). NEUs include cities, villages, towns, townships, or other types
of local governments.

Treasury employed various methodologies to determine how much funding
states and localities received, based on such factors as population size and
unemployment rates. ARPA required Treasury to send direct payments to all
SLFRF recipients except NEUs.7 ARPA required that states receive NEU funds
from Treasury, and then allocate and distribute payments to each NEU within
their state.

Treasury requires recipients to submit “project and expenditure” reports quarterly
or annually, depending on the recipient type, population, and award size. All
SLFRF recipients, including states and local governments, were required to
submit a report to Treasury by April 30, 2024, based on their award spending as
of March 31, 2024.8
In the project and expenditure reports, recipients are to detail their uses of
SLFRF funds, including obligations and spending amounts, and projects
undertaken. Treasury defines an obligation, in part, as an order placed for
property and services and entering into contracts, subawards, and similar
transactions that require payment.9
The SLFRF allows for a broad range of eligible uses to respond to the COVID-19
pandemic and its economic effects.10 SLFRF recipients are required to report on
their uses of funds across 10 spending categories (see fig. 2).11
What information are
SLFRF recipients
required to report to
Treasury on their uses
of funds?

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GAO-24-107301 Fiscal Recovery Funds
Figure 2: Coronavirus State and Local Fiscal Recovery Funds Spending Categories in Treasury Project and
Expenditure Reports, as of March 31, 2024

aTreasury guidance refers to this category as Public health-Negative economic impact: Public sector capacity.
bBased on Treasury guidance, recipients may not provide premium pay for work performed after April 10, 2023,
when the National Emergency concerning COVID-19 ended, but may award premium pay for work performed
prior to that date.
cSpending for Surface Transportation and Title I projects, combined, cannot exceed the greater of $10 million or
30 percent of a recipient’s SLFRF allocation.
Of the spending categories, revenue replacement provides recipients with the
most flexibility in using SLFRF awards and streamlining reporting requirements,
according to Treasury guidance. Under this category, recipients may use funds to
cover a broad range of government services (i.e., generally any service
traditionally provided by a government) up to the amount of revenue loss
experienced during the pandemic. Based on Treasury FAQs, recipients may use
SLFRF awards for revenue replacement for projects that are also eligible under
the other spending categories because those categories include services that
governments provide.12
Recipients may calculate revenue loss using a formula that Treasury established,
or they may elect a “standard allowance,” which allows them to spend up to $10
million (not to exceed their total SLFRF award amount) over the course of the
SLFRF program.13
Further, according to Treasury guidance, revenue replacement spending for
government services can be reported in the project and expenditure reports as a
single project, even if the project description notes that funds are used for more
than one activity or purpose.14

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GAO-24-107301 Fiscal Recovery Funds

In the aggregate, the states, including the District of Columbia, reported
obligating $163.7 billion (84 percent) and spending $117.3 billion (60 percent) of
the $195.8 billion in SLFRF awards they received, as of March 31, 2024.15 In
comparison, states reported obligating 60 percent and spending 45 percent of
their SLFRF awards, in the aggregate, as of March 31, 2023.
Obligated
Figure 3 shows the share of SLFRF award amounts states reported obligating as
of March 31, 2024. The majority of states (36, including the District of Columbia)
reported obligating at least 75 percent of their SLFRF awards. North Dakota (100
percent), Minnesota and Missouri (over 99 percent each), and California (99
percent) reported obligating the largest shares. New Jersey (51 percent) and
New York and Alabama (54 percent each) reported obligating the lowest shares.
Figure 3: Reported Obligations of Coronavirus State and Local Fiscal Recovery Funds (SLFRF) by States and the District of
Columbia, as of March 31, 2024

Note: Percentages have been rounded to the nearest whole percent.
Spent
Figure 4 shows the share of SLFRF award amounts that states reported
spending as of March 31, 2024. Nine states reported spending 75 percent or
more of their SLFRF awards, while 20 states reported spending less than 50
percent. Minnesota (99 percent), Alaska (97 percent), Illinois (96 percent), and
Hawaii (89 percent) reported spending the largest shares while South Carolina,
Oklahoma, Mississippi, and Tennessee reported spending the smallest shares
(less than 25 percent each).
How much of their
SLFRF awards have
states obligated and
spent as of March 31,
2024?

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Figure 4: Reported Spending of Coronavirus State and Local Fiscal Recovery Funds (SLFRF) by States and the District of
Columbia, as of March 31, 2024

Note: Percentages have been rounded to the nearest whole percent.

In the aggregate, the majority of the $117.3 billion in SLFRF awards the states
reported spending was used for two purposes: (1) replacing revenue and (2)
addressing the negative economic impacts of COVID-19. Figure 5 shows that
states reported spending 45 percent ($53.2 billion) of their SLFRF awards to
replace revenue and 39 percent ($45.5 billion) of their awards to address the
negative economic impacts of COVID-19.

How have states used
their SLFRF awards?

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Figure 5: How States Reported Spending Coronavirus State and Local Fiscal Recovery Funds (SLFRF) by Treasury Spending
Category, as of March 31, 2024

Note: Percentages may not add to 100 due to rounding.
aOther includes funding for such purposes as assistance for education, healthy childhood environments, and
social determinants of health.
bRecipients generally may use funds under the revenue replacement category to meet the non-federal cost-
share or matching requirements for other federal programs.
cBased on Treasury guidance, recipients may not provide premium pay for work performed after April 10, 2023,
when the National Emergency concerning COVID-19 ended, but may award premium pay for work performed
prior to that date.
dTreasury guidance refers to this category as Public health-Negative economic impact: Public sector capacity.
Replacing Revenue
The degree to which states used SLFRF awards to replace revenue varied:
•
In 15 states, revenue replacement accounted for 50 percent or more of
reported spending. North Dakota (100 percent), West Virginia (96 percent),
and Wyoming (82 percent) reported the largest shares of spending on
replacing revenue.
•
Five states—Idaho, Nebraska, Oklahoma, South Dakota, and Tennessee—
did not report spending any funds to replace revenue.
Of the funds spent on replacing revenue, nearly all of it (over 99 percent) was
spent on government services. As noted earlier, states may use their funds to
cover a broad range of government services under this spending category up to
the amount of revenue loss experienced during the pandemic. Examples of
individual projects reported by states to replace revenue include:
•
Nevada reported spending $747,323 to help maintain staffing levels and
continue required services in the state’s court system, due to a budget
shortfall from declines in revenue during the pandemic.
•
Hawaii reported spending $41.2 million to pay salaries and benefits for
medical staff working for a state-run health organization.

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GAO-24-107301 Fiscal Recovery Funds
•
Louisiana reported spending $295.9 million to fund the state’s Transportation
Trust Fund to support the construction of roads and bridges.
Addressing the Negative Economic Impacts of COVID-19
Overall, 20 states reported spending 50 percent or more of the SLFRF awards
they received on addressing the negative economic impacts of the pandemic.
Minnesota (83 percent), Maine (80 percent), and Ohio (78 percent) reported the
largest shares of spending for this purpose.
Of the $45.5 billion that states reported spending to address the negative
economic impacts of the pandemic, states spent 79 percent on providing
assistance to households. Contributions to state unemployment insurance trust
funds represented the largest share ($23.2 billion or 51 percent) of this spending
category.16 The states that reported spending the largest amount of awards on
these trust funds included Texas ($7 billion), Illinois ($4.1 billion), and Minnesota
($2.3 billion).
Examples of states’ reported spending on individual projects to address the
negative economic impacts of the pandemic include:
•
The District of Columbia reported spending $37.9 million to help hotels
mitigate the effects of the pandemic on hotel stays.
•
Nebraska reported spending $5 million on providing student financial
assistance at six community colleges.
•
Vermont reported spending $57.8 million on affordable housing projects.

In the aggregate, 26,398 localities submitted project and expenditure reports with
information as of March 31, 2024. Figure 6 shows that these localities received
$125.9 billion in SLFRF funds. An additional 4,272 localities, which received $2
billion in SLFRF awards, had not submitted a project and expenditure report with
information as of March 31, 2024. We plan to evaluate Treasury’s oversight of
these recipients in a future report.
Figure 6: Amount of Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Received
by Locality Type, as of March 31, 2024

Note: Amounts may not total due to rounding.
aCities refer to metropolitan cities as defined in 42 U.S.C. § 803(g)(4).
bNon-entitlement units of local government as defined in 42 U.S.C. § 803(g)(5).

In the aggregate, localities reported obligating $95.8 billion (76 percent) and
spending $75.8 billion (60 percent) of the $125.9 billion in SLFRF awards they
received, as of March 31, 2024. In comparison, the 26,410 localities that
How much of their
SLFRF awards have
localities received,
obligated, and spent?

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GAO-24-107301 Fiscal Recovery Funds
submitted a report 1 year prior, with information as of March 31, 2023, reported
obligating 54 percent and spending 38 percent of their awards in the aggregate.17
The share of total SLFRF awards localities reported obligating and spending
varied slightly by locality type. As shown in figure 7, cities, counties, and NEUs
each reported obligating between 75 and 80 percent of their awards as of March
31, 2024.
Figure 7: Obligations and Spending of Coronavirus State and Local Fiscal Recovery Funds
(SLFRF) Reported by Localities, as of March 31, 2024

aCities refer to metropolitan cities as defined in 42 U.S.C. § 803(g)(4).
bNon-entitlement units of local government as defined in 42 U.S.C. § 803(g)(5).
Obligated
The shares of SLFRF awards localities reported as obligated varied by locality
type. For example, as shown in figure 8, over half of cities (61 percent), counties
(70 percent), and NEUs (72 percent) each reported obligating at least 75 percent
of their awards. However, some cities and counties (2 percent each) and NEUs
(11 percent) reported obligating none of their awards.
Figure 8: Obligations of Coronavirus State and Local Fiscal Recovery Funds (SLFRF)
Reported by Localities, as of March 31, 2024

Note: Percentages may not add to 100 due to rounding.
aCities refer to metropolitan cities as defined in 42 U.S.C. § 803(g)(4).
bNon-entitlement units of local government as defined in 42 U.S.C. § 803(g)(5).

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Spent
The shares of SLFRF awards localities reported spending varied by locality type.
For example, figure 9 shows that over half of cities (63 percent), counties (68
percent), and NEUs (69 percent) each reported spending at least 50 percent of
their SLFRF awards. Some cities (2 percent), counties (3 percent), and NEUs (13
percent) reported spending none of their SLFRF awards.
Figure 9: Spending of Coronavirus State and Local Fiscal Recovery Funds (SLFRF)
Reported by Localities, as of March 31, 2024

Note: Percentages may not add to 100 due to rounding.
aCities refer to metropolitan cities as defined in 42 U.S.C. § 803(g)(4).
bNon-entitlement units of local government as defined in 42 U.S.C. § 803(g)(5).

Similar to states, replacing revenue and addressing the negative economic
impacts of COVID-19 accounted for the majority of localities’ $75.8 billion in
SLFRF spending. Figure 10 shows that localities reported using 68 percent
($51.5 billion) of their total spending to replace revenue and 12 percent ($9.2
billion) to address the negative economic impacts of COVID-19.
Figure 10: Localities’ Coronavirus State and Local Fiscal Recovery Funds Reported Spending by Treasury Spending
Category, as of March 31, 2024

Note: Percentages may not add to 100 due to rounding.
How have localities
used their SLFRF
awards?

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aOther includes funding for such purposes as assistance for education, healthy childhood environments, and
social determinants of health.
bRecipients generally may use funds under the revenue replacement category to meet the non-federal cost-
share or matching requirements for other federal programs.
cOther includes the following spending categories: Natural Disasters, Surface Transportation, and Title I
projects.
dBased on Treasury guidance, recipients may not provide premium pay for work performed after April 10, 2023,
when the National Emergency concerning COVID-19 ended, but may award premium pay for work performed
prior to that date.
eTreasury guidance refers to this category as Public health-Negative economic impact: Public sector capacity.
Replacing Revenue and Addressing the Negative Economic Impacts of
COVID-19
Of the amount localities reported spending to replace revenue, nearly all (over 99
percent) was spent on government services. As of March 31, 2024, 17,930
localities had reported that replacing revenue accounted for all of their spending
(totaling $27.8 billion).
Of the $9.2 billion that localities reported spending to address the negative
economic impacts of the pandemic, localities spent the majority on assistance to
households (61 percent). The largest share of assistance to households
spending ($1.9 billion or 20 percent of spending to address the negative
economic impacts of the pandemic) was for addressing long-term housing
efforts, such as affordable housing and services for homeless individuals.
Another $1.3 billion (14 percent) of negative economic impacts spending was for
projects that included providing food assistance, cash transfers, and emergency
housing to individuals and communities in need.
As shown in figure 11, cities (72 percent) and NEUs (89 percent) spent a larger
share of their SLFRF awards on revenue replacement than counties (56
percent). Cities (13 percent) and counties (15 percent) spent a larger share of
their SLFRF awards on addressing the negative economic impacts of COVID-19
than NEUs (1 percent).

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Figure 11: Breakdown of Coronavirus State and Local Fiscal Recovery Funds Reported
Spending by Locality Type, as of March 31, 2024

Note: Percentages may not add to 100 due to rounding.
aCities refer to metropolitan cities as defined in 42 U.S.C. § 803(g)(4).
bNon-entitlement units of local government as defined in 42 U.S.C. § 803(g)(5).
cOther includes the following spending categories: Administrative, Natural Disasters, Surface Transportation,
and Title I projects.
dBased on Treasury guidance, recipients may not provide premium pay for work performed after April 10, 2023,
when the National Emergency concerning COVID-19 ended, but may award premium pay for work performed
prior to that date.
eTreasury guidance refers to this category as Public health-Negative economic impact: Public sector capacity.

The projects that individual localities reported spending on replacing revenue and
addressing the negative economic impacts of COVID-19 varied in their size,
scope, and purpose. Figure 12 provides examples of such projects.

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Figure 12: Examples of Projects that Selected Localities Reported Spending Coronavirus State and Local Fiscal Recovery
Funds on, as of March 31, 2024

aCities refer to metropolitan cities as defined in 42 U.S.C. § 803(g)(4).
bNon-entitlement units of local government as defined in 42 U.S.C. § 803(g)(5).

We provided a draft of this report to Treasury for review and comment. Treasury
provided technical comments, which we incorporated as appropriate.

To inform our work, we reviewed laws and regulations governing the SLFRF
program and Treasury SLFRF program guidance, policies, and procedures. We
also interviewed Treasury officials.
To determine how much SLFRF funding states and localities reported obligating
and spending, we analyzed data from project and expenditure reports that states
and localities submitted to Treasury that reflected SLFRF obligations and
spending as of March 31, 2024. Treasury made these data publicly available in
July 2024; these data were the most recently available at the time of our review.
To identify each locality as a city, county, or NEU, we analyzed Treasury data
and consulted with Treasury officials. We identified which recipients requested
their SLFRF awards directly from Treasury because cities and counties were to
receive funds directly from Treasury and NEUs were to receive their funds from
the states. For localities that received their funds from Treasury, we categorized
localities with “county,” “parish,” or “borough” in their name as a “county” and the
remaining localities as a “city.” For localities that did not receive funds directly
from Treasury, we categorized them as an “NEU.” In addition, Treasury officials
identified which localities were consolidated jurisdictions (i.e., local governments
Agency Comments
How GAO Did This
Study

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GAO-24-107301 Fiscal Recovery Funds
that received funds from a combination of city, county, or NEU allocations). To
categorize the consolidated jurisdictions, we determined the composition of their
funding and categorized them as the locality type that comprised the majority of
their SLFRF award total.
To assess the reliability of Treasury data, we reviewed Treasury’s technical
documentation for project and expenditure reports and discussed the data with
Treasury officials. We determined the data were sufficiently reliable for reporting
the amount of SLFRF awards states and localities received, obligated, and spent.
We conducted this performance audit from January 2024 to September 2024 in
accordance with generally accepted government auditing standards. Those
standards require that we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our audit objectives. We believe that the evidence
obtained provides a reasonable basis for our findings and conclusions based on
our audit objectives.

The Honorable Patty Murray
Chair
The Honorable Susan Collins
Vice Chair
Committee on Appropriations
United States Senate
The Honorable Ron Wyden
Chairman
The Honorable Mike Crapo
Ranking Member
Committee on Finance
United States Senate
The Honorable Bernard Sanders
Chair
The Honorable Bill Cassidy
Ranking Member
Committee on Health, Education, Labor, and Pensions
United States Senate
The Honorable Gary C. Peters
Chairman
The Honorable Rand Paul, M.D.
Ranking Member
Committee on Homeland Security and Governmental Affairs
United States Senate
The Honorable Tom Cole
Chairman
The Honorable Rosa L. DeLauro
Ranking Member
Committee on Appropriations
House of Representatives
The Honorable Cathy McMorris Rodgers
Chair
The Honorable Frank Pallone, Jr.
Ranking Member
Committee on Energy and Commerce
House of Representatives
List of Addressees

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GAO-24-107301 Fiscal Recovery Funds
The Honorable Mark E. Green, M.D.
Chairman
The Honorable Bennie G. Thompson
Ranking Member
Committee on Homeland Security
House of Representatives
The Honorable James Comer
Chairman
The Honorable Jamie Raskin
Ranking Member
Committee on Oversight and Accountability
House of Representatives
The Honorable Jason Smith
Chairman
The Honorable Richard Neal
Ranking Member
Committee on Ways and Means
House of Representatives

We are sending copies of this report to the appropriate congressional
committees, the Secretary of the Treasury, and other interested parties. In
addition, the report is available at no charge on the GAO website at
https://www.gao.gov.

For more information, contact: Jeff Arkin, Director, Strategic Issues,
ArkinJ@gao.gov, (202) 512-6806.
Sarah Kaczmarek, Managing Director, Public Affairs, KaczmarekS@gao.gov,
(202) 512-4800.
A. Nicole Clowers, Managing Director, Congressional Relations,
ClowersA@gao.gov, (202) 512-4400.
Staff Acknowledgments: Brenda Rabinowitz (Assistant Director), Colleen
Corcoran (Analyst-in-Charge), Michael Bechetti, McLeod Brown, Robert Gebhart,
Mike Maciag, Steven Putansu, Emmanuel Sanchez, Dylan Stagner, and Peter
Verchinski.
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1Pub. L. No. 117-2, tit. IX, subtit. M, § 9901, 135 Stat. 4, 223 (2021), codified at 42 U.S.C. §§ 802-
803 (ARPA). Sections 602 and 603 of the Social Security Act as added by section 9901 of ARPA
appropriated $350 billion in total funding for two funds—the Coronavirus State Fiscal Recovery
Fund and the Coronavirus Local Fiscal Recovery Fund. For purposes of this report, we discuss
these two funds as one—the Coronavirus State and Local Fiscal Recovery Funds (SLFRF). See 42
U.S.C. §§ 802-803. For purposes of the SLFRF, ARPA establishes that the District of Columbia is
considered to be a state. 42 U.S.C. §§ 802(g)(5), 803(g)(9).
2SLFRF recipients have until December 31, 2024, to obligate their SLFRF awards and generally
until December 31, 2026, to liquidate those obligations, in accordance with allowable uses
established in ARPA. The Consolidated Appropriations Act, 2023, authorized SLFRF funding for
GAO Contact
Information
Endnotes

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emergency relief from natural disasters or the negative economic impacts of natural disasters, and
certain infrastructure and community development projects that meet existing eligibility criteria.
Pub. L. No. 117-328, div. LL, § 102, 136 Stat. 4459, 6097 (2022). Funds for certain infrastructure
and community development projects must be obligated by December 31, 2024, and liquidated by
September 30, 2026. For example, this includes funds for the Bridge Investment Program, National
Highway Performance Program, and Surface Transportation Block Grant Program, among other
programs, and activities under Title I of the Housing and Community Development Act of 1974. 42
U.S.C. § 802(c)(5)(A)-(E).
3Pub. L. No. 116-136, § 19010(b), 134 Stat. 281, 580 (2020). All of our reports related to the
COVID-19 pandemic are available at https://www.gao.gov/coronavirus.
4See GAO, COVID-19 Relief: States’ and Localities’ Fiscal Recovery Funds Spending as of March
31, 2023, GAO-24-106753 (Washington, D.C.: Oct. 11, 2023) and COVID-19 Relief: State and
Local Recovery Funds Spending as of September 30, 2023, GAO-24-107472 (Washington, D.C.:
Apr. 10, 2024). We excluded tribal governments, U.S. territories, and local governments in the
territories from our analysis. We reported on federal agencies’ distribution of COVID-19 relief funds,
including the SLFRF, to tribal recipients in December 2022. See GAO, COVID-19 Relief Funds:
Lessons Learned Could Improve Future Distribution of Federal Emergency Relief to Tribal
Recipients, GAO-23-105473 (Washington, D.C.: Dec. 15, 2022). We reported on the U.S.
territories’ use of COVID-19 relief funds, including the SLFRF, in September 2023. See GAO,
COVID-19: U.S. Territory Experiences Could Inform Future Federal Relief, GAO-23-106050
(Washington, D.C.: Sept. 19, 2023).
5Treasury officials told us they make data from project and expenditure reports publicly available
after revisions and quality control processes are complete. Treasury will generally allow revisions or
edits to submitted reports or submissions of reports within a designated revision period, such as 60
days following the official submission due date, according to Treasury policy. Within this period, the
submitted report is considered final unless Treasury identifies a material mistake or problem in the
report and requests that the recipient make a revision. The next project and expenditure report that
all SLFRF recipients are required to submit is due to Treasury on April 30, 2025.
642 U.S.C. §§ 803(g)(5), 5302(a)(5). NEUs include cities, villages, towns, townships, or other types
of local governments.
7As of March 31, 2024, SLFRF awards had not yet been disbursed to some counties and Tribes
because those recipients had not requested their funds, according to Treasury. Specifically, this
included $9.7 million for counties and $4.6 million for Tribes. According to Treasury, as of August 5,
2024, the remaining funds across recipients included $9.7 million for counties and $3.7 million for
Tribes.
8See 87 Fed. Reg. 4338, 4437 (Jan. 27, 2022). The following recipients are required to submit
quarterly project and expenditure reports: (1) tribal governments that are allocated more than $30
million in funding; (2) states, the District of Columbia, U.S. territories, metropolitan cities and
counties with a population that exceeds 250,000 residents; (3) metropolitan cities and counties with
a population below 250,000 residents that are allocated more than $10 million in funding; and (4)
NEUs that are allocated more than $10 million in funding. The following recipients are required to
submit annual reports: (1) tribal governments that are allocated less than $30 million in funding, (2)
metropolitan cities and counties with a population below 250,000 residents that are allocated less
than $10 million in funding, and (3) NEUs that are allocated less than $10 million in funding.
Treasury officials told us they accept new data submissions and revisions to submissions from
recipients for 60 days following the submission deadline. For the data Treasury made publicly
available with information as of March 31, 2024, Treasury included the submissions received as of
June 28, 2024.
9On November 20, 2023, Treasury published an interim final rule to clarify the definition of
“obligation” ((88 Fed. Reg. 80584 (Nov. 20, 2023)) (Obligation IFR). The term “obligation” continues
to mean an order placed for property and services and entry into contracts, subawards, and similar
transactions that require payment. As discussed in the Obligation IFR, a recipient is also
considered to have incurred an obligation by December 31, 2024, with respect to satisfying a
requirement under federal law or regulation or a provision of the SLFRF award terms and
conditions to which the recipient becomes subject as a result of receiving or expending SLFRF
funds. Separate from this report, we are considering whether Treasury’s definition of “obligation” is
consistent with conditions in the law that established SLFRF.
10ARPA established that recipients can use their SLFRF awards to cover costs incurred by

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December 31, 2024, to (1) respond to the coronavirus public health emergency or its negative
economic impacts; (2) provide premium pay to essential workers, or grants to employers with
essential workers; (3) provide government services up to the amount of the reduction in revenue
due to the COVID-19 pandemic; and (4) make necessary investments in water, sewer, or
broadband infrastructure. 42 U.S.C. §§ 802(c), 803(c). Subsequently, the Consolidated
Appropriations Act, 2023, established that recipients may also use their awards to provide
emergency relief from natural disasters or the negative impacts of natural disasters and to invest in
certain infrastructure projects. Pub. L. No. 117-328, div. LL, § 102, 136 Stat. 4459, 6098 (2022),
which is codified at 42 U.S.C. §§ 802(c)(1)(E), 803(c)(1)(E), 802(c)(5), 803(c)(6). Based on
Treasury guidance, recipients may not provide premium pay for work performed after April 10,
2023, when the National Emergency concerning COVID-19 ended, but may award premium pay for
work performed prior to that date. There are several restrictions on recipients’ uses of SLFRF
awards. Recipients other than tribal governments may not deposit SLFRF awards into a pension
fund. 42 U.S.C. §§ 802(c)(2)(B), 803(c)(2). Also, recipients that are states or territories may not use
SLFRF awards to offset a reduction in net tax revenue resulting from the recipient’s change in law,
regulation, or administrative interpretation. 42 U.S.C. § 802(c)(2)(A). However, this offset provision
has been found to be unconstitutional by some courts. See West Virginia v. Dept. of Treasury, 59
F.4th 1124 (11th Cir. 2023); Texas v. Yellen, 105 F.4th 755 (5th Cir. 2024). In addition, recipients
may not use SLFRF awards to service debt, satisfy a judgment or settlement, or contribute to a
“rainy day” fund. 87 Fed. Reg. 4338, 4394 (Jan. 27, 2022).
11Treasury published an interim final rule implementing the eligible uses that resulted from the
Consolidated Appropriations Act, 2023. 88 Fed. Reg. 64986 (Sept. 20, 2023); Pub. L. No. 117-328,
136 Stat. 4459 (2022).
12Department of the Treasury, Coronavirus State and Local Fiscal Recovery Funds: Frequently
Asked Questions (as of March 29, 2024), accessed September 19, 2024,
https://home.treasury.gov/system/files/136/SLFRF-Final-Rule-FAQ.pdf.
13The Consolidated Appropriations Act, 2023, codified the availability of the standard allowance
provided in Treasury’s final rule. Pub. L. No. 117-328, div. LL, § 102(a), 136 Stat. 4459 (2022).
14In addition, unlike the other spending categories, Treasury is not collecting subaward data for
projects categorized as revenue replacement.
15ARPA allocated $195.3 billion to the 50 states and the District of Columbia. The District of
Columbia received $1.8 billion from the allocations for states. It also received approximately $510
million from the funds ARPA allocated to metropolitan cities and counties. As a result, the District of
Columbia received approximately $2.3 billion in total SLFRF allocations.

16According to the Department of Labor, each state maintains its own Unemployment Insurance
(UI) trust fund reserve built from state taxes, primarily on employers, and used only to pay for state
UI benefits. According to Treasury’s guidance, under the public health and negative economic
impacts spending category, recipients may use SLFRF funds for contributions to unemployment
insurance trust funds and repayment of the principal amount due on advances received under Title
XII of the Social Security Act up to an amount equal to (1) the difference between the balance in
the recipient’s unemployment insurance trust fund as of January 27, 2020, and the balance of such
account as of May 17, 2021; plus (2) the principal amount outstanding as of May 17, 2021, on any
advances received under Title XII of the Social Security Act between January 27, 2020, and May
17, 2021.
17See GAO-24-106753. We reported that 26,410 localities submitted project and expenditure
reports with spending to Treasury as of March 31, 2023. These reporting localities received $124.9
billion in SLFRF funds.

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