Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance (Webinar, June 2021)
Summary
Slides for a June 2021 U.S. Department of the Treasury webinar introducing the Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, for states and U.S. territories. The slides say the American Rescue Plan Act was passed by Congress on March 10, 2021 and signed into law on March 11, 2021, and that it created the program to deliver $350 billion to states, territories, municipalities, counties and Tribal governments. They describe the Interim Final Rule adopted on May 10, 2021, with comments due July 16, 2021, and say the reporting guidance is split into General Guidance and Reporting Requirements. A schedule lists separate webinar sessions for other types of recipients.
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“Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance (Webinar, June 2021).”
Original at home.treasury.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/treas-slfrp-reporting-guidance-webinar-states-and-territories-fbd6a90ac8/
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AN INTRODUCTION TO THE
Coronavirus State and Local
Fiscal Recovery Funds
Compliance and Reporting Guidance
June 2021
Webinar Overview
The content of this webinar specifically covers the compliance and reporting
requirements of the State and Local Fiscal Recovery Funds program for:
States and U.S. territories
If you do not fall into this category of recipient, other webinar sessions are scheduled
this week specifically addressing your requirements.
This session provides an introduction to your compliance
and reporting responsibilities as discussed in the SLFRP
Compliance and Reporting Guidance. You can find this
document at treasury.gov/SLFRPreporting.
The session will not cover the State and Local Fiscal
Recovery Fund Interim Final Rule or permitted uses under
the Interim Final Rule.
2
SLFRF Webinar Schedule
Please refer to the chat for the registration links
States and Territories Tuesday, June 22 at 1:30 – 2:30 p.m. ET
Metropolitan cities and counties with a Thursday, June 24 at 1:30 – 2:30 p.m. ET
population that exceeds 250,000 residents
Metropolitan cities and counties with a Thursday, June 24 at 12:00 – 1:00 p.m. ET
population below 250,000 residents which Friday, June 25 at 1:30- 2:30 p.m. ET
received more than $5 million in SLFRF funding
Metropolitan cities and counties with a Tuesday, June 22 at 11:30 a.m. – 12:30 pm
population below 250,000 residents which Wednesday, June 23 at 1:30 – 12:30 p.m. ET
received less than $5 million in SLFRF funding
Tribes / Tribal Associations Monday, June 28 at 3:00 – 4:00 p.m. ET
3
Agenda
This session provides an introduction to your compliance and reporting responsibilities
as discussed in the SLFRP Compliance and Reporting Guidance. You can find this
document at treasury.gov/SLFRPreporting.
• Overview
• Part 1: General Guidance
• Part 2: Reporting Guidance
• Q&A
4
SLFRF Resources
For More Information:
Please visit Treasury’s State & Local website
at www.treasury.gov/SLFRP
To Request Funding:
Please visit www.treasury.gov/funding
For Media Inquiries:
Please contact the U.S. Treasury Press Office
at (202) 622-2960
For General Inquiries:
Please email SLFRP@treasury.gov
5
Overview
The American Rescue Plan Act of 2021
The American Rescue Plan Act (ARPA) is providing fast and direct economic assistance
for American workers, families, small businesses, and industries and it:
• Continues programs started by the CARES Act in 2020 and Consolidated
Appropriations Act in 2021.
• Adds new phases, allocations, and guidance to address issues related to the
continuation of the COVID-19 pandemic.
• Creates new programs to address continuing pandemic-related crises, and fund
recovery efforts as the United States begins to emerge from the COVID-19
pandemic.
• Was passed by Congress on March 10, 2021, and signed into law on March 11,
2021.
7
Coronavirus State and Local Fiscal Recovery
Funds Overview
ARPA created the Coronavirus State and Local Fiscal Recovery Funds (SLFRF) program
to deliver $350 billion for state, territories, municipalities, counties, and Tribal
governments much needed aid.
The key objectives for SLFRF are to:
• Support the urgent COVID-19 response efforts to continue to decrease spread of
the virus and bring the pandemic under control.
• Replace lost revenue for eligible recipients to strengthen support for vital public
services and help retain jobs.
• Support immediate economic stabilization for households and businesses.
• Address systemic public health and economic challenges that have contributed to
the inequal impact of the pandemic on certain populations.
8
Interim Final Rule
SLFRF is subject to the requirements and guidance specified in the Interim Final Rule,
adopted on May 10, 2021. The Interim Final Rule:
• Establishes a framework for determining the types of programs and services
eligible under ARPA.
• Builds on the use of eligible expenditures under the Coronavirus Relief Fund (CRF).
• Recognizes the broad range of eligible uses to help SLFRF recipients.
• Establishes certain regular reporting requirements, including requiring certain
recipients to publish information regarding use of SLFRF spend.
Treasury is seeking comments on all aspects of the Interim Final Rule.
Comments are due July 16, 2021 and can be electronically submitted through the
Federal eRulemaking Portal or via mail to the Treasury.
9
Compliance and Reporting Guidance Overview
On Jun 17, 2021, Treasury released the SLFRF
Compliance and Reporting Guidance, which builds
on the Interim Final Rule.
All SLFRF recipients are required to meet the
compliance and reporting responsibilities noted in
the Interim Final Rule.
The Reporting Guidance is broken into two parts:
(1) General Guidance
(2) Reporting Requirements
10
Purpose of the Reporting Guidance
The SLFRF Reporting Guidance will ensure a speedy, equitable, transparent, and accountable
recovery for all Americans
Accountable: Ensure recipients fulfill their compliance responsibilities
and use funding as intended
Transparent: Provide the public data on how these funds were used
and the outcomes achieved
User Friendly: Provide as easy and efficient user experience as
possible
11
Focused on Recovery
The Reporting Guidance addresses priority areas to ensure a speedy and equitable
recovery.
Equity Focused Community
Empowering
Results and evidence
Worker-Centered
focused
12
Part 1: General Guidance
Recipient Compliance Overview
• Part 1B: Statutory Eligible Uses
• Part 1C: Treasury’s Interim Final Rule
• Part 1D: Uniform Guidance (2 CFR)
Requirements
• Part 1D: Award Terms & Conditions
14
Parts 1B and 1C: Statutory Eligible Uses and
Treasury’s Rulemaking
Part 1.C.1:
• SLFRF has four permitted uses and certain restricted
Eligible and Restricted Uses uses
• Eligible costs incurred between March 3, 2021 and
Part 1.C.2: December 31, 2024
Eligible Cost Timeframe • Funds obligated by December 31, 2024 and
expended by December 31, 2026
• Generally, initial interim report, quarterly or annual
Part 1.C.3: Project and Expenditure reports, and Recovery Plan
Reporting Requirements
15
Parts 1D and 1E: Uniform Administrative
Requirements and Award Terms and Conditions
SLFRF recipients must follow the Uniform Administrative Requirement, Cost Principles,
and Audit Requirements for Federal Awards (2 CFR Part 200) and the Terms and
Conditions of the SLFRF assistance.
• Allowable Activities
• Allowable Costs/Cost Principles (such as administrative costs and salaries
and expenses)
• Cash Management
• Eligibility
• Subrecipient Monitoring
• SAM.gov Requirements
• Recordkeeping Requirements
• Single Audit Requirements
• Civil Rights Compliance
16
Part 2: Reporting Guidance
Reporting Requirements
States and U.S. Territories submit:
2. Project and
1. Interim Report 3. Recovery Plan
Expenditure Report
Contents • Initial overview of • Types of projects funded • Approach and
status and uses of • Financial data objectives
funding • Information on contracts, • Descriptions of funded
grants, and subawards projects
over $50,000 • Performance and
evidence information
• Promoting equity
Frequency & • One-time • Quarterly • Annually
Submission • By August 31, 2021 • By October 31, 2021 and • By August 31, 2021
Date • Covers date of 30 days after the end of (covering award
award through July each quarter thereafter through July 31, 2021)
31, 2021 and annually thereafter
18
Key Concept: Expenditure Category
An Expenditure Category (EC) is a coding system to track how funding is used,
and will also be used to identify where additional programmatic data is
required.
Appendix 1 includes a list of 66 Expenditure Categories.
19
Key Concepts: Projects
Projects:
• Closely related activities toward a common purpose/goal
• New or existing services or investments
• Funded in whole or in part by SLFRF funding
• Each project must align to one Expenditure Category. Projects
break down an Expenditure Category into more detail.
• Recipients have flexibility to define their projects – but must
provide a sufficient level of detail to be able to report on specific
activities for each project, including any required program
reporting.
20
Key Concepts: Relationships
Expenditure Category
(e.g., Education Assistance: Early
Learning)
Project A
Project B
(e.g. Pre-school services) Obligations/Expenditures
Subaward (e.g., Contract)
Subaward (e.g., Grant)
21
Part 2C: Recovery Plan
Provide information on how recipients are using program funding
to achieve outcomes in an effective, efficient, and equitable
manner.
• The first report is due August 31, 2021.
• Posted on the recipients' public-facing website and submitted
to Treasury.
• Key data from Recovery Plan will also be entered into Treasury
reporting system.
22
Part 2C: Recovery Plan
Minimum requirements of the Recovery Plan include:
• Executive Summary
Narrative • Use of Funds
description of • Promoting Equitable Outcomes
how funds will be • Community Engagement
used • Labor Practices
• Use of Evidence
Project inventory • Table of Expenses by Expenditure Category
• Project Inventory
Program data and • Performance Report
performance • Required Performance Data
indicators • Ineligible Activities: Tax Offset Provisions
23
1.C.3: Promoting Equitable Outcomes
Describe how funds will promote racially and economically
equitable outcomes:
• Goals for improving equity
• Barriers to services for communities and individuals
• Track progress and assess outcomes
Describe specific equity strategies for services or programs in Negative
Economic Impacts (EC 2) and Services to Disproportionately Impacted
Communities (EC 3)
Equity defined in President Biden’s Executive Order on Executive Order
13985, On Advancing Racial Equity and Support for Underserved
Communities Through the Federal Government
24
Community Engagement and Labor Practices
1.C.4: Community Engagement
• Gather feedback from diverse constituents and community-based
organizations
• Carry out projects that build community capacity and reach underserved
populations
1.C.5: Labor Practices:
• Promote effective and efficient delivery of high quality infrastructure
projects
25
1.C.6: Evidenced-Based Interventions
Identify amount of project funds allocated to evidence-based interventions OR if
undergoing rigorous program evaluation.
Applies to most Expenditure Categories in:
• Public Health (EC 1)
• Negative Economic Impacts (EC 2)
• Services to Disproportionately Impacted Communities (EC 3)
Encouraged to use Learning Agendas and relevant evidence Clearinghouses to assess
the level of evidence for your interventions.
Evidence defined in Appendix 2
26
1.C.9: Performance Report
Key performance indicators for each project (or a group of projects),
including:
• Output measures describe what was produced or services delivered
• Outcome measures the impact of the project and progress towards project
goals
Measures determined by recipients
Funds may be used to improve to data or technology infrastructure, data
analytics, capacity, and perform program evaluations.
27
1.C.10: Required Performance Indicators
Mandatory performance indicators for projects in the following areas:
a. Household Assistance (EC 2.2 & 2.5) and Housing Support (EC 3.10-3.12):
• Number of people or households receiving eviction prevention services (including legal
representation)
• Number of affordable housing units preserved or developed
b. Negative Economic Impacts (EC 2):
• Number of workers enrolled in sectoral job training programs
• Number of workers completing sectoral job training programs
• Number of people participating in summer youth employment programs
c. Education Assistance (EC 3.1-3.5):
• Number of students participating in evidence-based tutoring programs
d. Healthy Childhood Environments (EC 3.6-3.9):
• Number of children served by childcare and early learning
• Number of families served by home visiting
28
1.C.11: Ineligible Activities: Tax Offset Provision
SLFRF funding is not used for deposits into pensions or to offset a reduction in new tax
revenue,
States and territories will report actual tax revenue and calculating tax revenue for the
fiscal year ending 2019:
• If available, recipients should report audited financial information
Per Interim Final Rule, Treasury is seeking comment on reporting requirements related
to this provision
29
Part 2A: Interim Report
Initial overview of status and funding (covering spending from March 3 to June 31,
2021) and is due August 31, 2021.
One-time report to provide obligations and expenditures by Expenditure Category:
• Requires a breakdown by all Expenditure Categories (e.g., 1.1 COVID-19 Vaccination)
• Do not need a breakdown by project
Example
ID Category Cumulative Obligations to Date Cumulative Expenditures to Date
1 Public Health
1.1 COVID-19 Vaccination $1,000,000 $800,000
1.2 COVID-19 Testing $1,800,000 $1,100,000
1.3 COVID-19 Contact Tracing
1.4 Prevention in Congregate Settings $3,498,000
30
Part 2A: Interim Report
Required Programmatic Data includes:
Revenue • Revenue replacement formula and other revenue calculation
Replacement details and exclusions
• If available, use audited data
• Description of services provided
Distributions to NEUs • Disclosure of distributions to NEUs to determine appropriate
(States and territories funding disbursements to NEUs
only)
31
Part 2B: Project and Expenditure Report
Project and Expenditure Reports include projects and contracts, grants, and subawards
over $50,000. First report is due on October 31, 2021, and 30 days after the end of
each quarter thereafter.
• Project Inventory
• Expenditures
Projects and
• Project Status
Expenditures
• Project Demographic Distribution
• Civil Rights Compliance
Subawards • Subawards
• Required Programmatic Data
Program data • Required Programmatic Data (for infrastructure)
• Distributions to NEUs (States and territories only)
32
Part 2B: Project and Expenditure Report-
Project Demographic Distribution
Identify whether or not the project is serving an economically
disadvantaged community, based if program or service is:
• Provided at a physical location in a Qualified Census Tract
(QCT)
• Primary intended beneficiaries live within a QCT
• Eligibility criteria are such that the primary intended
beneficiaries earn less than 60 percent of the median income;
or
• Eligibility criteria are such that over 25 percent of intended
beneficiaries are below the federal poverty line.
33
Part 2B: Project and Expenditure Report-
Programmatic Data (Non-Infrastructure Projects)
Provide specific programmatic data requirements for non-infrastructure
projects for each Expenditure Category, including:
• Payroll for Public Health and Safety Employees
• Household Assistance
• Small Business Economic Assistance
• Aid to Travel, Tourism, and Hospitality or Other Impacted Industries
• Rehiring Public Sector Staff
• Education Assistance
• Premium Pay
• Revenue Replacement
34
Part 2B: Project and Expenditure Report-
Programmatic Data (Infrastructure Projects)
Infrastructure projects must report detailed project level information, location, and
expenditure data
All Water, Sewer, and Broadband infrastructure projects over $10m must also report:
• Number of employees/contractors
• Number of direct or third party hires
• Wages/benefits by worker classification
• Whether wages are at prevailing page
Recipients must also report:
• Detailed information on the wages and benefits provided, and how they will ensure
a ready supply of skilled and unskilled labor, minimize the risk of labor disputes,
and ensure a safe and healthy workplace.
• Some additional reporting requirements may be waived for recipients who can
certify compliance with Davis-Bacon or certify they have entered into a Project
Labor Agreement.
35
Treasury Submission Portal and Training
• Information submitted via Treasury Submission Portal.
• Detailed User Guide and reference materials will be provided
• Technical assistance webinars to support recipients’ reporting
requirements.
• Further communications to be posted on Treasury’s website.
36
Reporting Requirements
States and U.S. Territories submit:
2. Project and
1. Interim Report 3. Recovery Plan
Expenditure Report
Contents • Initial overview of • Types of projects funded • Approach and
status and uses of • Financial data objectives
funding • Information on contracts, • Descriptions of funded
grants, and subawards projects
over $50,000 • Performance and
evidence information
• Promoting equity
Frequency & • One-time • Quarterly • Annually
Submission • By August 31, 2021 • By October 31, 2021 and • By August 31, 2021
Date • Covers date of 30 days after the end of (covering award
award through July each quarter thereafter through July 31, 2021)
31, 2021 and annually thereafter
37
Q&A
Thank you
For More Information:
Please visit Treasury’s State & Local website
at www.treasury.gov/SLFRP
To Request Funding:
Please visit www.treasury.gov/funding
For Media Inquiries:
Please contact the U.S. Treasury Press Office
at (202) 622-2960
For General Inquiries:
Please email SLFRP@treasury.gov
39
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