State and Local Fiscal Recovery Funds Compliance and Reporting Guidance for Tribal Governments (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 Tribal Governments. The slides restate that the American Rescue Plan Act created the program to deliver $350 billion and describe the Interim Final Rule adopted on May 10, 2021, on which Treasury sought comments due July 16, 2021. The general guidance part lists four permitted uses, eligible costs incurred between March 3, 2021 and December 31, 2024, and funds obligated by December 31, 2024 and expended by December 31, 2026. The deck then turns to reporting requirements and closes with questions and answers.
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“State and Local Fiscal Recovery Funds Compliance and Reporting Guidance for Tribal Governments (June 2021).”
Original at home.treasury.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/treas-slfrp-reporting-guidance-webinar-tribes-521896833b/
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AN INTRODUCTION TO THE
Coronavirus State and Local
Fiscal Recovery Funds
Compliance and Reporting Guidance
For Tribal Governments
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:
Tribal Governments
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
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
3
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 tribal.consult@treasury.gov
4
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.
6
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.
7
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.
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.
8
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
applicable compliance and reporting
responsibilities noted in the Interim Final Rule.
The Reporting Guidance is broken into two parts:
(1) General Guidance
(2) Reporting Requirements
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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
10
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
12
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 and quarterly Project
Part 1.C.3: and Expenditure reports.
Reporting Requirements
13
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 applicable 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
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Part 2: Reporting Guidance
Reporting Requirements- Tribal governments
Tribal Governments submit:
2. Project and
1. Interim Report
Expenditure Report
Contents • Initial overview of • Types of projects funded
status and uses of • Financial data
funding • Information on contracts,
grants, and subawards
over $50,000
Frequency & • One-time • Quarterly
Submission • By August 31, 2021 • By October 31, 2021 and
Date • Covers date of 30 days after the end of
award through July each quarter thereafter
31, 2021
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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.
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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.
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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)
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Part 2A: Interim Report
Initial overview of status and funding (covering spending from March 3 to July 31, 2021) and is
due August 31, 2021.
One-time report to provide obligations and expenditures by Expenditure Category at the
summary level.
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
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
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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 quarterly thereafter.
• Project Inventory
Projects and • Expenditures
Expenditures • Project Status
Subawards • Subawards
• Required Programmatic Data
Program data
• Required Programmatic Data (for infrastructure)
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Part 2B: Project and Expenditure Report-
Project Demographic Distribution
Identify whether or not the project is serving an economically
disadvantaged community based on if the 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.
• Note: Pursuant to the Interim Final Rule, programs and
services provided by a Tribal government are presumed to
serve an economically disadvantaged community.
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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
23
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.
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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.
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Reporting Requirements- Tribal governments
Tribal Governments submit:
2. Project and
1. Interim Report
Expenditure Report
Contents • Initial overview of • Types of projects funded
status and uses of • Financial data
funding • Information on contracts,
grants, and subawards
over $50,000
Frequency & • One-time • Quarterly
Submission • By August 31, 2021 • By October 31, 2021 and
Date • Covers date of 30 days after the end of
award through July each quarter thereafter
31, 2021
26
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 tribal.consult@treasury.gov
28
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