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U.S. Department of the Treasury, State and Local Fiscal Recovery Funds: "Counties/Cities with population less than 250,000 and awards over $5M Presentation"

Summary

A June 2021 U.S. Department of the Treasury webinar presentation introducing the Coronavirus State and Local Fiscal Recovery Funds compliance and reporting guidance for metropolitan cities and counties with a population less than 250,000 that received more than $5 million in SLFRF funding. It states that ARPA was signed into law on March 11, 2021 and created SLFRF to deliver $350 billion, and that the Interim Final Rule was adopted on May 10, 2021, with comments due July 16, 2021. Eligible costs run from March 3, 2021 to December 31, 2024, with funds obligated by December 31, 2024 and expended by December 31, 2026. These recipients submit a one-time interim report by August 31, 2021 and quarterly project and expenditure reports beginning by October 31, 2021.

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“U.S. Department of the Treasury, State and Local Fiscal Recovery Funds: ‘Counties/Cities with population less than 250,000 and awards over $5M Presentation.’” Original at home.treasury.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/u-s-department-of-the-treasury-state-and-local-fiscal-recovery-funds-c-0c285a2656/, SHA-256 14798b5115b236bb3024cfe0fffe0957999ddf4fee587b8a5d8cd864b89d78ca.

Full text

AN INTRODUCTION TO THE

Coronavirus State and Local
Fiscal Recovery Funds
Compliance and Reporting Guidance
For metropolitan cities and counties with a population less than
250,000 which received more than $5 million in SLFRF funding
  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:

  Metropolitan cities and counties with a population less than
 250,000 which received more than $5 million in SLFRF funding
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
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




                                                             13
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




                                                                                            14
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


                                                                                        15
Part 2: Reporting Guidance
Reporting Requirements
Metropolitan city or county with a population below 250,000 residents and receiving
more than $5 million in funding 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,         • By October 31, 2021 and 30
           Date            2021                    days after the end of each
                         • Covers date of          quarter thereafter
                           award through
                           July 31, 2021



                                                                                      17
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.




                                                                                18
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.




                                                                          19
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)




                                                                                     20
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.


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


                                                                                                                21
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
                                •   Expenditures
   Projects and
                                •   Project Status
   Expenditures
                                •   Project Demographic Distribution
                                •   Civil Rights Compliance

   Subawards                    •   Subawards

                                •   Required Programmatic Data
   Program data
                                •   Required Programmatic Data (for infrastructure)




                                                                                        22
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.




                                                                     23
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




                                                                          24
Part 2B: Project and Expenditure Report-
Programmatic Data (Non-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.



                                                                                         25
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.




                                                                   26
Reporting Requirements
Metropolitan city or county with a population below 250,000 residents and receiving
more than $5 million in funding 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,         • By October 31, 2021 and 30
           Date            2021                    days after the end of each
                         • Covers date of          quarter thereafter
                           award through
                           July 31, 2021



                                                                                      27
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


                                                            29


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