U.S. Department of the Treasury, State and Local Fiscal Recovery Funds: "NEU Reporting Overview - presentation"
Summary
A Treasury presentation dated March 21, 2022 introducing non-entitlement units of local government (NEUs) to the Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance. It states that the American Rescue Plan Act created the program to deliver $350 billion and that Treasury released the final rule on January 6, 2022, effective April 1, 2022, with a standard allowance of up to $10 million for revenue loss. The slides list required NEU agreements and documents due by April 30, 2022 and Project and Expenditure Report deadlines, quarterly for NEUs allocated more than $10 million and annual for those allocated less. Two paths for submitting the report are described, one covering only projects under Expenditure Category 6: Revenue Replacement.
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“U.S. Department of the Treasury, State and Local Fiscal Recovery Funds: ‘NEU Reporting Overview - presentation.’”
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AN INTRODUCTION TO THE
Coronavirus State and Local
Fiscal Recovery Funds
Compliance and Reporting Guidance
Non-entitlement Units of Local Government
March 21, 2022
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
1
SLFRF Resources (1 of 2)
For More SLFRF Information:
Please visit Treasury’s State & Local website at
www.treasury.gov/SLFRP to find information including
the Overview of the Final Rule, FAQs, and the Final Rule.
Please visit Treasury’s website dedicated to NEUs.
For Reporting Information:
Please visit Treasury’s State & Local website at
www.treasury.gov/SLFRPReporting
For General Inquiries:
Please email SLFRP@treasury.gov
2
SLFRF Resources (2 of 2)
• Compliance and Reporting Guidance
https://home.treasury.gov/policy-issues/coronavirus/assistance-for-state-local-and-tribal-
governments/state-and-local-fiscal-recovery-funds/recipient-compliance-and-reporting-
responsibilities
• Overview of the final rule
https://home.treasury.gov/system/files/136/SLFRF-Final-Rule-Overview.pdf
• Final rule
https://www.govinfo.gov/content/pkg/FR-2022-01-27/pdf/2022-00292.pdf
• Statement regarding the IFR and final rule:
https://home.treasury.gov/system/files/136/SLFRF-Compliance-Statement.pdf
• NEU Page
https://home.treasury.gov/policy-issues/coronavirus/assistance-for-state-local-and-tribal-
governments/state-and-local-fiscal-recovery-fund/non-entitlement-units
3
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.
5
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:
• Fight the pandemic and support families and businesses struggling with its
public health and economic impacts
• Maintain vital public services, even amid declines in revenue resulting from
the crisis
• Build a strong, resilient, and equitable recovery by making investments
that support long-term growth and opportunity
6
Final Rule
• Treasury released the final rule on January 6, 2022.
• The final rule takes effect on April 1, 2022.
• If a use of funds complies with the final rule, Treasury will not take action to
enforce the interim final rule, regardless of when the funds were used (e.g., if
the IFR would not permit that use of funds); recipients can take advantage of
the expanded flexibilities in the final rule now.
• Treasury structured the Final Rule with the smallest recipients in mind
For more, please see the Statement Regarding Compliance with the
Coronavirus State and Local Fiscal Recovery Funds Interim Final Rule and Final Rule
U.S. Department of the Treasury
7
Four Key Eligible Use Categories
ARPA provides four major categories of eligible uses to tackle the broad range of public health
and economic challenges caused or exacerbated by the COVID-19 emergency.
• Providing government services up to the amount of revenue
Public Sector
1 Revenues
loss due to the pandemic
Public Health & • Responding to COVID-19’s public health impact, along with its
2 Economic Response economic harms
Premium Pay for • Offering additional support to workers who bear the greatest
3 Essential Workers health risks because of their service in critical sectors
Water, Sewer & • Providing funding to critical water and sewer projects, along
4 Broadband with high-speed broadband infrastructure
Infrastructure
Recipients have requested greater flexibility, simplicity & clarity in the final rule
to respond to new pandemic needs and make transformative investments
U.S. Department of the Treasury
8
Approach to the Final Rule
Treasury’s final rule provides greater flexibility and simplicity for recipients to turn the tide
on the pandemic, maintain vital public services amid revenue shortfalls, and build a strong,
resilient, and equitable recovery.
KEY NEW FEATURES IN THE FINAL RULE
• Major simplification for thousands of recipients through the
Public Sector
1 Revenues
$10 million revenue loss standard allowance
• Providing a broader set of eligible uses for impacted and
Public Health & disproportionately impacted populations
2 Economic Response • Clarifying that reasonably proportional capital expenditures may be
allowable (e.g., affordable housing, hospitals)
Premium Pay for • Streamlining options to provide premium pay by broadening
the share of essential workers who can receive premium pay
3 Essential
without a written justification
Workers
Water, Sewer & • Expanding water and sewer projects that are eligible
• Broadening eligible broadband investments to allow recipients to
4 Broadband
address access, affordability & reliability challenges
Infrastructure
U.S. Department of the Treasury
9
Replace Public Sector Revenue Loss 1 Public Sector
Revenues
Recipients may use these funds to provide government services, up to the amount of
revenue loss experienced due to the COVID-19 public health emergency.
1• Determine revenue loss, using one of two available options:
–
A Elect “standard allowance” of up to $10 million to spend on government services
through the life of the program, which greatly simplifies the program for small localities NEW
–
B Calculate actual revenue loss according to Treasury formula
» Calculate revenue loss either on a calendar or fiscal year basis NEW
» Must adjust actual revenue totals for the effect of tax cuts and tax increases that are
adopted after January 6, 2022, to more accurately reflect revenue loss due to the
pandemic NEW
2• Spend on government services up to the revenue loss amount
– Government services generally include any service traditionally provided by a
government unless Treasury has stated otherwise, such as:
✓ Construction of schools and ✓ Environmental remediation
hospitals ✓ Provision of police, fire, and other
✓ Road building and maintenance, public safety services (including
and other infrastructure purchase of fire trucks and police
✓ Health and other services vehicles)
U.S. Department of the Treasury
10
Restrictions on Use
The final rule maintains the IFR’s restrictions on use with additional clarifications.
• Final rule maintains IFR’s prohibition on states and localities for using
Net SLFRF funds to directly or indirectly offset reduction in net tax revenue
1 Reduction in resulting from a change in state or territory law, with additional
Tax Revenue technical clarifications
• Final Rule clarifies that the prohibition on “extraordinary
Deposits into contributions” to pension funds applies to all recipients except for
2 Pension Funds Tribal governments
• Final rule maintains that funds may not be used for debt service,
replenishing rainy day funds/financial reserves, or satisfaction of a
settlement or judgment
Other • Final rule clarifies additional restrictions that apply, including that:
3 Restrictions – Uses of funds may not undermine COVID-19 mitigation practices
on Use in line with CDC guidance and recommendations
– Uses of funds may not violate Uniform Guidance conflict-of-
interest requirements or other applicable laws
U.S. Department of the Treasury, Coronavirus State & Local Fiscal Recovery Funds
11
Compliance and Reporting Guidance Overview
On February 28th 2022, Treasury released the
updated Compliance and Reporting Guidance,
which builds on the final rule.
All SLFRF recipients are required to meet the
compliance and reporting responsibilities noted in
the final rule, including NEUs.
The Reporting Guidance is broken into two parts:
(1) General Guidance
(2) Reporting Requirements
12
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
13
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
14
Part 1: General Guidance
Recipient Compliance Overview
• Part 1A: Key Concepts
• Part 1B: Statutory Eligible Uses
• Part 1C: Treasury’s Final Rule
• Part 1D: Uniform Guidance (2 CFR part 200)
Requirements
• Part 1E: Award Terms & Conditions
16
Parts 1B and 1C: Statutory Eligible Uses and
Treasury’s Rulemaking
Part 1B: • SLFRF has four permitted statutory uses for award
Statutory Eligible Uses funds
• Identifies eligible and restricted uses for SLFRF
Part 1.C.1: funds
Eligible and Restricted Uses
• Eligible costs incurred between March 3, 2021,
Part 1.C.2: and December 31, 2024
Eligible Cost Timeframe • Funds obligated by December 31, 2024, and
expended by December 31, 2026
Part 1.C.3: • An annual or quarterly Project and
Reporting Requirements Expenditure Report, based on the aggregated
allocation the NEUs received
17
Part 2: Reporting for NEUs
NEU Reporting Requirements: Agreements and
Supporting Documents
• Copy of the signed award terms and conditions agreement
Required Docs • Copy of the signed assurances of compliance with Title VI of the
Civil Rights Act of 1964
• Copy of actual budget documents validating the top-line budget
total provided to the State or U.S. territory as part of the request
for funding
Frequency and • One-time collection
Deadline • Due by April 30, 2022validating the top-line budget total
provided to the State or U.S. territory as part of the request for
funding
19
Online System Access and Submission of NEU
Agreements/Documentation
• NEUs should access the Treasury Portal to:
• Confirm your accounts
• Designate the SLFRF reporting roles
• Submit the required agreements and supporting documentation
• An NEU User Guide is posted at www.treasury.gov/SLFRPReporting
• A recording is also posted in this link to assist NEUs. This link is accessible
from Treasury’s website: https://www.youtube.com/watch?v=3qd8tYYl0pg
20
NEU Reporting Requirements: Project and
Expenditure Report
• Types of projects funded
Contents • Programmatic data
• Financial data
• Information on subrecipients, subawards, and expenditures,
• By April 30, 2022, and
NEUs allocated more than $10 million then 30 days after the
(Tier 2) end of each quarter
Frequency & thereafter
Submission Date
• By April 30, 2022, and
NEUs allocated less than $10 million
then annually
(Tier 5
thereafter
21
Two Paths to Submitting a P&E Report
As an NEU, there are two ways to available to complete your Project and Expenditure
Report.
FAST AND SIMPLE STANDARD
OPTION 1 OPTION 2
Submitting ONLY Project(s) Submitting a Project(s)
under Expenditure Category under other Expenditure
6: Revenue Replacement Categories
Requirements (For April 2022): Requirements:
• Limited Project level reporting • Detailed Project level reporting
• No Subrecipient level reporting • Subrecipient level reporting may be
(for April) required
• No Subaward/Expenditure • Subaward/Expenditure reporting may
reporting (for April) be required
• Must still complete Recipient • Must complete Recipient Specific
Specific module module
Note: If your SLFRF allocation is over $10M you will need to pursue a mix of Option 1 and 2.
22
Submitting a P&E Report under Revenue
Replacement
All recipients will have the option to make a one-time decision to elect a “Standard
Allowance” of up to $10 million, not to exceed the award allocation.
STEP 1: Create a Project(s) aligned to EC 6.1 “Provision of Government Services”
• Ensure the Cumulative Obligations and Expenditures you are reporting are under
your allowed maximum.
STEP 2: Complete the Revenue Replacement fields in the “Recipient Specific” module.
• Choose whether to Elect the Standard Allowance or calculate your Estimated
Revenue Loss.
• Complete the required fields.
STEP 3: Certify and Submit!
23
Key Concept: Expenditure Category
Expenditure Categories (EC) categorize how funding is used and identifies where
additional programmatic data is required.
Appendix 1 of the Reporting Guidance includes a list of 83 Expenditure Categories.
24
Key Concept: 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
• Align to one Expenditure Category only.
• 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.
• Additional programmatic data may be required by project,
depending on the Expenditure Category selected
25
Key Concept: Relationships
Note: If you are only reporting
projects under EC 6.1, these
data points are not required
for April 2022 reporting.
26
Project and Expenditure Report
Project and Expenditure Reports include projects and contracts, grants, and subawards
over $50,000.
• Projects
• Obligations and Expenditures
Projects and
• Project Status
Expenditures • Project Demographic Distribution
• Civil Rights Compliance
• Subawards
Subawards • Expenditures related to Subawards
• Required Programmatic Data across multiple ECs
Program data • Required Programmatic Data for infrastructure
projects
27
Required Project Information
The following information will be required in Project and Expenditure Reports
for both quarterly and annual reporting.
• Project expenditure category and project specific information
• Obligations and expenditures
• Project status
• Any earned or expended program income, if applicable
• Any project capital expenditures (for non-infrastructure projects)
• Project Demographic Distribution (for certain ECs)
• Subawards, contracts, grants, loans, transfers, direct payments, and
expenditures
• Required programmatic data
28
P&E Treasury Submission Portal and Training
• Information will be submitted via Treasury’s Portal.
• Detailed updated user guide and reference materials, including recorded webinars,
will be provided with the release of the Project and Expenditure Report
functionality.
• Further communications will be posted on www.treasury.gov/SLFRPReporting
29
Q&A
SLFRF Resources
For More SLFRF Information:
Please visit Treasury’s State & Local website at
www.treasury.gov/SLFRP
Please visit Treasury’s website dedicated for NEUs.
Also view recorded webinars on the SLFRF Youtube page
For Reporting Information:
Please visit Treasury’s State & Local website at
www.treasury.gov/SLFRPReporting
For General Inquiries:
Please email SLFRP@treasury.gov
31
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