The Treasury released updates to version 2.1 of their Compliance and Reporting Guidance for State and Local Fiscal Recovery Funds (SLFRF) on November 15, 2021. The Guidance aims to provide resources and quick links to the Treasury’s expectations for recipient compliance responsibilities, best practices in relation to those responsibilities, and reporting requirements for the SLFRF program. ** See our SLFRF blog in June 2021 as background reference.**

All recipients of Federal funds must complete financial, performance, and  compliance reporting as required and outlined in Part 2 of the SLFRF guidance. SLFRF awards are generally subject to the requirements in the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards,  2 CFR Part 200  (UGG). The Guidance provides a general summary of compliance responsibilities, and all awardees are encouraged to also review the  2020 OMB Compliance Supplement Part 3. Compliance Requirements  (issued August 18, 2020).

Updates that may be beneficial for you to be aware of were made to the following:

  • Updated the Subrecipient Monitoring section to clarify beneficiaries and recipients 
  • Updated reporting tiers, thresholds and timelines in Part 2 Table 2, Reporting Requirements by Recipient Type, as well as Part 2 A and Part 2 B 
  • Updated reporting periods for both the Interim Report and the Project and Expenditure Report 
  • Added the Adopted Budget category to the Project and Expenditure Report data fields 
  • Removed certain data fields from the Ineligible Activities: Tax Offset Provision under the Recovery Plan Report 
  • Separated reporting of NEU Distributions (for States and territories) from the Interim Report and Project and Expenditure Reports > further information will be provided on an ongoing basis 
  • Updated pages 9 and 11 to note that civil rights certification is not applicable to Tribal Governments for the Project and Expenditure Report 

Most importantly, there have been updates to reporting requirements.

Updates have been made to the compliance requirements for the Interim Report (Section A, page 13), the Project and Expenditure Report (Section B, page 17-22), and the Recovery Plan Performance Report (Section C, page 22-29). We have taken a deeper dive into these reporting types and have created a  guide  to the updated Reporting Requirements for the Treasury’s  SLFRF.

We have even more resources pertaining to the American Rescue Plan Act (ARPA) and associated compliance requirements, and more information on State and Local Fiscal Recovery Funds in our Learning Hub for you.

Whether  you are trying to maximize the impact of your funding, finding ways to allocate your funding, or planning for  a more equitable future,  we’re here to help.   

 

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