These past few weeks have been pretty action-packed when it comes to compliance requirements. As you know, the Treasury released their guidance on State and Local Fiscal Recovery Funds (SLFRF), and there have been FAQ updatesto the guidance for Non-Entitlement Units of Local Government (NEUs).
Last week, I had the privilege of speaking with several officials as I made my rounds in Washington D.C., and through these conversations, it became clear to me that there is a much more coordinated rollout of American Rescue Plan Act(ARPA) funding than there was with CARES funding in 2020. There are two major highlights that I took away from these conversations that I thought might be helpful for you to know.
First, Federal agencies have been working hand-in-hand with the Office of Management and Budget (OMB) on the internal guidance that is being rolled out for ARPA funding. With CARES funding, there were multiple revisions to agency guidance, and this ultimately caused a lot of problems for recipients and subrecipients when it came to maintaining compliance (particularly around audit requirements). Due to this early coordination with the OMB, there is much less likelihood that we will see the same amount of revisions to the guidance with ARPA funds.
Second, if you’ll remember, CARES Act funds were distributed in April of 2020, but audit guidance was not released until December of 2020 despite the funds needing to be spent by the end of December. ARPA funding is on a three-year timeline, which helps immensely when it comes to spending and reporting in general. Hopefully, the 2021 Single Audit Compliance Supplement will be published soon as well.
While we wait for the audit guidance, there is still a lot of information to sort through that can be overwhelming. We have a guide to the SLFRF reporting requirements, and a resource hub for ARPA funding to help you navigate your recovery. We want to hear from you as well. If there is advice you’re looking for when it comes to ARPA funding, or something that you think you could use more information on, don’t hesitate to reach out. Grants and compliance are complicated, and the past year and a half has been eventful, to say the least. We’re here to help however we can.