AN INTRODUCTION TO THE

Coronavirus State and Local

Fiscal Recovery Funds

Compliance and Reporting Guidance

Non-entitlement Units of Local Government 

March 21, 2022
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Agenda

• Overview

• Part 1: General Guidance

• Part 2: Reporting Guidance 

• Q&A

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.
2

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
3

SLFRF Resources (2 of 2)

• Compliance and Reporting Guidance

https://home.treasury.gov/policy-issues/coronavirus/assistance-for-state-local-and-tribalgovernments/state-and-local-fiscal-recovery-funds/recipient-compliance-and-reportingresponsibilities

• 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-tribalgovernments/state-and-local-fiscal-recovery-fund/non-entitlement-units
Overview
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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.
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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
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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

U.S. Department of the Treasury

For more, please see the Statement Regarding Compliance with the 

Coronavirus State and Local Fiscal Recovery Funds Interim Final Rule and Final Rule 
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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 

loss due to the pandemic Public Sector 

Revenues

• Responding to COVID-19’s public health impact, along with its 

economic harms

Public Health & 

Economic Response

• Offering additional support to workers who bear the greatest 

health risks because of their service in critical sectors

Premium Pay for 

Essential Workers

• Providing funding to critical water and sewer projects, along 

with high-speed broadband infrastructure

Water, Sewer & 

Broadband 

Infrastructure

1

2

3

4

U.S. Department of the Treasury

Recipients have requested greater flexibility, simplicity & clarity in the final rule 

to respond to new pandemic needs and make transformative investments
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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 

$10 million revenue loss standard allowance Public Sector 

Revenues

• Providing a broader set of eligible uses for impacted and 

disproportionately impacted populations

• Clarifying that reasonably proportional capital expenditures may be 

allowable (e.g., affordable housing, hospitals)

Public Health & 

Economic Response

• Streamlining options to provide premium pay by broadening 

the share of essential workers who can receive premium pay 

without a written justification

Premium Pay for 

Essential

Workers

• Expanding water and sewer projects that are eligible

• Broadening eligible broadband investments to allow recipients to 

address access, affordability & reliability challenges 

Water, Sewer & 

Broadband 

Infrastructure

1

2

3

4

U.S. Department of the Treasury
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✓ Construction of schools and 

hospitals

✓ Road building and maintenance, 

and other infrastructure

✓ Health and other services 

✓ Environmental remediation

✓ Provision of police, fire, and other 

public safety services (including 

purchase of fire trucks and police 

vehicles)

Replace Public Sector Revenue Loss

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.

• Determine revenue loss, using one of two available options:

– 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

– Calculate actual revenue loss according to Treasury formula

» Calculate revenue loss either on a calendar or fiscal year basis

» 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 

• 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: 

1

2

U.S. Department of the Treasury

A

B

Public Sector 

Revenues

1

NEW

NEW

NEW
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Restrictions on Use

The final rule maintains the IFR’s restrictions on use with additional clarifications.

Net 

Reduction in 

Tax Revenue 

1

Deposits into 

Pension Funds 2

Other 

Restrictions

on Use

3

• Final rule maintains IFR’s prohibition on states and localities for using 

SLFRF funds to directly or indirectly offset reduction in net tax revenue 

resulting from a change in state or territory law, with additional 

technical clarifications

• Final Rule clarifies that the prohibition on “extraordinary 

contributions” to pension funds applies to all recipients except for 

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

• Final rule clarifies additional restrictions that apply, including that:

– Uses of funds may not undermine COVID-19 mitigation practices 

in line with CDC guidance and recommendations

– Uses of funds may not violate Uniform Guidance conflict-ofinterest requirements or other applicable laws

U.S. Department of the Treasury, Coronavirus State & Local Fiscal Recovery Funds
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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
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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

User Friendly: Provide as easy and efficient user experience as 

possible

Transparent: Provide the public data on how these funds were used 

and the outcomes achieved
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Focused on Recovery 

The Reporting Guidance addresses priority areas to ensure a speedy and equitable 

recovery. 

Equity Focused Community 

Empowering

Results and evidence 

focused Worker-Centered
Part 1: General Guidance 
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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
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Parts 1B and 1C: Statutory Eligible Uses and 

Treasury’s Rulemaking

• Identifies eligible and restricted uses for SLFRF 

funds

• Eligible costs incurred between March 3, 2021, 

and December 31, 2024

• Funds obligated by December 31, 2024, and 

expended by December 31, 2026

Part 1.C.1: 

Eligible and Restricted Uses

Part 1.C.2: 

Eligible Cost Timeframe

Part 1.C.3:

Reporting Requirements

• An annual or quarterly Project and 

Expenditure Report, based on the aggregated 

allocation the NEUs received 

Part 1B: 

Statutory Eligible Uses

• SLFRF has four permitted statutory uses for award 

funds 
Part 2: Reporting for NEUs
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NEU Reporting Requirements: Agreements and 

Supporting Documents 

Required Docs

• Copy of the signed award terms and conditions agreement

• 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 

Deadline

• One-time collection

• 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
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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
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NEU Reporting Requirements: Project and 

Expenditure Report

Contents

• Types of projects funded

• Programmatic data

• Financial data

• Information on subrecipients, subawards, and expenditures,

Frequency & 

Submission Date

NEUs allocated more than $10 million

(Tier 2)

NEUs allocated less than $10 million

(Tier 5

• By April 30, 2022, and 

then 30 days after the 

end of each quarter

thereafter

• By April 30, 2022, and 

then annually

thereafter
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Two Paths to Submitting a P&E Report

As an NEU, there are two ways to available to complete your Project and Expenditure 

Report. 

OPTION 1

Submitting ONLY Project(s) 

under Expenditure Category 

6: Revenue Replacement

OPTION 2

Submitting a Project(s) 

under other Expenditure 

Categories

FAST AND SIMPLE STANDARD

Requirements (For April 2022):

• Limited Project level reporting

• No Subrecipient level reporting 

(for April)

• No Subaward/Expenditure 

reporting (for April)

• Must still complete Recipient 

Specific module

Requirements:

• Detailed Project level reporting

• Subrecipient level reporting may be 

required

• Subaward/Expenditure reporting may 

be required

• Must complete Recipient Specific 

module

Note: If your SLFRF allocation is over $10M you will need to pursue a mix of Option 1 and 2. 
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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!
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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. 
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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
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Key Concept: Relationships

Note: If you are only reporting 

projects under EC 6.1, these 

data points are not required 

for April 2022 reporting.
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Project and Expenditure Report

Project and Expenditure Reports include projects and contracts, grants, and subawards 

over $50,000.

Projects and 

Expenditures

Subawards

Program data

• Projects

• Obligations and Expenditures

• Project Status

• Project Demographic Distribution

• Civil Rights Compliance

• Subawards

• Expenditures related to Subawards

• Required Programmatic Data across multiple ECs

• Required Programmatic Data for infrastructure 

projects
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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
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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
Q&A
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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