1

CORONAVIRUS LOCAL FISCAL RECOVERY FUND 

GUIDANCE ON COUNTIES THAT ARE NOT UNITS OF GENERAL LOCAL GOVERNMENT 

 

U.S. DEPARTMENT OF THE TREASURY 

 

JULY 30, 20211 

 

Section 603 of the Social Security Act (the Act), as added by the American Rescue Plan Act of 2021 (ARPA)

established the Coronavirus Local Fiscal Recovery Fund (CLFRF), which allocates $65.1 billion to counties 

and county equivalents. In general, these funds are to be paid directly from Treasury to eligible counties.

However, the ARPA further states that: 

In the case of an amount to be paid to a county that is not a unit of general local 

government, the amount shall instead be paid to the State in which such county is located, 

and such State shall distribute such amount to each unit of general local government within 

such county in an amount that bears the same proportion to the amount to be paid to such 

county as the population of such units of general local government bears to the total 

population of such county.2

On May 10, 2021, Treasury published allocation amounts for payments to county governments.3

 As part 

of that announcement, Treasury identified an initial list of counties that are not units of general local 

government (non-UGLG counties). Treasury is issuing the following guidance to provide an updated list of 

non-UGLG counties and assist States and territories with the distribution of funds to units of general local 

government that are located within non-UGLG counties. 

This guidance is organized into five sections: 

I. Identifying Non-UGLG Counties

II. Identifying Units of General Local Government Within Non-UGLG Counties

III. Allocating Funds

IV. Operations and Restrictions

V. Recordkeeping and Reporting for States and Recipients

I. Identifying Non-UGLG Counties 

As noted above, the CLFRF provides that, for each non-UGLG county, Treasury should pay the State in 

which such non-UGLG county is located for distribution by the State in accordance with the statute. For 

the purposes of CLFRF, the term “unit of general local government” is defined to have the same meaning 

as in section 102(a)(1) of the Housing and Community Development Act of 1974 (42 U.S.C. 5302(a)(1)). 

1 Please see page 8 for updates made since the July 30, 2021 publication date.

2 Section 603(b)(3)(B)(ii) of the Social Security Act, as amended by the ARPA. 3 https://home.treasury.gov/system/files/136/fiscalrecoveryfunds_countyfunding_2021.05.10-1a-508A.pdf. For more 

information on the allocation methodology for counties, see Coronavirus State and Local Fiscal Recovery Funds: Allocations to 

Counties, https://home.treasury.gov/system/files/136/Allocation-Methodology-for-Counties-508A.pdf.
2

Treasury has interpreted this definition, as applied to non-UGLGs, to refer to counties that are not 

general-purpose political subdivisions of a State.4

To determine which counties are not general purpose subdivisions of a State, Treasury analyzed public 

data for 2019 posted by the U.S. Census Bureau on the functional status of county and county-equivalent 

governments.

5

 Specifically, Treasury determined that a county was a non-UGLG county if it is classified by 

the U.S. Census Bureau as either:

• A nonfunctioning legal entity; or

• A statistical entity. 

Based on this approach, 32 counties can be classified as non-UGLG counties.6 Treasury has conducted a

further review in the case of the specific circumstance in which counties are not classified as either 

nonfunctioning nor as statistical entities but are described by the Census Bureau’s Census of 

Governments as having “limited” authorities.7

 Based on this review, Treasury identified Vermont’s 14 

counties as non-UGLG counties based on the very limited extent of their authority under state law. As 

summarized by the Census of Governments, Vermont’s counties “perform very limited functions, which 

consist chiefly of maintaining the courthouse and county jail.”8

 As Treasury understands the term general 

purpose political subdivision to refer to a political subdivision such as a county that has a broad array of 

functions, such as providing a broad array of services, it would not be appropriate to classify Vermont’s 

counties as units of general local government given the extent of their functions. 

Because U.S. territories are not included in the 2019 Census data referenced above, for U.S. territories, 

Treasury reviewed a separate Census dataset, the 2020 TIGER/Line Shapefiles data for counties and 

4 As section 603(b)(3)(B)(ii) of the Act applies in the case of a “county that is not a unit of general local government,” read

literally, this provision would mean that Treasury may not make a payment to a county that is not a county. Under this reading, 

every county would satisfy the UGLG definition, and all counties would receive a payment. To avoid a reading that would 

deprive this clause of meaning, Treasury believes that the clause should be read as intending to apply to any city, county, town, 

township, parish or village that is a general purpose political subdivision and any other local government that also constitutes a

general purpose political subdivision of a State or territory. This reading is supported by the use of the word “other” in the last 

clause suggesting that the preceding list of governmental organizations must be “general purpose political subdivision[s].” The 

Act incorporates the term “unit of general local government” from the Housing and Community Development Act of 1974, but 

the latter does not define “general purpose political subdivision of a state.” A plain meaning of “general purpose” is having 

various purposes rather than a specific purpose. As applied more specifically to ARPA, Treasury understands “general purpose

political subdivision” to refer to a political subdivision such as a county that has a broad array of functions, such as providing a 

broad array of services. This interpretation gives meaning to this provision and is consistent with the intent of Congress to 

provide payments to counties, as general-purpose political subdivisions, that have the ability to accept and expend funds. 5 The data Treasury used to identify non-UGLG counties is available at: https://www2.census.gov/programssurveys/popest/datasets/2010-2019/cities/totals/sub-est2019_all.csv. For more information on the functional status of 

geographic entities in the Census data, see: https://www.census.gov/library/reference/code-lists/functional-status-codes.html. 6 On May 10, 2021, Treasury published an initial list of non-UGLG counties that designated Kalawao County, Hawaii as a nonUGLG county. Kalawao County is classified by the U.S. Census Bureau as an “active government that is subordinate to another 

unit of government” (see note 5 for data sources). Under state law, Kalawao County “is constituted a county by itself” and 

“shall be under the jurisdiction and control of the department of health and be governed by the laws, and rules relating to the 

department and the care and treatment of persons affected with Hansen's disease, except as otherwise provided by law” (HAW.

REV. STAT. § 326-31, available at https://www.capitol.hawaii.gov/hrscurrent/vol06_ch0321-0344/hrs0326/hrs_0326-0034.htm). 

Because the county is under the jurisdiction of the Hawaii Department of Health, Treasury will coordinate with that Department 

regarding payment of the county’s $16,704 allocation and monitoring of the use of funds in accordance with CLFRF program 

rules. 

7 See https://www.census.gov/content/dam/Census/library/publications/2017/econ/2017isd.pdf. 8 Census of Governments at 280. 
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county equivalents.

9

 This dataset includes functional status codes which allow Treasury to identify 

counties that are nonfunctioning legal entities within U.S. territories. Based on this approach, Treasury is 

identifying five additional county-equivalents located in U.S. territories as non-UGLG counties. 

The updated list of non-UGLG counties identified by Treasury and the allocations to those counties are 

provided in the Appendix. 

II. Identifying Units of General Local Government Within Non-UGLG Counties 

 

For the purposes of CLFRF, the term “unit of general local government” is defined to have the same 

meaning as in section 102(a)(1) of the Housing and Community Development Act of 1974 (42 U.S.C. 

5302(a)(1)). Treasury analyzed the CLFRF definitions of “unit of general local government” and 

“nonentitlement unit of local government,” consistent with the approach discussed in Treasury’s 

Nonentitlement Unit of Local Government Definitional and Data Methodology.

10 Treasury has determined

that the units of general local government in non-UGLG counties eligible to receive a distribution by the 

State are:

• Metropolitan cities that are eligible to receive funds under CLFRF;

11 and

• Non-entitlement units of local government (NEUs) that are eligible to receive funds under CLFRF, 

in accordance with the Guidance on Distribution of Funds to Non-Entitlement Units of Local 

Government.

12

States should use the list of eligible metropolitan cities plus their own lists of NEUs receiving funds to 

develop lists of units of general local government within each non-UGLG county. 

U.S. territories should identify NEUs within non-UGLG counties in a manner consistent with the guidance 

specified in FAQ 7.8 of the Frequently Asked Questions on Distribution of Funds to Non-entitlement Units 

of Local Government.

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III. Allocating Funds 

 

Once a State has developed a list of units of general local government within each non-UGLG county, it 

should allocate funds to the units of general local government based on their population share of the 

non-UGLG county’s population. Specifically, under this guidance, a unit of general local government’s 

total allocation will equal:

PPPPPPPPPPPPPPPPPPPP oo hee oo gg gg ll gg gg gg gg

PPPPPPPPPPPPPPPPPPPP oo hee -UUUUUUUU cc

× -UUUUUUUU cc

 

If a unit of general local government spans multiple counties, a State should consider only the portion of 

the population that falls within the non-UGLG county for the purpose of applying the formula above. In

some States, the boundaries of some units of general local government overlap with or encompass other 

9 For additional information on the dataset, see: https://www.census.gov/geographies/mapping-files/time-series/geo/tigerline-file.html. To access the data set, see: https://www.census.gov/cgi-bin/geo/shapefiles/index.php (select ‘Counties (and 

equivalent)’ from drop-down). 10 https://home.treasury.gov/system/files/136/NEU_Methodology.pdf 11 https://home.treasury.gov/system/files/136/fiscalrecoveryfunds-metrocitiesfunding1-508A.pdf 12 https://home.treasury.gov/system/files/136/NEU_Guidance.pdf 13 https://home.treasury.gov/system/files/136/NEU-FAQs.pdf
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units of general local government within the State, typically resulting in overlapping populations between 

the larger “parent” unit and the subsidiary unit. An example is a township that encompasses a city. If a 

State has overlapping units of general local government within a non-UGLG county, States should 

determine the population of these units in a manner consistent with the approach described in the 

Guidance on Distribution of Funds to Non-Entitlement Units of Local Government.

14 

A State may adjust allocations within a particular non-UGLG county on a pro rata basis to ensure that all 

available funds are distributed to units of general local government within a given non-UGLG county. 

Consistent with section 603(b)(6) of the Act, for the purpose of determining populations to calculate

allocations to units of general local government within non-UGLG counties, States should use “the most 

recent data [that] are available from the Bureau of the Census or, if not available, from such other data as 

a State determines appropriate.” For non-UGLGs in States, States receiving funds should use the U.S. 

Census Bureau’s City and Town Population Subcounty Resident Population Estimates file from the 2019 

Vintage.

15 Each territory should use the population data it deems most appropriate, consistent with the 

guidance specified in FAQ 7.8 of the Frequently Asked Questions on Distribution of Funds to Nonentitlement Units of Local Government.

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IV. Operations and Restrictions 

 

A State’s submission of a request for payment from the Coronavirus State Fiscal Recovery Fund (CSFRF) 

under section 602 of the Act will suffice for Treasury to initiate payment to the State from the CLFRF for 

distribution to the units of general local government within non-UGLG counties. Payment of this amount 

will be made to the bank account designated by the State with respect to the CSFRF.

Treasury expects to begin paying the non-UGLG county allocations to States in the days following the 

publication of this guidance or a State’s submission of a request for payment under section 602, 

whichever occurs later. Consistent with section 603(b)(7), the payment of these funds to States will occur 

in two equal tranches, with the second tranche paid no earlier than 12 months after the date on which 

the first tranche is paid. A State’s distribution of these funds to units of general local government within 

non-UGLG counties should also occur in two equal tranches. 

Once a State receives a payment for distribution to units of general local government within non-UGLG 

counties, it should calculate the allocations to those units of general local government within 60 days. 

Once a State has calculated the allocations, payments to units of general local government should 

proceed as follows: 

• For units of general local government that are NEUs under CLFRF: In order to receive funds 

under section 603(b)(3)(B)(ii) of the Act, an NEU must be eligible to receive funds under section 

603(b)(2) of the Act, as implemented by the Guidance on Distribution of Funds to NonEntitlement Units of Local Government.

17 States should begin making the section 603(b)(3)(B)(ii) 

payments to NEUs as soon as practicable after NEUs have accepted the award terms and 

conditions described in the Guidance on Distribution of Funds to Non-Entitlement Units of Local 

14 See note 12. 15 https://www2.census.gov/programs-surveys/popest/datasets/2010-2019/cities/totals/sub-est2019_all.csv 16 See note 13. 17 See note 12. 
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Government. NEUs receiving funds under section 603(b)(3)(B)(ii) are bound by the same terms 

and conditions that apply to section 603(b)(2) payments, as described in the Guidance on 

Distribution of Funds to Non-Entitlement Units of Local Government, and States should make 

payments using the same financial institution information that was collected and verified in the 

first tranche distribution process described in the Guidance on Distribution of Funds to NonEntitlement Units of Local Government. 

• For units of general local government that are metropolitan cities under CLFRF: In order to 

receive funds under section 603(b)(3)(B)(ii) of the Act, a metropolitan city must have received 

funds under section 603(b)(1) of the Act. Metropolitan cities receiving funds under section 

603(b)(3)(B)(ii) are bound by the same terms and conditions that apply to the section 603(b)(1) 

payments. Treasury expects to provide notification to States when metropolitan cities in nonUGLG counties have accepted the terms and conditions and received section 603(b)(1) payment.

Prior to initiating payment to metropolitan cities under section 603(b)(3)(B)(ii), States should 

collect and verify the following information: 

o Local government name, Entity’s Taxpayer Identification Number, DUNS number, and

address

o Authorized representative name, title, and email

o Contact person name, title, phone, and email

o Financial institution information (e.g., routing and account number, financial institution

name and contact information)

For States making payments to units of general local government, Treasury encourages States to 

implement best practices, and recommends ongoing consultation with relevant state agencies, such as 

the state auditor’s office, on ways to proactively prevent, detect, and respond to threats to program 

integrity. State partners should also consult resources available from the federal government.18 Treasury 

expects states to fulfill their legal obligation under the statute and Treasury’s implementing regulations 

and guidance to issue accurate and proper payments to units of general local government. 

States may not place additional conditions or requirements on distributions to units of general local 

government within non-UGLG counties, beyond those required by the Act and Treasury’s implementing 

regulations and guidance.

 

V. Recordkeeping and Reporting for States and Recipients 

 

States should keep records regarding the lists of units of general local government within non-UGLG 

counties; the allocations to those units of general local government, including the population data used 

to calculate the allocations; and the payments made to those units of general local government. 

As stated above, metropolitan cities and NEUs receiving funds disbursed to units of general local 

government within non-UGLG counties are subject to all restrictions and compliance and reporting 

obligations applicable to other prime recipients that receive CLFRF allocations and disbursements, 

18 Examples of available resources include the United States Chief Financial Officers Council’s Program Integrity: The Antifraud 

Playbook, which provides an overview of practical and actionable guidance to reduce fraud risk, and the Government 

Accountability Office’s Standards for Internal Control in the Federal Government (“Green Book”).
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including those described in the award terms,19 Interim Final Rule20 and the Compliance and Reporting 

Guidance.

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The following subsections describe the reporting obligations for: (A) states acting as pass-through entities 

for section 603(b)(3)(B)(ii) payments; and (B) the recipients of section 603(b)(3)(B)(ii) payments.

A. State Reporting on section 603(b)(3)(B)(ii) Payments

Relevant States must provide information about all section 603(b)(3)(B)(ii) payments in the 

quarterly Project and Expenditure Report immediately following such payments. Note that, 

like the CLFRF payments to counties, the section 603(b)(3)(B)(ii) payments will occur in two 

tranches such that States must furnish section 603(b)(3)(B)(ii) payments data more than 

once.

Treasury will provide a template to report information on payments to units of general local 

government within non-UGLG counties in a forthcoming user guide. This will resemble the 

process for NEU distributions in the Interim Report as described in Part 2, Section A.1.b. of 

the Compliance and Reporting Guidance. 

B. Reporting Obligations for Units of Government Receiving Section 603(b)(3)(B)(ii) Payments

Generally, the reporting obligations for a recipient of a section 603(b)(3)(B)(ii) payment are 

determined according to the reporting tiers included in Part 2 of the Compliance and 

Reporting Guidance. It is important to note that if a recipient receives both non-UGLG and 

direct payment of funds, then it must prepare and submit consolidated reports covering 

combined program funds and data collection.

In addition, a section 603(b)(3)(B)(ii) payment recipient’s status as either an NEU or a 

metropolitan city will ultimately determine its reporting obligations to Treasury as a prime 

recipient. Metropolitan cities also have varying reporting obligations based on population 

size and the total amount of CLFRF funding received. The following subsections describe the 

different reporting requirements for each type of section 603(b)(3)(B)(ii) payment recipient.

i. Non-Entitlement Units of Local Government

Any recipient of a section 603(b)(3)(B)(ii) payment that is an NEU retains the same 

reporting requirements as other NEUs described in Part 2 of the Compliance and 

Reporting Guidance. Note that each annual Project & Expenditure report must cover 

the combined funding received under the program including non-UGLG and other 

payments, as necessary.

For example, if an NEU received an allocation of $250,000 under the Guidance on 

Distribution of Funds to Non-Entitlement Units of Local Government and a section 

19 https://home.treasury.gov/system/files/136/NEU_Award_Terms_and_Conditions.pdf 20 https://www.govinfo.gov/content/pkg/FR-2021-05-17/pdf/2021-10283.pdf 21 https://home.treasury.gov/system/files/136/SLFRF-Compliance-and-Reporting-Guidance.pdf
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603(b)(3)(B)(ii) payment of $120,000, then the NEU will report on $370,000 of 

funding in its annual Project and Expenditure report.

ii. Metropolitan Cities

Metropolitan cities must also report on the combined total of all funding received 

under the program – including both the section 603(b)(3)(B)(ii) and other payments –

according to the reporting tiers included in Part 2 of the Compliance and Reporting 

Guidance. For example, if a metropolitan city received $3 million of program funding 

and an additional $1 million as a section 603(b)(3)(B)(ii) payment, then it would 

provide a combined report covering $4 million of total program funding.

In addition, any recipient of a section 603(b)(3)(B)(ii) payment that is a metropolitan 

city with a population greater than 250,000 residents will have the same obligations 

to provide Interim, Recovery Plan, and Project and Expenditure reports to Treasury as 

other qualifying cities.

Metropolitan cities with less than 250,000 residents must provide Interim and Project 

and Expenditure reports, but are not required to provide a Recovery Plan. The 

frequency of the Project and Expenditure reporting depends on whether the 

recipient’s total CLFRF funding exceeds $5 million.

Accordingly, when a metropolitan city receives (a) a direct payment from Treasury; 

and (b) a section 603(b)(3)(B)(ii) payment from the State, the $5 million threshold will 

apply to the sum of the two payments. For example, if City B has a population of 

220,000 residents and receives a direct $4 million allocation from Treasury and then 

subsequently receives a section 603(b)(3)(B)(ii) payment of $1.5 million, then City B 

must report on $5.5 million of program funding as a metropolitan city with less than 

250,000 residents and funding exceeding the $5 million threshold for reporting 

purposes. 

For more information on recipient reporting obligations, please refer to “Table 2: Reporting requirements 

by recipient type” on page 12 of the Compliance and Reporting Guidance. 
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Updates 

• October 21, 2021: Based on further analysis of governmental functions in American Samoa, 

Treasury is identifying three additional county-equivalents in American Samoa as non-UGLG 

counties. These three county-equivalents in American Samoa are: Eastern District, Manu'a 

District, and Western District. Allocations to these counties are given in the Appendix. 

 

As outlined above, the special payment rule in section 603(b)(3)(B)(ii) requires Treasury to make 

payments to the UGLGs within the non-UGLG counties. Since American Samoa does not have 

UGLGs within these counties, it is necessary to reallocate these funds under the pro rata 

adjustment authority in section 603(b)(5) to the territory. Therefore, the American Samoa 

government may receive funds previously allocated to non-UGLG counties and expend those 

funds in accordance with program requirements. 

Additionally, since the U.S. Virgin Islands also does not have UGLGs within non-UGLG counties, 

the territory may receive funds previously allocated to non-UGLG counties and expend those 

funds in accordance with program requirements.

 
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Appendix: List of Non-UGLG Counties 

State County or county-equivalent Allocation

Alaska Aleutians West Census Area $1,094,338

Alaska Bethel Census Area $3,571,265

Alaska Dillingham Census Area $954,875

Alaska Hoonah-Angoon Census Area $417,224

Alaska Kusilvak Census Area $1,614,897

Alaska Nome Census Area $1,943,160

Alaska Prince of Wales-Hyder Census Area $1,204,860

Alaska Southeast Fairbanks Census Area $1,338,884

Alaska Valdez-Cordova Census Area $1,787,381

Alaska Yukon-Koyukuk Census Area $1,015,866

Connecticut Fairfield County $183,231,182

Connecticut Hartford County $173,206,156

Connecticut Litchfield County $35,027,571

Connecticut Middlesex County $31,551,289

Connecticut New Haven County $166,026,527

Connecticut New London County $51,513,156

Connecticut Tolland County $29,275,787

Connecticut Windham County $22,683,534

Massachusetts Berkshire County $24,268,907

Massachusetts Essex County $153,260,605

Massachusetts Franklin County $13,631,642

Massachusetts Hampden County $90,587,294

Massachusetts Hampshire County $31,239,342

Massachusetts Middlesex County $313,053,637

Massachusetts Nantucket County $2,214,122

Massachusetts Suffolk County $156,149,511

Massachusetts Worcester County $161,338,586

Rhode Island Bristol County $9,416,477

Rhode Island Kent County $31,911,795

Rhode Island Newport County $15,943,466

Rhode Island Providence County $124,104,857

Rhode Island Washington County $24,391,860

Vermont Addison County $7,143,501

Vermont Bennington County $6,889,632

Vermont Caledonia County $5,825,789

Vermont Chittenden County $31,811,180

Vermont Essex County $1,197,091

Vermont Franklin County $9,595,759

Vermont Grand Isle County $1,405,314
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Vermont Lamoille County $4,926,271

Vermont Orange County $5,611,932

Vermont Orleans County $5,251,620

Vermont Rutland County $11,302,920

Vermont Washington County $11,345,264

Vermont Windham County $8,201,129

Vermont Windsor County $10,695,148

Virgin Islands St. Croix Island $9,828,651

Virgin Islands St. John Island $809,974

Virgin Islands St. Thomas Island $10,029,299

American Samoa Rose Island $0

American Samoa Swains Island $3,302

Added October 21, 2021:

American Samoa Eastern District $4,473,308

American Samoa Manu'a District $222,014

American Samoa Western District $6,085,291