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September 2023
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Table of Contents

Part 1: Introduction.................................................................................................................. 1

Part 2: Reporting Requirements ............................................................................................. 3

A. Project and Expenditure Report ............................................................................... 4

B. Performance Report ............................................................................................... 10

Part 3: General Guidance ..................................................................................................... 13

A. Compliance Requirements ..................................................................................... 13

B. Uniform Administrative Requirements .................................................................... 13

Appendix 1: Definitions ......................................................................................................... 17
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Coronavirus Capital Projects Fund

Compliance and Reporting Guidance

For States, Territories, and Freely Associated States

Part 1: Introduction 

On March 11, 2021, the American Rescue Plan Act was signed into law, establishing the 

Coronavirus Capital Projects Fund (Capital Projects Fund or CPF) Program. CPF is 

administered by the U.S. Department of the Treasury (Treasury) and provides grants to States,

territories, freely associated states, and Tribal governments to carry out critical Capital Projects

directly enabling work, education, and health monitoring, including remote options, in response 

to the public health emergency with respect to the Coronavirus Disease (COVID-19). 

This guidance provides additional detail and clarification about reporting and compliance 

responsibilities for States, territories, and freely associated states under the CPF Program, and 

should be read in concert with the following documents: 

• Capital Projects Fund Statute;

• Capital Projects Fund Guidance for States, Territories, and Freely Associated States

(Capital Projects Fund Guidance);

• Grant Agreement;

• Frequently Asked Questions (FAQs);

• Assistance Listing in SAM.gov under Assistance Listing number (formerly known as 

CFDA number), 21.029; 

• SLFRF and CPF Supplementary Broadband Guidance; and

• Other regulatory and statutory requirements, including regulatory requirements under the

Uniform Guidance (2 CFR Part 200).

This guidance is not applicable to Tribal governments. Tribal Recipients should instead refer to 

the Tribal Government Reporting Guidance on the CPF website. 

Recipients are responsible for reporting on approved Program Plans and the associated 

Projects. A “Program” means one or more Capital Projects with common characteristics (e.g., a 

group of Multi-Purpose Community Facility Projects that directly enable work, education, and 

health monitoring). 

Recipients are responsible for monitoring and overseeing Subrecipients’ use of funds and other 

activities related to the award to ensure that Subrecipients comply with the applicable statutory 

and regulatory requirements, and the terms and conditions of the award pursuant to 2 CFR 

200.332. 

In addition to reporting to Treasury, CPF Recipients are responsible for reporting on subawards 

in the Federal Subaward Reporting System (FSRS) and reporting executive compensation 
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information in SAM.gov pursuant to 2 CFR Part 170, Appendix A, Award Term, which is 

incorporated by reference in the Grant Agreement. Recipients must maintain an active 

SAM.gov registration for the duration of their CPF award pursuant to 2 CFR 25.200(b)(2).
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Part 2: Reporting Requirements 

There are two types of reporting requirements for the CPF Program. 

• Project and Expenditure Report (P&E): A quarterly report to provide information on 

Projects funded, obligations, expenditures, project status, outputs, performance indicators, 

and other information. See Section A, page 3. 

• Performance Report: An annual report to provide information on CPF-funded Programs 

and to describe the outputs and outcomes of Programs. See Section B, page 9.

Reporting will be due according to the schedule below, which may be modified by Treasury with 

prior notice to Recipients. 

All reporting must be submitted through Treasury’s Reporting Portal. Table 1 shows the 

reporting requirements for States, territories, and freely associated states.

Table 1: Report Timelines

Report Report Type Period Covered Due Date

1

† P&E 

Q0,1,2,3

All Costs Incurred Until September 30, 

2022 (Including Pre-Award Costs)

October 31, 

2022†

2 P&E Q4 October 1, 2022 – December 31, 2022 January 31, 2023

3 P&E Q1 January 1, 2023 – March 31, 2023 April 30, 2023

4 P&E Q2 April 1, 2023 – June 30, 2023 July 31, 2023

P1 Performance All Performance Until June 30, 2023 July 31, 2023

5 P&E Q3 July 1, 2023 – September 30, 2023 October 31, 

2023††

6 P&E Q4 October 1, 2023 – December 31, 2023 January 31, 2024

7 P&E Q1 January 1, 2024 – March 31, 2024 April 30, 2024

8 P&E Q2 April 1, 2024 – June 30, 2024 July 31, 2024

P2 Performance July 1, 2023 - June 30, 2024 July 31, 2024

9 P&E Q3 July 1, 2024 – September 30, 2024 October 31, 2024

10 P&E Q4 October 1, 2024 – December 31, 2024 January 31, 2025

11 P&E Q1 January 1, 2025 – March 31, 2025 April 30, 2025

12 P&E Q2 April 1, 2025 – June 30, 2025 July 31, 2025

P3 Performance July 1, 2024 - June 30, 2025 July 31, 2025

13 P&E Q3 July 1, 2025 – September 30, 2025 October 31, 2025

14 P&E Q4 October 1, 2025 – December 31, 2025 January 31, 2026

15 P&E Q1 January 1, 2026 – March 31, 2026 April 30, 2026

16 P&E Q2 April 1, 2026 – June 30, 2026 July 31, 2026

P4 Performance July 1, 2025 - June 30, 2026 July 31, 2026

17 P&E Q3 July 1, 2026 – September 30, 2026 October 31, 2026

18 P&E Q4 October 1, 2026 – December 31, 2026 March 31, 2027

P5 Performance July 1, 2026 - December 31, 2026 March 31, 2027

The remainder of this document describes these reporting requirements. A User Guide

describing how and where to submit required reports, among other information, is posted on the 

† Recipients that have not received an initial CPF payment (either payments for Administrative Costs or 

Project Costs) on or before September 15, 2022, are exempted from Report 1.

†† All Recipients should submit reports no later than October 31, 2023 (Report 5). 
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CPF Recipient Compliance and Reporting Responsibilities webpage, and will be updated on a 

periodic basis.

A. Project and Expenditure Report 

States, territories, and freely associated states are required to submit Project and Expenditure 

Reports on a quarterly basis according to the due dates noted in Table 1. A Project and 

Expenditure Report must be completed for each Project included in an approved Program Plan, 

beginning after a Project has been selected and a subaward has been executed (if applicable). 

Project and Expenditure Reports will be due each quarter thereafter for the remainder of the 

period of performance to continue to collect performance data. Additionally, to provide public 

transparency, Treasury will seek information from Recipients regarding their plans and practices 

related to promoting on-time and on-budget delivery related to CPF Projects. 

Following the initial report, all Project and Expenditure Reports will cover one three-month

period and must be submitted to Treasury within 30 calendar days after the end of each period, 

except for the final report, which is due 120 calendar days after the end of the period of 

performance.1 Treasury may provide additional closeout instructions prior to the end of the 

period of performance. 

The User Guide published by Treasury includes definitions for data elements, information about 

how frequently each data element should be submitted, processes to be followed when 

collecting data, templates for data submission, and further instructions as to how to submit 

required data and reports.

The following information must be submitted with respect to the use of CPF funds during the 

period covered in Project and Expenditure Reports:

a. Administrative Expenses

• Current period obligation

• Cumulative obligation

• Current period expenditure

• Cumulative expenditure

Pursuant to the Grant Agreement, Recipients are permitted to charge both direct and 

indirect costs to their CPF award as Program Administrative Costs. If a Recipient has a 

current Negotiated Indirect Costs Rate Agreement (“NICRA”), then the Recipient may use its 

current NICRA to charge indirect costs to its CPF award. However, if the Recipient does not 

have a current NICRA, the Recipient may elect to use the de minimis rate of 10 percent of 

the modified total direct costs to charge indirect costs to its CPF award pursuant to 2 CFR 

200.414(f). Note that Administrative Expenses do not need to be broken down at the 

Project level, and instead should be reported in the aggregate. Recipients should refer to 

the Capital Projects Fund Guidance for more information about requirements for the use of 

Administrative Funds.

b. Program Budget Updates

Recipients must revise and submit each Program Plan budget no less frequently than once 

every twelve months.

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 Each Program budget should be provided in the form of a table with 

a project costs section and a program administrative costs section, and columns for each 

year in the period of performance. Past years should be updated to show actual obligations

and expenditures. Remaining years should be updated to reflect accurate budget 

1 For additional information on final reports, see 2 C.F.R. 200.344(a) and (b).

2 Program budget update due dates to be specified in the user guide.
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projections. Table rows should align with the Program budgets previously established in the 

Recipient’s Program Plans, with rows added and removed as needed. Recipients are 

required to explain any major changes compared to the prior submitted budget, including 

deviations from budget, program scope, or objective. Program budget instructions can be 

found in the use type Program Plan Questionnaires on the CPF website. 

The following information will be required in Project and Expenditure Reports for each Project:

1. Project Information: For each Project, the Recipient will provide:

• Project name

• Identification number (created by the Recipient)

• Corresponding approved Program Plan number (designated by Treasury)

• Project use code

• A brief description with sufficient detail to provide understanding of the objective(s) 

and major activities that will occur throughout the Project

• Type of owner for the capital asset (such as private, public private partnership, 

government, co-operative, etc.).

• For each subrecipient, as applicable:

o Name

o Contact information

o Tax ID number (TIN)

o Unique Entity Identifier

o Date of award 

o Total award amount

• Start date for construction (Planned/Actual) (if applicable)

• Date for completion of construction (Planned/Actual) (if applicable) 

• Date of the initiation of operations (Planned/Actual) 

Throughout the Project, the Recipient will be accountable for the accuracy of this information 

and for reflecting any changes, as is applicable, in each Project and Expenditure Report

submission.

If applicable, the Recipient will also be required to answer the following questions regarding 

additional sources of funding being used for the Project:

• Is CPF funding used in conjunction with other federal funding for the Project? (Y/N)

• If “Y”:

▪ Provide the Program Name and Assistance Listing number of the other program(s) 

providing federal funding

▪ Provide the amount of the other federal funding obligated (by Assistance Listing)

▪ Is the other federal funding subject to the requirements of the Davis-Bacon Act?

(Y/N)

2. Obligations and Expenditures: For each Project, the Recipient will report:

• Current period obligation

• Cumulative obligation

• Current period expenditure

• Cumulative expenditure

• A brief description of the major activities on which funds were expended during the 

reporting period, including costs related to community engagement and any other 

Ancillary Costs
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Treasury needs certain project-level budget information to assess overall adherence to 

project cost and schedule and to evaluate performance outcomes. In addition to Program 

Plan information, Recipients must report the following budget information for each Project: 

• Total amount of CPF funding budgeted for the project

• Total amount budgeted for the project from all funding sources, including but not 

limited to non-CPF federal funding sources, and private funding sources 

3. Project Status: The Recipient will be asked to report on project status each reporting 

period, in four categories:

• Not Started

• Completed less than 50 percent

• Completed 50 percent or more

• Completed

4. Special Statutory Matching Funds Requirements: CPF funds may be used as a State’s 

non-federal share (also known as “matching funds”) for certain other federal programs as 

specifically permitted under statute. Recipients using CPF funds as non-federal share funds 

for other federal programs will be asked to report on the following: 

• Provide the Program Name and Assistance Listing of the other federal program that is 

being matched, as well as the statutory citation permitting CPF funds to be used as 

non-federal matching funds 

• Provide the total amount of CPF funds being used as matching funds

• Provide a brief description of the project, including the total anticipated costs for the 

project from all funding sources

5. Labor: For Projects receiving $ 5 million or more in CPF funding (based on expected total 

cost):

a. A recipient may provide a certification that, for the relevant Project, all laborers and 

mechanics employed by contractors and subcontractors in the performance of such 

Project are paid wages at rates not less than those prevailing, as determined by the 

U.S. Secretary of Labor in accordance with subchapter IV of chapter 31 of title 40, 

United States Code (commonly known as the “Davis-Bacon Act”), for the 

corresponding classes of laborers and mechanics employed on projects of a character 

similar to the contract work in the civil subdivision of the State (or the District of 

Columbia) in which the work is to be performed, or by the appropriate State entity 

pursuant to a corollary State prevailing-wage-in-construction law (commonly known as 

“baby Davis-Bacon Acts”). If such certification is not provided, a Recipient must 

provide a project employment and local impact report detailing: 

• The number of contractors and sub-contractors working on the Project;

• The number of employees on the Project hired directly and hired through a 

third party;

• The wages and benefits of workers on the Project by classification; and

• Whether those wages are at rates less than those prevailing.3

3 As determined by the U.S. Secretary of Labor in accordance with subchapter IV of chapter 31 of title 40, 

United States Code (commonly known as the “Davis-Bacon Act”), for the corresponding classes of 

laborers and mechanics employed on projects of a character similar to the contract work in the civil 

subdivision of the State (or the District of Columbia) in which the work is to be performed.
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Recipients must maintain sufficient records to substantiate this information upon 

request. 

b. A recipient may provide a certification that a Project includes a project labor 

agreement, meaning a pre-hire collective bargaining agreement consistent with section 

8(f) of the National Labor Relations Act (29 U.S.C. 158(f)). If the Recipient does not 

provide such certification, the Recipient must provide a project workforce continuity 

plan, detailing:

• How the Recipient will ensure the Project has ready access to a sufficient 

supply of appropriately skilled and unskilled labor to ensure high-quality 

construction throughout the life of the Project, including a description of any 

required professional certifications and/or in-house training, registered 

apprenticeships or labor-management partnership training programs, and 

partnerships like unions, community colleges, or community-based groups;

• How the Recipient will minimize risks of labor disputes and disruptions that 

would jeopardize timeliness and cost-effectiveness of the Project; 

• How the Recipient will provide a safe and healthy workplace that avoids delays 

and costs associated with workplace illnesses, injuries, and fatalities, including 

descriptions of safety training, certification, and/or licensure requirements for all 

relevant workers (e.g., OSHA 10, OSHA 30);

• Whether workers on the Project will receive wages and benefits that will secure 

an appropriately skilled workforce in the context of the local or regional labor 

market; and 

• Whether the Project has completed a project labor agreement. 

c. Whether the Project prioritizes local hires. 

d. Whether the Project has a Community Benefit Agreement. Recipient must provide a 

description of any such agreement. 

6. Required Performance Indicators and Project Data: Recipients will be required to provide 

project-level information according to the project use code of the corresponding approved 

Program Plan. 

The following programmatic data is required for each corresponding project use code. Note 

that not all data elements will be required in each quarterly Project and Expenditure Report 

and that the frequency of submission will vary depending on the data element, the project 

status, and other components, to be described in greater detail in the user guide.

Project Use Code 1A – Broadband Infrastructure Projects

The Recipient must provide Project-level data for the following measures:

• Project technology type(s) (Planned/Actual)

o Fiber

o Coaxial Cable

o Terrestrial Fixed Wireless

o Other (specify)

• Total miles of fiber deployed (Planned/Actual)

• Total number of locations served (Planned/Actual)

o Total number of locations served, broken out by speeds:

▪ Pre-CPF Investment:

• Number receiving less than 25/3 Mbps

• Number receiving 25/3 Mbps or greater but less than 100/20 Mbps
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▪ Post-CPF Investment (Planned/Actual):

• Number receiving minimum 100/100 Mbps 

• Number receiving minimum 100/20 Mbps and scalable to 100/100 

Mbps

o Total number of funded locations served, broken out by type (Planned/Actual):

▪ Residential

• Total Housing Units

▪ Business

▪ Community anchor institution

• Speed tiers offered and corresponding non-promotional prices, including associated 

fees, for each speed tier of broadband service.

• Confirmation that the provider is participating in the FCC’s Affordable Connectivity 

Program (ACP) (Actual) [Applies only for States and territories]

For each location served by a Project, the Recipient must collect from the subrecipient and 

submit the following information to Treasury using a predetermined file format that will be 

provided by Treasury on the CPF website:

• Latitude/longitude at the structure where service will be installed 

• Technology used to offer service at the location

• Location Type

o Residential

▪ If Residential, Number of Housing Units

o Business

o Community anchor institution

• Speed tier at the location pre-CPF investment

o Below 25/3 Mbps 

o 25/3 Mbps or greater but less than 100/20 Mbps

• Speed and latency at the location post-CPF investment 

o Maximum download speed offered 

o Maximum download speed delivered

o Maximum upload speed offered.

o Maximum upload speed delivered

o Latency

• Standardized FCC Identifiers

o Fabric ID # (Broadband Serviceable Fabric Locations)

o FCC Issued Provider ID #

Project Use Code 1B – Digital Connectivity Technology Projects

• Address(es) from which devices will be distributed or installed (in the case of public wifi equipment), or other location information as appropriate

• Device type (Select all that apply)

o Laptops

o Tablets

o Desktop Computers

o Public Wi-Fi Equipment

o Other

• For each selected device type, provide: (Planned/Actual)

o Total number of devices purchased
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o Total expenditure

• Total number of individuals using devices (Planned/Actual)

• A brief narrative explaining the number and types of digital literacy trainings and other 

support services provided to enable use of the devices, including the number of 

individuals who attend or make use of the trainings and support services

(Proposed/Actual)

• Are Subrecipients measuring the Project’s effectiveness and impact through data 

collection, such as surveys? (Y/N)

Project Use Code 1C – Multi-Purpose Community Facility Projects

• Physical address of each Multi-Purpose Community Facility funded by the Project

(Planned/Actual)

• Investment type

o New construction, to include acquisition of property for development

o Renovation/expansion of existing structure, to include acquisition of existing 

structures for renovation/expansion

• Type and number of features in the Multi-Purpose Community Facility

(Planned/Actual):

o Classroom

o Computer Lab

o Multi-purpose Space

o Telemedicine Room

o Other (with explanation)

• Total square footage funded by CPF dollars (Planned/Actual)

• Total number of individuals using the capital asset (Actual)

• Does the Multi-Purpose Community Facility have proximate access to public 

transportation? (Y/N)

Project Use Code 2 – Case-by-Case Reviews

For Program Plans submitted for Case-by-Case Review, Treasury will work with the 

Recipient to develop metrics and performance measures for the Program Plan and 

associated Projects. As one component of their submission, Recipients will be asked to 

provide proposed metrics and performance measures for review by Treasury. Performance 

indicators proposed should include both output and outcome measures. Recipients are 

encouraged to use logic models4to identify their output and outcome measures. All 

proposed metrics and measures are subject to final review and approval by Treasury.

4 A logic model is a tool that depicts the intended links between program investments and outcomes, 

specifically the relationships among the resources, activities, outputs, outcomes, and impact of a 

program. More information about logic models can be found in Managing For Results: The Performance 

Management Playbook for Federal Awarding Agencies.
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B. Performance Report

All Recipients must submit Performance Reports that demonstrate the performance of CPFfunded Programs. While the Project and Expenditure Report focuses on project-level 

information associated with approved CPF Programs, the Performance Report will provide 

information related to program outputs and outcomes against the stated objectives in the 

approved Program Plan(s). Recipients must submit a Performance Report for each approved 

Program Plan according to the schedule outlined in Table 1.

Performance Reports are due 30 calendar days after the end date of the reporting period, 

except for the final report, which is due 120 calendar days after the end of the period of 

performance.5

Recipients must post each Performance Report on their public-facing website before submitting

the report to Treasury, and the report must continue to be available on the Recipient’s website 

for a period of not less than five years. This reporting requirement includes uploading a link to 

the publicly available Performance Report document along with submitting the report using the 

Treasury Reporting Portal. 

Treasury will provide a recommended template for Performance Reports in a forthcoming user 

guide, but Recipients may modify this template as long as the submission meets the 

requirements outlined in this section.

More information about how to submit Performance Reports will be shared in the user guide.

The Performance Report should include, at a minimum, the following information for each 

Program Plan that has been approved by Treasury: 

1. Program Information

• Approved Program Plan number (as provided by Treasury)

• Program start date 

• Program end date

• Actual CPF funds allocated to this Program

2. Executive Summary

Provide a high-level overview of the Recipient’s actual uses of funding and progress made 

during the period covered towards objectives stated in the corresponding approved Program 

Plan. The Executive Summary should also include an overview of key outcomes and any 

noteworthy challenges or opportunities identified during the period covered. 

3. Uses of Funds

Recipients must provide a short narrative describing the intended and actual use of funds and

the performance of the Program Plan. Recipients should reference the objectives and activities 

outlined in the approved Program Plan. The narrative should also explain the data, including 

performance indicators, submitted via the Project and Expenditure Reports during the period 

covered and must address the following topics:

• Activities implemented over the period covered, including summaries of key milestones 

achieved, outputs produced, and outcomes achieved;

• Activities planned for the next period covered;

5 For additional information on final reports, see 2 C.F.R. 200.344(a) and (b).
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• Narratives about individuals/households benefiting from CPF funds, including 

information about methods used for collecting and measuring success;

• Notable challenges and the status of each challenge;

• Overview and outcomes of ancillary costs incurred to support bringing the capital 

asset(s) into full use (e.g., focused advertising to increase broadband subscriptions in 

high-need communities, digital literacy training to support device loan programs,

community engagement to support successful operations, etc.).

4. Promoting Equitable Outcomes and Addressing Critical Needs

Treasury encourages uses of funds that promote strong, equitable growth, including racial 

equity, in communities with a critical need, such as high-poverty and rural areas. For the 

purposes of CPF, equity and underserved communities are defined in the Executive Order

13985 On Advancing Racial Equity and Support for Underserved Communities Through the 

Federal Government, as issued on January 20, 2021 (EO 13985). Treasury additionally 

supports “equity for all, including people of color and others who have been historically 

underserved, marginalized, and adversely affected by persistent poverty and inequality” EO 

13985 at 7009.

Performance Report 1 must describe efforts and outcomes during the period covered to 

promote equity and address critical needs as described in each approved Program Plan. Each 

Performance Report thereafter must provide an update, using qualitative and quantitative data, 

on how the Recipient achieved or promoted equitable outcomes or progressed toward equity 

objectives during the reporting period, and any constraints or challenges related to increasing 

equity. 

Please describe how the Recipient considered and measured equity and addressed critical 

need at the various stages of the Program during the reporting period, including: 

a. Objectives: Based on your definition of communities with critical need, are there particular 

historically underserved, marginalized, or adversely affected groups, including those living in 

rural areas and/or high-poverty areas, that the capital assets being funded by CPF are 

designed to serve? Reiterate the definition of critical need used for each Program Plan.

b. Awareness: How equal and practical was the ability for members of these communities, 

including households, businesses, and other organizations, to become aware of the services 

funded by CPF? 

c. Outcomes: What progress has the Program made toward addressing critical need(s) 

identified in targeted communities, such as closing gaps, reaching universal levels of 

service, or disaggregating progress by race, ethnicity, and other equity dimensions that are 

relevant to the policy objective? What methods (e.g., surveys, interviews) are being used (if 

applicable) to quantify and qualify Project and Program outcomes?

5. Labor

Describe workforce practices on any Broadband Infrastructure and/or Multi-Purpose Community 

Facility projects being pursued. How are projects using strong labor standards to promote 

effective and efficient delivery of high-quality infrastructure projects while also supporting the 

economic recovery through employment opportunities for workers? For example, report 

whether any of the following practices are being utilized: project labor agreements, community 

benefits agreements, prevailing wage requirements, and local hiring.

6. Community Engagement

Please describe how the Recipient incorporated or plans to incorporate feedback from

communities, organizations, and constituents when selecting Capital Projects Fund Projects and 
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how the Recipient plans to address feedback (including grievances) received during project 

construction and/or implementation. 

Recipients should report on (and include quantitative information, such as counts, about) the 

following activities related to community engagement in support of the implementation and 

operations of each Program and related Projects:

• Community engagement efforts and activities that occurred with and/or in communities 

served by the Program; Recipients should include information about the types of 

organizations (such as training providers, community colleges, libraries, churches, and 

community-based groups) and, where possible, names of organizations and 

communities the Recipient and Subrecipient(s) were engaged with to support the 

implementation and operations of Projects;

• Outreach, advertising, and translation activities and services deployed to reach 

communities the Program is designed to serve; and

• Languages used in community outreach efforts and materials for people with limited 

English proficiency, and other approaches taken to solicit feedback from underserved 

communities.

If relevant, Recipients must report on how funds will build the capacity of community 

organizations to serve people with significant barriers to services, including people of color, 

people with low incomes, populations with limited English proficiency, and other traditionally

unserved or underserved groups. 

Recipients should also outline any plans to sustain, improve, and or grow community engagement 

efforts in the subsequent performance year.

7. Civil Rights Compliance

See Part 3 Section B.8.c. 
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Part 3: General Guidance

This section provides an overview of Recipients’ compliance responsibilities under the Capital 

Projects Fund Program.

It is the Recipient’s responsibility to ensure that their CPF award funds are used in compliance 

with all applicable statutes, regulations, and guidance published by Treasury, and the 

requirements of any other funding sources used in conjunction with CPF award funds.

Recipients must maintain proper documentation supporting determinations of allowable costs 

and proper internal controls.

It is the Recipient’s responsibility to ensure that Subrecipients are using the subawards for 

authorized purposes in accordance with 2 CFR 200.332, including ensuring that Subrecipients 

comply with the Capital Projects Fund Statute, grant agreement, applicable federal statutes, 

regulations, guidance published by Treasury, and reporting requirements.

A. Compliance Requirements

All Recipients of federal funds must complete financial, performance, and compliance reporting 

as required by the Grant Agreement, 2 CFR 200.328, 2 CFR 200.329, and as outlined in Part 2 

of this guidance. Expenditures may be reported on a cash or accrual basis as long as the 

methodology is disclosed and is consistently applied. Project and Expenditure Reports must 

incorporate the definition of expenditures pursuant to 2 CFR 200.1. Recipients must maintain 

accounting records for compiling and reporting accurate financial data in accordance with 

appropriate accounting standards and principles.

B. Uniform Administrative Requirements

CPF awards are subject to the requirements set forth in the Uniform Guidance except as 

otherwise provided by Treasury guidance. Recipients should review the Uniform Guidance 

requirements applicable to their use of Capital Projects Fund grant funds, and Capital Projects 

Fund Projects. 

The following sections provide a general summary of Recipients’ compliance responsibilities 

under applicable statutes and regulations, including the Uniform Guidance. Note that the 

descriptions below are only general summaries. All Recipients and Subrecipients are advised 

to carefully review the Uniform Guidance requirements and all other regulatory and statutory 

requirements applicable to CPF.

1. Internal Controls

Per 2 CFR 200.303, Recipients must establish and maintain effective internal controls to 

manage their CPF award in compliance with Federal statutes, regulations, and the terms and 

conditions of the CPF award. Recipients should review program requirements, the Grant 

Agreement, and the approved Program Plans to determine and record eligible uses of CPF 

grant funds. 

2. Allowable Costs/Cost Principles

As outlined in the Uniform Guidance at 2 CFR Part 200, Subpart E regarding Cost Principles, 

allowable costs must meet the following criteria: (1) be allowable, necessary, reasonable, and 

allocable for the performance of the Federal award, (2) be accorded consistent treatment as 

either a direct cost or indirect cost (and as either a Project cost or administrative cost), and (3) 

be adequately documented. Recipients are responsible for the effective administration of 
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Federal awards, application of sound management practices, and administration of Federal 

funds in a manner consistent with the program objectives and terms and conditions of the 

award.

3. Cash Management 

Capital Projects Fund payments made to states and territories are subject to the requirements 

of the Cash Management Improvement Act (P.L. 101-453) and Treasury’s implementing 

regulations at 31 CFR part 205. CPF payments made to freely associated states are subject to 

the cash management requirements described in the Uniform Guidance at 2 CFR 200.305(b). 

Recipients may request drawdowns of CPF funds from Treasury on a reimbursement basis to 

cover outlays already incurred, or as advances on anticipated outlays. Recipients are 

responsible for requesting drawdowns from Treasury only as needed. Pursuant to 31 CFR 

205.33, state Recipients are required to minimize the time elapsing between drawdowns of 

award funds and outlays of award funds.

4. Earned Interest

Recipients are not required to deposit CPF funds in a separate bank account; however they 

must track and account for CPF funds appropriately. Recipients are also required to track 

interest earned on CPF funds. 

Freely Associated States

Pursuant to 2 CFR 200.305(b)(9), interest earned up to $500 per year may be retained 

by freely associated state Recipients for administrative expenses on the CPF award. All 

additional interest earned by freely associated state Recipients on advances from CPF 

funds must be remitted annually to the Department of Health and Human Services 

Payment Management System (PMS) through an electronic medium using either 

Automated Clearing House (ACH) network or a Fedwire Funds Service payment.

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5. Period of Performance and Pre-Award Costs

The period of performance for the CPF grant begins on the date that Treasury countersigns the 

Grant Agreement (the “POP Start Date”) and ends on December 31, 2026 unless otherwise 

indicated. Recipients may use CPF funds to pay for certain eligible costs incurred after March 

15, 2021, but before the POP Start Date (“Pre-Award Costs”) subject to certain conditions. Any 

Pre-Award Costs must be disclosed, explained, and submitted along with corresponding 

Program Plan materials to be reviewed and approved by Treasury. Recipients should refer to 

Section 10 of the Grant Agreement and Section I.D.b of the Capital Projects Fund Guidance for 

additional information about Pre-Award Costs. All funds must be used for costs incurred during 

the period of performance or for Pre-Award Costs.

6. Program Income

For all projects (other than broadband infrastructure projects) Treasury requires that Recipients 

add program income to their CPF award pursuant to 2 CFR 200.307. Any program income 

generated from CPF funds must be used for the purposes and under the conditions of CPF. 

Program income includes but is not limited to income from fees for services performed or fees 

from the use or rental of real or personal property acquired under federal awards. Interest 

6 See 2 CFR 200.305(b)(9) for detailed information on how freely associated state recipients may remit 

interest earned over $500 annually to the Department of Health and Human Services Payment 

Management System (PMS).
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earned on advances of federal funds is not program income. For more information on what 

constitutes “Program Income” please see 2 CFR 200.1.

Recipients not using CPF funds for a broadband infrastructure project should calculate, 

document, and record their program income. Treasury additionally encourages Recipients to 

implement written policies that explicitly identify appropriate allocation methods, accounting 

standards and principles, compliance monitoring checks for program income calculations, and 

records. 

Treasury’s SLFRF and CPF Supplementary Broadband Guidance, published on May 17, 2023, 

provides guidance on program income generated by broadband infrastructure projects. 

7. Subrecipient Monitoring 

CPF Recipients that provide a subaward to Subrecipients to carry out CPF Projects are required 

to manage and monitor their Subrecipients to ensure compliance with requirements of the CPF 

award pursuant to 2 CFR 200.332 regarding requirements for pass-through entities. 

Recipients must clearly identify to the Subrecipient that: (1) the award is a subaward of CPF 

funds; (2) all applicable compliance requirements for use of CPF funds; and (3) all applicable 

reporting requirements for expenditures of CPF funds. 

8. Other Compliance Obligations

Recipients should ensure that they remain in compliance with the Grant Agreement. These 

obligations include the following items in addition to those described above: 

a. Recordkeeping Requirements. Recipients must maintain records and financial documents 

for five years after all CPF funds have been expended or returned to Treasury. Wherever 

practicable, such records should be collected, transmitted, and stored in open and machinereadable formats. 

Recipients must agree to provide or make available such records to Treasury upon request, 

and to any authorized oversight body, including but not limited to the Government 

Accountability Office (GAO), Treasury’s Office of Inspector General (OIG), and the 

Pandemic Relief Accountability Committee (PRAC). 

b. Single Audit Requirements. Recipients and Subrecipients that expend $750,000 or more

in Federal awards during their fiscal year will be subject to an audit under the Single Audit 

Act and its implementing regulation at 2 CFR Part 200, Subpart F. Recipients and 

Subrecipients may also refer to the Office of Management and Budget (OMB) Compliance 

Supplements for audits of federal funds and related guidance and the Federal Audit 

Clearinghouse to see examples of single audit submissions. 

c. Civil Rights Compliance. Recipients of Federal financial assistance from the Treasury are 

required to meet legal requirements relating to nondiscrimination and nondiscriminatory use 

of Federal funds. Those requirements include ensuring that entities receiving Federal 

financial assistance from the Treasury do not deny benefits or services, or otherwise 

discriminate on the basis of race, color, national origin (including limited English proficiency), 

disability, age, or sex (including sexual orientation and gender identity), in accordance with 

the following authorities: Title VI of the Civil Rights Act of 1964 (Title VI), 42 U.S.C. 2000d-1 

et seq., and the Department's implementing regulations, 31 C.F.R. part 22; Section 504 of 

the Rehabilitation Act of 1973 (Section 504), 29 U.S.C. 794; Title IX of the Education 

Amendments of 1972 (Title IX), 20 U.S.C. 1681 et seq., and the Department's implementing 
16

regulations, 31 C.F.R. part 28; Age Discrimination Act of 1975, 42 U.S.C. 6101 et seq., and 

the Department’s implementing regulations at 31 C.F.R. part 23.

In order to carry out its enforcement responsibilities under Title VI of the Civil Rights Act, 

Treasury will collect and review information from Recipients to ascertain their compliance 

with the applicable requirements after providing financial assistance. Treasury’s 

implementing regulations, 31 CFR part 22, and the Department of Justice (DOJ) regulations, 

Coordination of Non-discrimination in Federally Assisted Programs, 28 CFR part 42, provide 

for the collection of data and information from Recipients (see 28 CFR 42.406). Treasury 

will request that Recipients submit data for post-award compliance reviews, including 

information such as a narrative describing their Title VI compliance status. Treasury may

also request certain Title VI compliance information on an annual basis. This information 

may include questionnaires, narratives, and assurances describing Recipient compliance 

with Title VI.
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Appendix 1: Definitions 

Treasury will apply the following definitions for purposes of this reporting guidance. Terms not 

defined herein shall have the definitions contained in Uniform Guidance.

(a) “Administrative Expenses”, “Program Administrative Expenses”, or “Administrative 

Costs” mean the costs incurred by a Recipient related to the administration of 

Capital Projects Fund awards, the provision of technical assistants to potential 

Subrecipients, and compliance with grant administration and audit requirements.

(b) “Ancillary Costs” has the meaning set forth in Section I.C.c of the Capital Projects 

Fund Guidance.

(c) “Broadband Infrastructure Project” has the meaning set forth in Section I.C.a of the 

Capital Projects Fund Guidance.

(d) “Capital Project” or “Project” has the meaning set forth in Section I.C.c of the Capital 

Projects Fund Guidance.

(e) “Capital Projects Fund Program Plan” or “Program Plan” means a plan submitted by 

a Recipient containing a description of a program for which the Recipient is seeking 

funding under the Capital Projects Fund. 

(f) “Capital Projects Fund Guidance” refers to the Guidance for the Coronavirus Capital 

Projects Fund for States, Territories, and Freely Associated States. 

(g) “Capital Projects Fund Statute” or “Statute” means Section 604 of the Social 

Security Act, as added by section 9901 of the American Rescue Plan Act of 2021, 

Pub. L. No. 117-2 (Mar. 11, 2021), codified as 42 U.S.C. § 804.

(h) “Contractor” is an entity that receives a contract by which a CPF Recipient or 

Subrecipient purchases property or services needed to carry out a CPF Project or 

Program. 

(i) “Digital Connectivity Technology Project” has the meaning set forth in Section I.C.a 

of the Capital Projects Fund Guidance.

(j) “Expenditure” is the amount that has been incurred as a liability of the entity (the 

service has been rendered or the good has been delivered to the entity).

(k) “Grant Agreement” means the standardized agreement executed between the Eligible 

Recipient’s authorized representative and Treasury that outlines the terms and 

conditions of the funds, reporting and recordkeeping, and other requirements. 

(l) “Logic Model” is a tool used to describe how programs are linked to the results the 

program is expected to advance or achieve. Logic models are intended to identify 

problems (in the problem statement), name desired results (in the goals and objectives), 

and develop strategies for achieving results. Logic models also provide a visual 

representation of the causal relationships between a sequence of related events, 

connecting the need for a planned program or project with desired results. Logic models 

identify strategic elements (e.g., inputs, outputs, activities, and outcomes) and their 

relationships. This also includes statements about the assumptions and external risks 
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that may influence success or present challenges.

(m)“Multi-Purpose Community Facility Project” has the meaning set forth in Section 

I.C.a of the Capital Projects Fund Guidance.

(n) “Obligations” are orders placed for property and services, contracts and subawards 

made, and similar transactions that require payment.

(o) “Outcome” is a desired result of a program. 

(p) “Output” is a quantity of a product or service delivered by a program. 

(q) “Performance Indicator” or “Indicator” is a measurable value that indicates the state or 

level of something. 

(r) “Period Covered” is the set amount of time for which a Project and Expenditure Report 

or Performance Report requests information. 

(s) “Program” means one or more Capital Projects with common characteristics (e.g., a 

group of Multi-Purpose Community Facility Projects that directly enable work, education, 

and health monitoring) for which an Eligible Recipient is seeking funding under the 

Capital Projects Fund. 

(t) “PoP Start Date” has the meaning set forth in Part 3. Section B.5. 

(u) “Pre-Award Costs” has the meaning set forth in Part 3. Section B.5. 

(v) “Recipient” or “Eligible Recipient” is an entity that receives a federal award directly 

from a federal awarding agency. The term Recipient does not include 

Subrecipients or individuals that are beneficiaries of the award.

(w) “State” has the meaning set forth in Section I.A of the Capital Projects Fund 

Guidance. 

(x) “Subrecipient” is an entity that receives a subaward from a CPF Recipient to carry 

out a capital project on behalf of a CPF Recipient. Subrecipients may include, but 

are not limited to, other levels or units of government, non-profits, or private 

entities. 

(y) “Treasury” means the U.S. Department of the Treasury. 

(z) "Treasury Reporting Portal” refers to the online portal that will be used to submit Project 

and Expenditure Reports and Performance Reports.

(aa) “Tribal Government” means the recognized governing body of any Indian or Alaska 

Native tribe, band, nation, pueblo, village, community, component band, or component 

reservation, individually identified (including parenthetically) in the list published most 

recently as of the date of enactment of this Act pursuant to section 104 of the Federally 

Recognized Indian Tribe List Act of 1994 (25 U.S.C. 5131) and the State of Hawaii (for 

exclusive use of the Department of Hawaiian Home Lands and the Native Hawaiian 

Education Programs to assist Native Hawaiians).
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(bb) “Uniform Guidance” means the Administrative Requirements, Cost Principles, and Audit 

Requirements for Federal Awards, located in Title 2 of the Code of Federal Regulations 

(2 CFR Part 200).

Revision Log

Version Date Published Summary of Changes

1.0 August 10, 2022 Initial Publication

1.1 December 22, 2022 • Pg 2, revised period covered in P1 Performance 

Report to thru June 30,2023

• Pg 3(b), revised Program Budget Update 

frequency to no less frequently than once every 

twelve months

1.2 May 1, 2023 • Pg 1, changes made to reflect publication of the 

Reporting Guidance for Tribal Entities

• Pg 4, changes made to clarify due date for first 

report

• Pg 15, additional guidance on program income 

generated by non-broadband infrastructure 

projects.

1.3 June 7, 2023 • Pg 9, added FCC standardized identifier 

requirements. 

1.4 September 18, 

2023

• Pg 1, pg 15, references to SLFRF and CPF 

Supplementary Broadband Guidance updated.

• Pg 3, pg 4, references to User Guide updated.

• Pg 3, timeline for submitting first P&E report 

updated.
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