Tuesday, April 20, 2021
Intended Audience: Local government employees, including but not limited to, clerks, treasurers, elected officials, finance directors, city, township, or village managers, and accounting staff.
Pre-Award Requirements for the Coronavirus State and Local Fiscal Recovery Fund and Other Preparation Tips
Under the American Rescue Plan Act of 2021 (ARPA), the U.S. Department of Treasury has established three classifications for local governments – metropolitan cities, counties, and non-entitlement communities. Metropolitan cities are defined by the Housing Community Development Act of 1974. Non-entitlement communities are generally local governments other than counties and metropolitan cities.
Metropolitan cities and counties will receive their federal ARPA payments directly from the U.S. Department of Treasury, while non-entitlement communities will receive their payments through the state of Michigan.
On April 15, 2021, the U.S. Department of Treasury announced pre-award requirements for metropolitan cities and counties. While this guidance focuses on metropolitan cities and counties, non-entitlement communities are expected to provide the same information, which includes a DUNS number and a SAM registration.
Many of Michigan’s local governments have already set up this information for the state-level CARES Act programs administered last year, which included the Coronavirus Relief Local Government Grants Program (CRLGG), First Responder Hazard Pay Premiums Program (FRHPPP), and Public Safety and Public Health Payroll Reimbursement Program (PSPHPR).
Local governments must renew their SAM registration annually to maintain an “active status,” which designates an entity as eligible to receive federal financial assistance. Additional information on this topic is available on the U.S. Department of Treasury’s Coronavirus State and Local Fiscal Recovery Fund webpage.
American Rescue Plan Act Inquiries
The Michigan Department of Treasury is receiving many inquiries from local governments about the recent enactment of ARPA.
Most of the questions revolve around the following three themes:
- When will local governments receive their federal funds?
- How can federal dollars be spent?
- What kind of reporting requirements will be mandated with this funding?
The U.S. Department of Treasury will be providing additional guidance on APRA funding. As more information is made available, the state Treasury Department will be providing guidance.
Local governments are encouraged to review tips about preparing for the use of ARPA dollars by viewing Treasury's "Planning for the Use of the American Rescue Plan Act" memo. This information will assist local governments as they prepare to use this funding most effectively.
The state Treasury department will continue to provide more detailed information as it is made available through webinars and email notifications.
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