Michigan Townships Association
Michigan Townships Association
The vast majority of Michigan townships accepted federal American Rescue Plan Act (ARPA) funds, allocated by the U.S. government in 2021 to support response to and recovery from the COVID-19 pandemic. Under program guidelines, all ARPA funds must be fully expended by Dec. 31, 2026. All funds must have been fully obligated by the end of 2024. Funds not fully obligated or those townships that did not complete their reporting requirements may see their funds recouped by the U.S. Department of Treasury (even if they are already spent).
Beginning in fall 2025, U.S. Treasury began inviting ARPA recipient communities, on a rolling basis, that had reported fully obligated and expended their ARPA allocation to close out their award ahead of the Dec. 31, 2026, program performance deadline. Recipients invited to close out their award will receive instructions from Treasury. If your township has not received communication from Treasury, the closeout option is not yet available. Treasury is expected to open this capability to more municipalities during the 2026 reporting cycle. Treasury will provide instructions at a later date for recipients that do not closeout prior to the end of the performance period.
Treasury has created a “Closeout Resource Hub” with information, including an “Award Closeout Preparation Checklist” to help ARPA recipients verify compliance with program requirements. This includes: the entire award has been obligated and spent; all reporting requirements have been completed; active SAM.gov registration; and Treasury communications are received by your township’s point of contact (confirm/updating information in Treasury’s portal). Non-entitlement unit recipients (NEUs; all but eight of Michigan’s largest townships are NEUs) must also ensure their award terms and conditions agreement is signed and uploaded to the Treasury portal.
Until your township closes out its award—including receiving confirmation from Treasury that the closeout is successful, you must continue to file the annual “Project & Expenditure Report” with U.S. Treasury. Per Treasury’s “State and Local Fiscal Recovery Funds Compliance and Reporting Guidance,” updated in September 2025, NEUs must file their annual report by April 30, 2026, for expenditures from April 1, 2025 through March 31, 2026. A final report must be filed in April 30, 2027, covering
April 1, 2026 through Dec. 31, 2026.
As the ARPA program winds down, MTA will continue to provide updates and information as it becomes available.
All non-entitlement units of government (NEUs—all but eight of Michigan’s largest townships) that accepted American Rescue Plan Act (ARPA) funds must complete their annual “Project and Expenditure Report” by April 30 each year. Every NEU must complete the report, even if your township has already fully spent the funds. It is important to complete the report, as the federal government has indicated its intentions to “claw back” funds from municipalities that do not comply with program requirements, including annual reporting.
A one-hour webinar recording from the U.S. Department of Treasury offers a portal demonstration and overview of NEU reporting and compliance obligations. Watch the webinar here.
MTA-member officials can reach out to MTA’s Member Information Services Department for assistance or with ARPA questions at (517) 321-6467 (press option 1). State Treasury can also assist townships continuing to have issues completing reporting or accessing U.S. Treasury’s reporting system; email them at treas-arpa@michigan.gov.
Your township’s SAM.gov registration must be active for the reporting, and must be renewed annually. This is free of charge. Your township does not have to pay, or go through a third party, to renew your registration. (Note: SAM.gov uses a Unique Entity ID instead of a DUNS number. Visit www.SAM.gov or see below for more information.)
The U.S. Department of the Treasury issued an alert to all recipients of Coronavirus State and Local Fiscal Recovery Funds (SLFRF)—also called American Rescue Plan Act or ARPA—awards that it will be vigorously monitoring recipients’ methods of obligating funds by the Dec. 31, 2024, deadline. For non-entitlement unit (NEU) townships (all but Michigan’s eight largest townships), the annual report must have been submitted to Treasury between April 1 and April 30, 2025, covering obligations through the Dec. 31, 2024, deadline.
U.S. Treasury plans to conduct enhanced compliance checks on the obligation data to ensure funds are used in accordance with program requirements, and to recoup funds obligated or expended impermissibly and recapture funds that were not obligated by the deadline. For local units that did not fully obligate their funds by the deadline, you will receive “Financial Instructions to Return Unobligated Funds” based on the latest data available to Treasury. The instructions will:
If recipients do not repay amounts owed by the specified date, U.S. Treasury will establish a debt and follow standard debt collection policy and procedures in coordination with the federal Bureau of the Fiscal Service. Interest and penalties will accrue once the debt is established.
Townships that did not choose the standard allocation option to use up to $10 million for general government services have a few more eligible uses for the funds. Under an interim rule released by U.S. Treasury, the following uses are also eligible (read the overview of the new interim rule here):
A Self-Service Resources page on U.S. Treasury’s State and Local Fiscal Recovery Funds (through ARPA) website includes guidance and frequently asked questions, based on topic, including reporting, accessing Treasury’s portals and eligible use of funds.
Most, if not all, townships had a federal DUNS number—a unique identifying number used by the federal government to track how federal money is allocated, including, for example, American Rescue Plan Act funds. In 2022, SAM.gov—the federal database used to do business with the federal government—stopped using the DUNS number and changed to a “Unique Entity ID” (UEI) that is generated by SAM.gov. The intention was to allow the government to streamline the entity identification and validation process, and make it easier and less burdensome for entities to do business with the federal government. This information is particularly important for nearly every Michigan township as they prepare for the annual ARPA reporting April 30 of each year.
If you play a role in your township’s federal reporting or activity, you can find your township’s UEI—which has already been assigned—in your entity registration record after logging in. You can also search https://SAM.gov; expand the “Select Domain” option, then select “Entity Information,” then “Entities.” You can then use keywords and filters to search for your township. Visit SAM.gov or https://gsa.gov/entityid for more details.
Townships that spend more than $750,000 of their State and Local Fiscal Recovery Funds through the American Rescue Plan Act (ARPA) in a fiscal year will not have to undergo the usually required federal single audit as long as any additional, non-ARPA federal award expenditures do not exceed $750,000. In addition, recipients must have received $10 million or less in ARPA allocation. (Less than 10% of townships received allocations greater than $750,000, and all but one Michigan township received less than $10 million). Guidance released by U.S. Treasury details the alternative option for single audit requirements. Typically, a township that expends $750,000 or more in federal financial assistance within their fiscal year is required to engage the services of an auditor to conduct Single Audits as described in 2 C.F.R. 200, Subpart F, Audit Requirements. However, the compliance information grants eligible local governments the option for their auditor or practitioner to follow “Alternative Compliance Examination Engagement” guidance, as outlined in “Section IV. New Information,” beginning on page 9 of the guidance document.
For general support when completing the report, email Treasury at SLFRP@treasury.gov or call (844) 529-9527. For technical assistance, email covidreliefITsupport@treasury.gov.
Townships’ ability to put American Rescue Plan Act dollars to use in their communities was clarified—and GREATLY broadened and simplified—under the The U.S. Department of the Treasury final rule. Previously, most general government services or projects could only be funded if the township could project or demonstrate “revenue loss” as defined in the ARPA and prior interim final rule. According to a final rule overview, recipients that select a new up-to-$10 million “standard allowance may use that amount—in many cases their full award—for government services, with streamlined reporting requirement,” without having to demonstrate any “revenue loss.” Because all but one township has an allocation less than $10 million, this means that your township can elect to use its full allocation for general township services, projects and uses. Additional changes streamline the premium pay use, and broaden the infrastructure and economic impact categories.
Communities with Qualified Census Tracts have additional uses for ARPA funds to help offset impacts of the pandemic on certain populations, including low-income communities. A listing of all townships with QCTs is available here.
U.S. Department of Treasury resources
MTA resources
Michigan Department of Treasury guidance
National Association of Towns and Townships resources
Additional information and resources
Your township must have a valid UEI number and active SAM registration to ARPA applications and reporting. Local units must have a valid Unique Entity ID number (which replaced the DUNS number) to meet reporting requirements under the program. If your township has received other federal funds, including Coronavirus Relief Funds (i.e., First Responder Hazard Pay Premiums Program, Public Safety Public Health Payroll Reimbursement Program, COVID Relief Local Government Grants), you may already have this information.
You can find your township’s UEI—which has already been assigned—in your entity registration record after logging in. You can also search https://sam.gov; expand the “Select Domain” option, then select “Entity Information,” then “Entities.” You can then use keywords and filters to search for your township.
Visit SAM.gov or https://gsa.gov/entityid for more details.