Michigan Townships Association

Federal COVID-19 Relief Funding

ARPA COVID

Reminder: Annual NEU Project and Expenditures Report are due April 30

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 not obligated any funds or determined how you will put them to use. The portal for reporting opens around April 1 each year.

A new, 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.

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.)

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.

Townships have until the end of 2024 to obligate ARPA funds

Townships have until Dec. 31, 2024, to obligate their allocation of federal ARPA funds. If your township has not already done so or has not fully obligated the money—distributed to local and state governments to mitigate the fiscal impacts of the COVID-19 pandemic—you should make plans now in order to meet the deadline. ARPA funds must be fully spent by Dec. 31, 2026.

As a reminder, townships that did not choose the standard allocation option, which allowed use up to $10 million to be used for general government services, can use the funds for the following purposes:

  • Provide government services affected by a revenue reduction during the pandemic
  • Make necessary investments in water, sewer and broadband infrastructure
  • Respond to the COVID-19 emergency and address its negative economic impacts
  • Provide premium pay for essential employees performing an essential function in the pandemic
  • Emergency relief from national disasters
  • Surface transportation infrastructure
  • Title I projects (includes community development in line with the federal Housing and Urban Development Community Development Block Grant program)

ARPA prohibits the use of the funds for pension or to offset revenue loss due to a tax cut.

New ARPA ‘obligation’ interim rule

In late 2023, the U.S. Department of Treasury issued an “Obligation Interim Final Rule” in response to questions and comments regarding obligation of State and Local Fiscal Recovery Funds (SLFRF) through the American Rescue Plan Act (ARPA).

“Obligation,” according to Treasury, continues to mean “an order placed for property and services and entry into contracts, subawards, and similar transactions that require payment.” Under the interim rule, “obligation” now also expands ARPA funds to cover costs related to reporting and compliance requirements, including subrecipient monitoring; single audit costs; record retention and internal control requirements; property standards; environmental compliance requirements; and civil rights and nondiscrimination requirements.

The interim final rule does not alter any deadlines for APRA fund obligations (by end of 2024) or expenditures (by the end of 2026), nor does it alter eligible use categories.

Interim rule includes new eligible uses for ARPA funds

Townships that have not yet obligated their American Rescue Plan Act allocation or that did not choose the standard allocation option to use up to $10 million for general government services now have a few more eligible uses for the funds. Under a new interim rule released by U.S. Treasury in August, the following uses are now eligible (read the overview of the new interim rule here):

  • Emergency relief from national disasters (including the negative economic effect of natural disasters)—According to the U.S. Treasury overview of the interim rule, this includes firefighting, search and rescue, emergency repairs, snow removal, and more when responding to a designated or declared natural disaster. The interim rule also outlines eligible uses for mitigation activities for future natural disasters.
  • Surface transportation infrastructure—This allowance includes various pathways for recipients to use ARPA funds for surface transportation projects eligible for specific U.S. Department of Transportation programs, for projects not receiving USDOT funds, and to satisfy non-federal share requirements for certain surface transportation projects.
  • Title I projects—This includes community development in line with the federal Housing and Urban Development (HUD) Community Development Block Grant program, subject to certain requirements and limitations.

Self-Service ARPA Resources webpage 

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.

SAM.gov UEI replaces previous DUNS

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.

ARPA single audit guidance

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.

Additional resources for completing your township’s ARPA ‘Project and Expenditure’ Report

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.

Broadband uses for ARPA funds

Merit Network offers the following resources for townships considering using their ARPA funds to improve broadband access in their communities. How Communities are using ARPA for Broadband Next Century Cities highlights how communities across the country are using funds from the American Recovery Plan Act (ARPA) to fund broadband planning and pilots. Rules for using ARPA funds for Broadband The U.S. Treasury Department recently put out a final ruling on how State and Local Fiscal Recovery Funds (ARPA) can be used. Grants Office details increased flexibility in applying these funds toward broadband initiatives. Report: Grant Opportunities Grants Office, LLC, puts together a detailed report on current and upcoming state and federal grants that can be applied towards broadband projects. The report is updated quarterly (March report just posted!), and can be downloaded for free by completing the form at this page.

ARPA Final Rule GREATLY simplifies and broadens township’s use of funds

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.

Guidance and resources for townships

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

Quick Links

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.

  • Valid SAM.gov UEI number. SAM.gov—the federal database used to do business with the federal government—has stopped using the DUNS number (a unique identifying number used by the federal government to track how federal money is allocated)  and changed to a “Unique Entity ID” (UEI) that is generated by SAM.gov.

    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.

  • Active SAM registration. SAM is the official government-wide database to register with in order to do business with the U.S. government. All federal financial assistance recipients must register on SAM.gov and renew their SAM registration annually to maintain an active status to be eligible to receive Federal financial assistance. There is no charge to register or maintain your township’s SAM registration. Your township does not have to pay, or go through a third party, to renew your registration. If your townships does not have an active SAM registration, please visit, SAM.gov to begin the entity registration or renewal process. Please note that SAM registration can take up to three weeks; delay in registering in SAM could impact timely payment of funds. Click here for a quick overview for SAM registration

Auditor and CPA firms available to help your township with ARPA reporting

Baird, Cotter and Bishop, PC, Cadillac
231-775-9789      tmulder@bcbcpa.com
www.bcbcpa.com

Schulze Oswald Miller & Edwards PC, Alpena
989-354-8707      kristy@somecpa.com
www.somecpa.com

Siegfried Crandall, Grand Rapids
800-876-0979      dveldhuizen@scpro.net
www.siegfriedcrandall.com

Walker, Fluke & Sheldon, PLC, Hastings
269-945-9452 rsprague@wfscpas.com
www.wfscpas.com

Yeo & Yeo, PC, Saginaw
989-793-9830 jamriv@yeoandyeo.com
www.yeoandyeo.com2