The U.S. Treasury has scaled back its American Rescue Plan Act (ARPA) assistance to local governments, including responding to phone calls via its contact center. Contact center staffing has also been ramped down, and email response times are expected to be delayed as a result, according to Treasury, citing funding shortfalls. A new Self-Service Resources page is now available on U.S. Treasury’s State and Local Fiscal Recovery Funds (through ARPA) website, which includes guidance and frequently asked questions, based on topic, including reporting, accessing Treasury’s portals and eligible use of funds. MTA-member officials can continue to reach out to MTA’s Member Information Services Department for ARPA assistance or questions.
Most, if not all, townships have 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 (ARPA) funds. Earlier this year, 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 is 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). New guidance released by U.S. Treasury announced 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 new 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.
If your township has been unable to complete its filing of the first “Project and Expenditure” Report, it is recommended that you try to file something, and if tech issues persist, open a support ticket and save the number. A “record of attempting to file” will be helpful if U.S. Treasury does raise issues about late filing.
Treasury has stated that if someone was unable to meet the deadline by April 30, 2022, “recipients will be asked to provide a date by which the delayed reporting will be submitted so that Treasury can plan for incorporating the data.” 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.
IMPORTANT: Your township’s SAM.gov registration must be active for the reporting, and must be renewed annually. This is free of charge; townships do not need to pay a fee for this registration. We are again hearing of companies—some of whose communication appear to be affiliated with SAM.gov—reaching out to townships to renew the SAM.gov registration for a fee. Your township does not have to pay, or go through a third party, to renew your registration.
U.S. Treasury Webinars
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.
Townships’ ability to put #AmericanRescuePlan 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.
As a member of a statewide coalition, MTA continues to work to gain support for a comprehensive plan to leverage the state’s nearly $6 billion in federal ARPA funding. The plan, From Rescue to Prosperity: A Roadmap to Michigan’s Future, focuses the state’s ARPA resources in a coordinated manner across five key areas: infrastructure, fiscal health, thriving communities, strong economy, and public health and safety. We encourage township officials to seek the support of their legislators as the plan would provide direct investment across multiple sectors and maximize the one-time ARPA dollars. Learn more about the plan here.
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.
More than 98% of Michigan’s “non-entitlement unit” townships (those under 50,000 population) applied and have received the first half of their allocation of federal COVID relief funding through the American Rescue Plan Act. The second half will be distributed no later than 12 months after the initial allocation.
Townships have time to make decisions on uses
The funding has very broad flexibility for its uses and does not have to be obligated until Dec. 31, 2024. The funds will be helpful in shoring up, expanding or simply funding your local services. State Treasury, for example, believes that most local units of government-using the formula for revenue loss-will have demonstrable lost revenue due to the pandemic. By showing lost revenue, your township can use the funds on most current township services, to the extent of that loss.
As additional guidance is provided and communities around the state and country begin to make decisions on how to best put this funding to use, MTA will continue to provide updates and information for townships.
The American Rescue Plan Act contains $1.9 trillion for the coronavirus relief package with $350 billion allocated for state, local and tribal governments to mitigate the fiscal impacts of the COVID-19 pandemic and provide vital services. Local governments can use ARPA funds to cover costs incurred by Dec. 31, 2024, to:
The ARPA prohibits the use of the funds for pension or to offset revenue loss due to a tax cut.
The ARPA also includes $10 billion to states for a Critical Infrastructure Projects Program, with Michigan expected to receive $250 million. The monies are to be used for projects that would directly enable work, education and health monitoring-including remote options-in response to COVID-19. Examples provided during the legislative discussion included water, sewer and broadband.
U.S. Department of Treasury resources
Michigan Department of Treasury guidance
National Association of Towns and Townships resources
Additional information and resources
Your township must have a valid DUNS number and active SAM registration to ARPA applications and reporting. Local units must have a valid 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.
Auditor and CPA firms available to help your township with ARPA reporting
Baird, Cotter and Bishop, PC, Cadillac
Schulze Oswald Miller & Edwards PC, Alpena
Siegfried Crandall, Grand Rapids
Walker, Fluke & Sheldon, PLC, Hastings
Yeo & Yeo, PC, Saginaw