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 firstname.lastname@example.org.
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:
ARPA prohibits the use of the funds for pension or to offset revenue loss due to a tax cut.
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.
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):
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.
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
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.
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