On June 17, the U.S. Department of the Treasury released the “Compliance and Reporting Guidance for the Coronavirus State and Local Fiscal Recovery Funds” authorized by the American Rescue Plan Act.

The State and Local Fiscal Recovery Fund is providing $350 billion in emergency funding for eligible state, local, territorial, and tribal governments across the country to accelerate recovery from the pandemic, address its economic fallout, and lay the foundation for a strong and equitable recovery.

The guidance builds on the Interim Final Rule issued on May 10 and provides additional detail and clarification for recipients’ compliance and reporting responsibilities.

Metropolitan Cities and NEUs
Reporting requirements differ for Metropolitan Cities and non-entitlement units of local government.

Metropolitan Cities will be required to provide periodic reports, with specific reporting requirements aligned to the population size of the jurisdiction and the size of its SLFRF award. All reports are due 30 days after the close of the relevant expenditure period.

By Aug. 31, 2021, all Metropolitan Cities must file an Interim Report to report programmatic data for spending between March 3 and July 31, 2021.

Metropolitan Cities must also file Project and Expenditure Reports providing data for awards and sub-awards, demographic information for each project, and other programmatic data, with the first due on Oct. 31, 2021. For Metropolitan Cities with SLFRF awards above $5 million, project and expenditure reports are due quarterly. For those with SLFRF awards under $5 million, project and expenditure reports are due annually.

A Recovery Plan Performance Report is required only for Metropolitan Cities with a population over 250,000 and must be published annually on the city’s website and provided to the Treasury Department. The report will contain detailed project performance data, including information on efforts to improve equity and engage communities. The first Recovery Plan Performance Report is due on Aug. 31, 2021.

The 38 Metropolitan Cities in Massachusetts are: Arlington, Attleboro, Barnstable, Boston, Brockton, Brookline, Cambridge, Chicopee, Fall River, Fitchburg, Framingham, Gloucester, Haverhill, Holyoke, Lawrence, Leominster, Lowell, Lynn, Malden, Medford, Methuen, New Bedford, Newton, Northampton, Peabody, Pittsfield, Plymouth, Quincy, Revere, Salem, Somerville, Springfield, Taunton, Waltham, Westfield, Weymouth, Worcester, and Yarmouth.

The other 313 communities in Massachusetts are considered non-entitlement units of local government.

Each non-entitlement unit of local government is required to meet compliance and reporting responsibilities as defined in the Interim Final Rule and further described in the Compliance and Reporting Guidance. Each NEU must submit a Project Expenditure Report by Oct. 31, 2021, and then annually thereafter. The Treasury Department reports that it will begin accepting these reports in October 2021 and will issue a User Guide and other reference materials before that date.

Reporting guidance principles
The Treasury Department states that the SLFRF Reporting Guidance has several features to ensure a speedy, equitable, transparent, and accountable recovery for all Americans.

Specifically, the SLFRF Reporting Guidance is:
• Accountable: The SLFRF requires program, performance, and financial reporting to build public awareness, increase accountability, and allow the Treasury Department to monitor compliance. Recipients are required to account for every dollar spent and provide detailed information on how funds are used.
• Transparent: Those recipients receiving the largest amount of funds will be required to publicly post a detailed Recovery Plan Performance Report each year so the public is aware of how funds are being used and whether outcomes are being achieved. In addition, the Treasury Department will provide comprehensive public transparency reports using the project and expenditure reports that recipients are required to provide.
• User friendly: SLFRF reporting includes improvements requested by recipients of CARES Act funding, including deadlines 30 days after the close of the reporting period (versus 10 days in CARES), streamlined requirements for smaller funding recipients, and increased availability of bulk upload capabilities.
• Focused on recovery: The SLFRF reporting guidance addresses priority areas for an equitable economic recovery, including provisions that prioritize equity, focus on economically distressed areas, support community empowerment, encourage strong labor practices, and spotlight evidence-based interventions.

For more information about the Reporting Guidance and the SLFRF, visit Treasury Department’s Coronavirus State and Local Fiscal Recovery Funds website.

ARPA allocations
Signed into law on March 10, the $1.9 trillion American Rescue Plan, the latest round of federal stimulus funds, provides billions in relief for state and local governments across the country. For Massachusetts, the ARPA provides $2 billion for municipalities and $1.34 billion for counties.

On June 1, the Executive Office for Administration and Finance’s Federal Funds Office released a spreadsheet with total allocation amounts for all Massachusetts municipalities.

Massachusetts has only five functioning county government structures among the state’s 14 counties.

Where county government has been abolished (Berkshire, Essex, Franklin, Hampden, Hampshire, Middlesex, Nantucket, Suffolk and Worcester), the county’s share of funds will initially be allocated to the state and then redistributed to the county’s communities on a per capita basis. These counties will receive approximately $945 million of the county allocations designated for Massachusetts.

Functioning counties in Massachusetts (Barnstable, Bristol, Dukes, Norfolk and Plymouth) will receive their allocation directly from the Treasury Department, through the same process used for counties nationwide. These counties will receive approximately $393 million of the county allocations for Massachusetts.

Baker-Polito administration officials report that they have also applied to the Treasury on behalf of the communities in non-functioning counties, and await further clarification about when to expect those funds.