COVID-19 & Pandemic recovery
American Rescue Plan Resources – The U.S. Treasury Department has posted its Interim Final Rule for the Coronavirus State and Local Fiscal Recovery Funds (https://home.treasury.gov/system/files/136/FRF-Interim-Final-Rule.pdf). Treasury has also finalized the amounts that will be distributed to metro (entitlement) communities. The amounts for “non-entitlement units” (NEUs) – the 33 non-metro communities in Rhode Island -- are still being finalized and should be available next week. There are several resources you can use to help determine how funds may be used.
Treasury Department Page --
Update: 6.10.21 https://home.treasury.gov/system/files/136/SLFRPFAQ.pdf
- Includes fact sheet and quick reference guide of allowable uses
- FAQs (which will be updated over time) -- https://home.treasury.gov/system/files/136/SLFRPFAQ.pdf
U.S. Treasury’s COVID-19 Economic Relief Page – Other information about assistance programs for businesses, workers, etc. -- https://home.treasury.gov/policy-issues/coronavirus
- REMINDER: There is a link on the right side of this page (“Receive Updates”) that allows you to sign up for email updates from Treasury on COVID-19 programs.
National League of Cities’ ARP FAQs – In addition to National League of Cities’ main information page on the American Rescue Plan (https://www.nlc.org/covid-19-pandemic-response/), they have a page of frequently asked questions, which will be updated as additional guidance is issued -- https://www.nlc.org/covid-19-pandemic-response/arp-local-relief-frequently-asked-questions/
Government Finance Officers Association –
- Guidance FAQ -- https://www.gfoa.org/cslfrf-guidance-faq -- Includes topics like certification, eligible uses, reporting & audit
- Overview of American Rescue Plan – https://www.gfoa.org/cslfrf-guidance-faq -- Brief oversight of ARP and key programs
National League of Cities’ Briefing on Local Fiscal Recovery Funds – NLC leadership and staff held a member briefing on May 12, 2021 with their initial analysis of the Treasury’s guidance on the Local Fiscal Recovery Fund. The slides and recording for that presentation are available at https://www.nlc.org/resource/from-the-event-coronavirus-local-fiscal-recovery-fund-treasury-dept-guidance-call/. Below are some key items they mentioned:
- Generally speaking, the goal of the Interim Final Rule is to provide flexibility to local governments in responding to the impacts of COVID-19 while encouraging a strong economic recovery.
- The Pandemic Response category of eligible uses includes direct COVID-19 costs, but also behavioral health/addiction treatment, health disparities and survivor benefits
- The Economic Impacts category includes individual and business assistance, industry/worker assistance, housing and community development, homelessness, childcare and education
- To address the disproportionate impacts of COVID-19 on economically disadvantaged populations, local officials will have greater leeway in using funds for programs/projects/investments targeted to Qualified Census Tracts (https://www.huduser.gov/portal/datasets/qct.html). Spending outside QCTs is authorized for many categories, but for those projects, communities may need to demonstrate the impact of COVID-19 and why the program addresses those impacts. The NLC presentation has a framework that officials can use to demonstrate that linkage.
- Premium pay is an allowable use, but it must be for those performing “essential work,” defined as work involving regular in-person interactions or regular physical handling of items that were also handled by others. (It appears that those working remotely do not qualify.) There are also limits on how much may be provided per worker. For more information, see pg. 45 – 51 of the Interim Final Rule and questions 28-30 in the Treasury FAQ.
- The Infrastructure category includes water, sewer and broadband, as in law. Projects that are approved under the Clean Water/Drinking Water State Revolving Fund are eligible uses. Other uses include cybersecurity, climate change/resilience and lead service line replacement.
- The Lost Revenue language allows cities and towns to use ARP funds for lost revenue. The methodology is explained in the rule, but the general concept is that ARP funds may be used for the difference between actual general revenues and what the estimated revenues would have been without the pandemic. ARP funds may be used for revenue replacement through 12/31/2023.
- ARP funds may NOT be used for federal matching requirements; pensions; infrastructure not directly addressed in ARPA; and rainy day funds, financial reserves and outstanding debt.
NOTE: NLC is trying to get Treasury to allow ARP funds to replenish rainy day funds or reserves that were used to avoid layoffs, etc.
- Metro recipients must submit an interim report and quarterly reports thereafter; non-entitlement units do not have the interim and quarterly reports but will have to submit an annual report.