Upcoming American Rescue Plan reporting deadline extended to 2022

Oct 20, 2021

The U.S. Department of the Treasury is expected to provide further instructions at a later date, including an update to existing guidance and a user guide.

The U.S. Department of the Treasury extended the first State and Local Fiscal Recovery Funds Project and Expenditure Report reporting deadline to next year. The funds, which were provided through the American Rescue Plan Act (ARPA), originally had an Oct. 31, 2021 reporting deadline.

Award recipients now have until Jan. 31, 2022, to submit their Project and Expenditure Report. As a result, the report must cover the period between the award date and Dec. 31, 2021. For non-entitlement cities — local governments typically serving a population under 50,000 — the report is due on April 30, 2022, and will need to cover the period between the award date and March 31, 2022.

Key program principles

The Treasury Department has outlined the following key principles for expenditures that serve as guidelines for successful implementation and reporting:

  • Recipients and sub-recipients are the first lines of defense and are responsible for ensuring that funds are not used for ineligible purposes, and that there is no fraud, waste, and abuse associated with their State and Local Fiscal Recovery Funds award. 
  • Many Recovery Fund projects respond to the COVID-19 public health emergency and meet urgent community needs. Swift and effective implementation is vital, and recipients must balance facilitating simple and rapid program access widely across the community and maintaining a robust documentation and compliance regime. 
  • Recovery Fund projects should advance shared interests and promote equitable delivery of government benefits and opportunities to underserved communities, as outlined in Executive Order 13985: On Advancing Racial Equity and Support for Underserved Communities Through the Federal Government. 
  • Transparency and public accountability for the awarded funds and the use of such funds are critical to upholding program integrity and trust in all levels of government. Recovery funds should be managed consistent with Administration guidance per Memorandum M-21-20 and Memorandum M-20-21.

Additionally, the Treasury Department clarified that there are no plans to use the ID.me system for non-entitlement city (NEU) reporting at this time, a concern that many smaller cities have raised. The department stated, "We are working on rolling out an alternative, more user-friendly method for NEUs to login to the Treasury portal, and guidance will be developed in the near future."

The Treasury Department is expected to provide further instructions at a later date, including an update to existing guidance and a user guide. For more information about the American Rescue Plan Act, please visit Cal Cities’ regularly updated Guide to Local Recovery portal.