In a welcomed clarification, Treasury recently issued an update on the American Rescue Plan Act (ARPA) Interim Final Rule (IFR) process.

In the statement, Treasury affirmed that proper spending made under the IFR will not be subject to recoupment:

“Until Treasury adopts a final rule and the final rule becomes effective, the Interim Final Rule is, and will remain, binding and effective. This means that recipients can and should rely on the Interim Final Rule to determine whether uses of funds are eligible under this program…Funds used in a manner consistent with the Interim Final Rule while the Interim Final Rule is effective will not be subject to recoupment.”

It remains unclear when the final rule for ARPA will be made available. We encourage city leaders to continue to use the IFR as a guide when making decisions on how to spend ARPA funds.

For more information, please refer to the Treasury’s website or contact Jacob Ewing.