As a reminder, under the American Rescue Plan Act (ARPA), non-entitlement cities (NEUs) that received funds from the federal government are required to submit reports to the Treasury Department. The first report is due on April 30, 2022. Below are steps
you can take now as well as resources you can access to ensure you are prepared to submit your report before the deadline.
As a reminder, a non-entitlement city is a city that received its ARPA funds through the state and not directly from Treasury.
Create a Login.gov account and assign reporting roles to city staff
To access the Treasury reporting portal, city staff must have a Login.gov account set up. A key step in accessing the portal is determining your city’s account administrator. By default, this role was assigned to the individual who accepted federal funding on behalf of the city.
To assign a different account administrator for your city, the individual currently assigned to that role should process the change in Treasury’s portal, following the instructions outlined on page 3 of the user guide.
If you run into issues, please contact Treasury directly at COVIDReliefITSupport@treasury.gov.
Below are two additional resources that you may find helpful as you create Login.gov accounts and assign roles:
Create a SAM.gov account for your city
If your city already has a SAM.gov account, you do not need to register again with SAM.gov. You will need to provide Treasury with your unique entity ID during the ARPA reporting process.
If your city does not have a SAM.gov account, begin the process now. This is a free service provided by the federal government. You can access SAM.gov registration portal here. You are required to provide Treasury with your unique entity ID during the ARPA reporting process.
Upload signed documents
As a part of your first report to Treasury, you will also need to submit the following documents:
- Copy of the signed award terms and conditions agreement (which was signed and submitted to the state as part of the request for funding)
- Copy of the signed assurances of compliance with Title VI of the Civil Rights Act of 1964 (which was signed and submitted to the state as part of the request for funding)
- Copy of actual budget documents validating the top-line budget total provided to the state as part of the request for funding
If you cannot locate the award terms and conditions agreement or the Title VI compliance assurances submitted to the state last year, you can find copies of those documents using the links below:
How cities can spend ARPA funds
As a reminder, cities are allowed to spend ARPA dollars under the following categories:
- Replace lost public sector revenue
- Respond to the public health and negative economic impacts of COVID-19
- Provide premium pay for essential workers
- Invest in water, sewer, and broadband infrastructure
Please be aware that under the final rule published by Treasury, cities are allowed to claim a standard allowance of up to $10 million in lost revenues without needing to provide documentation of lost revenues or complete the Treasury lost revenue calculator. The standard allowance for lost revenues option is the most flexible option available as well as the option with the least amount of reporting requirements.
For more information on the standard allowance for lost revenues, please review Treasury’s final rule overview.
Examples of ARPA projects and programs
In Washington, we have many cities that have already begun using ARPA funds to benefit their communities. You can read more about the work they are doing here.
Treasury webinars are available
Treasury has recorded two trainings specifically for non-entitlement cities. We strongly encourage you to review these trainings as soon as possible:
Questions?
As you have questions, we encourage you to refer to Treasury’s website,
the final rule, and the overview of the final rule.
If you have general questions or need additional assistance, please contact Treasury at SLFRP@treasury.gov.
Cities are also welcome to contact Jacob Ewing, AWC Legislative Policy Analyst, with general questions.