Last week, the U.S. Department of Treasury released updated Reporting Guidance on their website. All recipients of State and Local Fiscal Recovery Funds (SLFRF) award grants received an email Monday about the updated guidance. Please see the analysis from the League’s federal partner, the National League of Cities (NLC).
1. The Treasury Department rearranged the reporting tiers in the Compliance and Guidance Reporting document from six to five. Starting after April 30, 2022, Non-entitlement units of government (NEUs) with a grant of more than $10 million will have to report on a quarterly basis instead of yearly. NLC estimates that this could affect 163 NEUs nationally. Additionally, NLC caught an interesting line that appears in the document. "The total SLFRF allocations across all sources for a given jurisdiction will be used to identify that jurisdiction's Reporting Tier, beginning in April of 2022. Treasury may reach out to jurisdictions to update Reporting Tiers." NLC has asked for clarity on exactly what Treasury means and if a local government receives SLFRF monies from a county or state above their initial allocation if that could change their reporting tier.
2. In the final rule, local governments can make an irrevocable decision as to whether it will take the $10 million standard allowance or use the lost revenue calculation. Municipalities must decide in their April 30, 2022, report which option it is electing.
3. To facilitate reporting, each NEU will need a NEU Local Government Number. This is a unique identification code for each NEU assigned by the State or territory to the NEU as part of its request for funding.
4. For municipalities that must file quarterly reports, quarterly reports will cover one calendar quarter and must be submitted to the Treasury by the last day of the month following the end of the period covered. This is a change from the Treasury's previous position. Under the old rules, a quarterly filer had 30 calendar days after the end of each calendar quarter to file a report.
5. The Treasury added a new piece of required information that applies to all local governments. Local governments should report the program income earned and expended to cover eligible project costs, if applicable.
6. This is in older versions of the Compliance and Reporting Guidance but is worth repeating. Local governments do not need to submit separate monthly sub-award reports to FSRS.gov as required pursuant to the 2 CFR Part 170, Appendix A.
7. Local governments should also note that sub-recipients do not include individuals and organizations that received SLFRF funds as end-users. Such individuals and organizations are beneficiaries and not subject to audit pursuant to the Single Audit Act and 2 C.F.R. Part 200, Subpart F.
8. A local government must provide detailed information to the Treasury if aid is provided to impacted industries other than tourism, and hospitality.
a. Describe if the industry experienced at least 8 percent employment loss from pre-pandemic levels, or if the industry is experiencing comparable or worse economic impacts than national tourism, travel, and hospitality industries as of the date of the final rule, and rationale for providing aid to the industry.
i. For each sub-award, the local government will need to provide the sector of the employer (Note: additional detail, including list of sectors, to be provided in the user guide posted to www.treasury.gov/SLFRP)
ii. Purpose of funds (e.g., payroll support, safety measure implementation)
9. The Treasury Department will require local governments that pursue water and sewer projects to provide additional reporting data once the project starts.
a. If a local government chooses a water and sewer project listed in expenditure categories 5.1-5.18 (a list of 5.1-5.18 can be found in the Appendix 1, seen below), it will need to provide:
- Median Household Income of service area (Collection to begin in April 2022)
- Lowest Quintile Income of the service area (Collection to begin in April 2022)
We encourage you to review this information with your municipal manager and CFO.
Contact: Paul Penna, Senior Legislative Analyst, firstname.lastname@example.org or 609-695-3481, x110.