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SPOTLIGHT

ARPA reporting deadline approaching

By Kayla Carter Smith, Policy Analyst
Project and Expenditure Report due April 30, 2022 for all counties.

All counties who received funding from the American Rescue Plan Act (ARPA) Fiscal Recovery Fund must submit a Project and Expenditure Report through the U.S. Treasury portal by April 30, 2022. 

Counties which received less than $10 million must submit their first Project and Expenditure Report by the April 30 deadline and will submit annually thereafter. The first report will cover the period from March 3, 2021 to March 31, 2022. 

Counties which received more than $10 million should have submitted their first Project and Expenditure Report by January 31, 2022 and must submit their next quarterly report by the April 30 deadline. 

Reporting Revenue Loss

The Final Rule, which was released in January, simplified reporting requirements for many counties by allowing a standard allowance of up to $10 million in revenue loss, not to exceed the total award. Counties wishing to designate all or a portion of their funds as revenue loss, are required to make a one-time decision on the April report to either calculate revenue loss according to the formula or elect to take the standard allowance.

If a county elects to take the standard allowance, they will be required to report the amount of revenue loss they are taking and a description of how revenue loss funds were allocated to government services. 

 

Revenue Loss FAQ

What do counties need to include in their description under revenue loss?

The description of government services may be a narrative or in another form, and counties are encouraged to report based on their existing budget processes and to minimize administrative burden. For example, a county with $100 in revenue replacement funds available could indicate that $50 were used for personnel costs and $50 were used for pay-go building of sidewalk infrastructure.

Can counties recategorize obligations previously reported under a different category on the Interim Report to revenue loss?

Yes, counties can recategorize their previously obligated funds to the revenue loss eligible use category to account for all funds under revenue loss. 

Do counties who have projects under the Revenue Loss category need to report on subrecipients, subawards, and expenditures?

Counties who have projects categorized under revenue loss are not required to report on the subrecipients, subawards, and expenditures (for subawards or in aggregate) for those projects for the April 2022 report.


General FAQ

What records must be kept by governments receiving funds?

Financial records and supporting documents related to the award must be retained for a period of five years after all funds have been expended or returned to Treasury, whichever is later. This includes those records which demonstrate the award funds were used for eligible purposes in accordance with sections 602(c) and 603(c) of the Social Security Act, Treasury’s regulations implementing those sections, and Treasury’s related guidance.

Can records be edited or updated after submission? How do I report changes?

Recipients will have an opportunity to reopen and provide edits to their submitted Project and Expenditure Reports anytime before the reporting deadline. Recipients will then be required to re-certify and submit the report again to properly reflect any edits made. 

Is there a penalty for not submitting timely reports? 

A record of late reporting could lead to a finding of non-compliance, which could result in development of a corrective action plan or other consequences. 

For more information on the April Project and Expenditure Report refer to Treasury’s User Guide which can be accessed here.

Watch a video here from Treasury, including step-by-step instructions on reporting lost revenue.

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