The Department of the Treasury is expected to follow up its March-issued updated FAQs on the American Rescue Plan’s State and Local Fiscal Recovery Program with further guidance on how counties and local governments will be expected to handle reporting and compliance requirements.
The 107-page
“In the coming months, we will be updating our reporting and compliance guidance to help recipients understand how to report information for the implementation of these new FAQs,” said James Bond, policy advisor and outreach lead for the Department of Treasury’s SLFRF program. “It would be helpful to throw it back to you all to get additional feedback and details about what kind of information would be helpful and what are some concrete examples you’re contemplating when thinking about how to report,” he added. “Feel free to chime in on that.”
Included in that upcoming guidance will be information on how counties and local governments should go about closing out their SLFRF awards and how to complete a final report related to that.
Considerable time during the discussion was paid to how counties can use the federal dollars for personnel costs, which applies to those eligible positions outlined in the 2022 final rule and must apply to roles established before the obligation deadline on Dec. 31, 2024. The FAQs help to detail some flexibility within that.
“What the FAQs outline is that if you do have an excess amount of funding, say for the estimates in the personnel costs, you actually have the ability to reclassify funds to other eligible costs under the 2022 final rule provided by Treasury,” said Eryn Hurley, director of government affairs for the National Association of Counties. “As long as you don’t add any sort of positions, you are still able to cover those personnel costs.”
Personnel costs can include salary and wages, covered benefits and payroll taxes. Funds may also be used to cover a specific position, established before the obligation deadline, if the specific person leaves that job and is replaced and may also continue to pay for someone in the job that was promoted.
For those counties that use the funds to cover personnel costs, reporting requirements include estimating the exact costs, provide a reasonable justification for the costs to be spent on personnel and report that to Treasury by Jan. 31, 2025 if the county has a population greater than 250,000 or has received more than $10 million in SLFRF funds. If the specific county doesn’t meet those thresholds, it must report to Treasury by April 30, 2025.
If a county has excess funds after it has completed estimates for personnel costs, it must allocate them to another eligible use under the SLFRF program, or else return those funds back to Treasury. Those costs also must be incurred by the obligation deadline at the end of 2024.