On June 17, the U.S. Department of Treasury (Treasury) released reporting and compliance requirements for the State and Local Fiscal Recovery Fund (Recovery Fund). The Recovery Fund, authorized under the American Rescue Plan Act, provides $65.1 billion in direct and flexible aid to every county in America and offers opportunities for crucial investments in local communities.

The guidance is split into two sections – General Guidance and Reporting Requirements – and provides additional detail and clarification for counties’ compliance and reporting responsibilities under the Recovery Fund program.

The General Guidance section outlines counties’ responsibilities when reporting expenditures of Recovery Funds and Treasury’s expectations and recommended best practices where appropriate under the SLFRF program.

The second section, Reporting Guidance, outlines the three different reports that counties are required to complete when reporting on Recovery Fund investments:

• Interim Report: All counties that received an allocation from Treasury must provide an initial overview of the status and uses of funding. This is a one-time report. The deadline to submit the interim report to Treasury is August 31, 2021.
• Project and Expenditure Report: Report on projects funded, expenditures, contracts and sub-awards over $50,000, and other information. Counties that received more than $5 million in Recovery Funds are required to submit these reports quarterly to Treasury, whereas counties that received less than $5 million in Recovery Funds must submit these reports on an annual basis. The deadline to submit the first report is October 31, 2021.
• Recovery Plan Performance Report: The Recovery Plan Performance Report will provide information on the projects that large recipients are undertaking with program funding and how they plan to ensure program outcomes are achieved in an effective, efficient, and equitable manner. It will include key performance indicators identified by the recipient and some mandatory indicators identified by Treasury. Only counties with populations of 250,000 residents and above are required to submit Recovery Plan Reports. The deadline to submit the first report is August 31, 2021.

In addition to clarifying each type of report outlined above, Treasury provides useful distinctions for the Recovery Fund reporting and compliance requirements from what was required of the CRF as well.

NACo strongly suggests counties continue submitting comments for the record in response to Treasury’s Interim Final Rule on the Recovery Fund to ensure the county voice is reflected in the public comments when it comes time to finalize the rule. The deadline to submit comments is July 16, 2021.