Treasury has outlined additional programmatic data that counties must provide on their next Project and Expenditure Report Counties need to submit a written justification for certain capital expenditures projects Large counties should note changes to required information on the upcoming Recovery Plan
The American Rescue Plan Act authorized the State and Local Fiscal Recovery Funds (Recovery Fund) program, which provides counties $65.1 billion in direct, flexible aid to respond to the effects of the COVID-19 pandemic. As part of the conditions for accepting these funds, counties must submit regular Project and Expenditure (P&E) Reports detailing how Recovery Funds are obligated and spent. In advance of the upcoming reporting deadline, the U.S. Department of Treasury (Treasury) has released new reporting guidance that counties must follow when submitting their next P&E Report.
Counties that have a population of more than 250,000 residents and/or received more than $10 million in Recovery Funds must submit quarterly P&E Reports. Those with populations below 250,000 residents and/or that received less than $10 million in Recovery Funds are required to only submit annual P&E Reports. However, these changes to Treasury’s reporting guidance affect all counties, regardless of size or Recovery Fund allocation.
Key updates to the Compliance and Reporting Guidance outlined by Treasury include:
- Additional programmatic data for capital expenditures: When using Recovery Funds for capital expenditures projects, counties need to report the type of expenditure based on a list of enumerated uses. Examples of enumerated uses are COVID-19 vaccination sites, job and workforce training centers, and public health data systems. A full list of enumerated uses is available on pages 27 to 28 of the updated guidance.
- Written justification for capital expenditures: Counties are required to provide a written justification for capital projects of any category that cost at least $10 million and for projects in the “other” (i.e., project not explicitly enumerated by Treasury) category that cost at least $1 million. Previously, counties needed to create a written justification for these projects but were not required to submit them as part of regular reporting.
- Description of labor requirements for capital expenditures: Counties are required to provide additional labor reporting. For projects that cost at least $10 million, counties will need to report on the strength of the project’s labor standards, including information on the presence of a project labor agreement, community benefits agreement, prevailing wage requirement, or local hiring. This new required information is outlined under Infrastructure Project on pages 30-31 of the updated guidance.
- Project information for broadband projects: The updated guidance requires counties to provide detailed project information for broadband infrastructure investments. Counties need to report what kind of technology is involved in the project (i.e., fiber optic cables, coaxial cables, etc.), the total miles of fiber deployed over the project, and the total number of funded locations served broken out by both speed of connection and type of location (i.e., residential, business, or community). This new required information is outlined under Broadband Projects on pages 32-33 of the updated guidance.
- Moving of Recovery Plan Performance Report data into P&E Report: Under the updated guidance, some of the data that was previously only required for the Recovery Plan Performance Report (Recovery Plan) is now required for large counties (i.e., populations above 250,000 and/or above $10 million in awards) on their quarterly P&E Report. For example, large counties investing in housing security programs must now report the number of households receiving eviction prevention services. A full list of changes to programmatic data requirements for large counties is available on page 33 of the compliance and reporting guidance.
- Updated template for Recovery Plan: The updated guidance also provides a template for the Recovery Plan due for large counties on July 31, 2022, reflecting the expenditure categories and other changes made by the Final Rule.
