On April 27, the U.S. Department of the Treasury (Treasury) released a new Frequently Asked Questions (FAQs) document applicable to the Final Rule of the Coronavirus State and Local Fiscal Recovery Fund (Recovery Fund) published in January 2022. This new FAQs document includes several answers to questions associated with and unique to the Final Rule as well as modified answers to questions previously covered in the Interim Final Rule FAQs document.

Of note, the Final Rule FAQs document includes new and substantially updated information regarding claiming the $10 million revenue loss standard allowance. Counties are required to make the one-time, irrevocable election to either utilize the standard allowance or calculate actual revenue loss in the project and expenditure report due on April 30, 2022. The Final Rule FAQs also clarifies that counties do not have to demonstrate actual revenue loss to claim the standard allowance, how revenue is defined in relation to calculating actual revenue loss, and what constitutes as a government service and is, therefore, an eligible expense under this category.  

Additionally, the Final Rules FAQs has an entirely new section related to the federal Uniform Guidance (2 CFR Part 200) that recipients must adhere to in the provision of ARPA Recovery Funds, including Cost Principles and Single Audit requirements, and provides updated information on new flexibilities for counties and eligible expenditures under the Final Rule.  

NACo will provide a more in-depth analysis of the Final Rules FAQs in the coming days.

Additional Resources

• NACo Blog: Treasury ARPA Project and Expenditure Reports due April 30 – Important information for counties
• NACo Webinar: Part 1: U.S. Treasury Webinar on Reporting Guidelines for the State and Local Fiscal Recovery Funds
• NACo Webinar: Part 2: Overview of U.S. Treasury Webinar on Project and Expenditure Reports for ARPA Recovery Funds – Overview of Revenue Replacement Reporting