Treasury to open portal on Monday, April 3 ahead of ARPA Project and Expenditure Report April 30 deadline

Key Takeaways

All counties must submit an American Rescue Plan Act (ARPA) State and Local Coronavirus Fiscal Recovery Fund (Recovery Fund) Project and Expenditure (P&E) Report to the U.S. Department of the Treasury (Treasury) by April 30, 2023. These required, periodic reports provide Treasury with financial and current performance information on projects using Recovery Funds. To help counties navigate the reporting process, the Treasury has released several resources that answer many of counties’ most common questions. 

The Project and Expenditure Report User Guide takes counties step-by-step through the reporting portal and gives more details on what information Treasury wants for some programmatic questions. The guide includes screenshots of the Treasury Portal, showing counties what questions they can expect to answer for each project. This document is a supplement to Treasury’s compliance and reporting guidance.

For the April P&E Reports, Treasury announced new information that counties are required to submit: These updates apply to all counties unless a county allocated its entire ARPA allocation towards the $10 million revenue loss standard allowance.

The P&E Report updates include:

1. Unique Entity ID Requirements for Subrecipients and Contractors: All subrecipients and contractors are required to have a Unique Entity ID (UEI) and have that number included as part of the reporting process. The UEI is the replacement for the previously used DUNS numbers, and they are issued by SAM.gov. While this requirement is not new, starting in April 2023’s P&E Report the report form will now return an error when no valid UEI is provided when creating new Subrecipient or Contractor entities. This was previously not explicitly required, but strongly urged by Treasury. 
   • ​​​Treasury has stated that for the April 2023 P&E reporting form, if a pre-existing subrecipient or contractor record does not have a UEI, the system will simply flag it as a warning but not prevent them from submission of the entire P&E report.
   • However, ANY NEW subrecipient or contractor records will be required to have their UEIs provided and they cannot create those entities without one.
   • Treasury has stated they DO NOT KNOW how long they will be able to keep this flexibility available after April 2023 so counties should get their UEIs together ASAP.
      
2. New Subaward/Direct Payments Entity Type: All Subawards/Direct Payments records will be required to have an “entity type” selected before a subaward can be created. This field will capture whether the entity receiving the award or payment is a Subrecipient, Contractor, or Beneficiary. If a county attempts to create a new subaward for a subrecipient without a populated entity type field, it will result in an error. 

For more information, please see Treasury’s Recipient Compliance and Reporting Guidance page.