What Counties Need to Know: ARPA reporting requirements for program income

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Eryn Hurley

Eryn Hurley

Managing Director, Government Affairs & NACo Federal Fellowship Initiative
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Paige Mellerio

Legislative Director, Finance, Pensions & Intergovernmental Affairs | Local Government Legal Center

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Key Takeaways

 On May 20, the U.S. Department of Treasury (Treasury) distributed a memo to counties that received American Rescue Plan Act (ARPA) State and Local Fiscal Recovery Fund (SLFRF) dollars. Both quarterly and annually reporting recipients who reported their 2025 annual report with $0 obligated or had program income in their most recently submitted report received this communication.  

If your county received this communication and/or obligated all or more of your allocation, you can log into the reporting portal so you can make edits to the report and re-submit by Friday, May 23, 2025. 

ACTION IF NEEDED:  Review the program income definition and how the Treasury guidance applies to your award to determine if your government earned program income that should be reported. 

  • If the Program Income reported is correct, no further action is needed.
  • If the Program Income reported is not correct, please update your report.

Remember: Treasury defines program income (FAQ 13.11) as money earned as a direct result of a federal award. This can include fees for services, rental income from project-acquired property, or revenue from selling items created by the project. Interest earned on advances of Federal funds is not considered program income.

HOW TO UPDATE REPORT: 

The memo from Treasury provides instruction on how to make revisions through the reporting portal. If recipients reported in error, the communication states that recipients can make updates by logging into the reporting portal and re-submit by Friday, May 23, 2025

The communication to annually reporting recipients contains links to join office hours if they require additional support in correcting this potential error.

 

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