What Counties Need to Know: ARPA SLFRF Non-Compliance Next Steps

Since in March 2021, the American Rescue Plan Act (ARPA) authorized the $350 billion State and Local Coronavirus Fiscal Recovery Fund (SLFRF), which provided $65.1 billion in direct, flexible aid to every county, parish and borough in America. Now that we are four years into the program’s implementation, compliance with reporting requirements is of utmost importance.

Now that the Dec. 31, 2024 obligation deadline has passed, the U.S. Department of Treasury (Treasury) is focused on ensuring all SLFRF prime recipients – including counties – are complying with reporting and eligible use requirements. 

Below is a list of frequently asked questions (FAQs) for counties about how to stay compliant: 

1. What happens if my county is not in compliance?

If your county is out of compliance — for example, if you missed submitting required reports or used funds on ineligible expenses — Treasury has been instructed to begin recoupment proceedings, and letters of recoupment are already being sent.

If your county remains out of compliance, you will be required to repay the SLFRF funds awarded to you under ARPA.

2. What should my county do if we’re not in compliance?

If you know you are behind, you must act now: 

• Submit your 2024 P&E Report ASAP.
• If you remain noncompliant when the 2025 report opens, Treasury has been instructed to begin full recoupment proceedings. 

3. We haven’t reported in a few years, and I can’t access 2022 or 2023 reports. How do I know which reports I need to fill out?

ARPA SLFRF reports are cumulative, meaning, if you submit the 2024 report (currently open in the Treasury portal) you will be brought back into compliance.

4. We’ve had staff turnover. How do I get access to the account?

• If you have access to your county’s Account Identifier – ensure that you have an active Login.gov account and input the Account Identifier and county’s zip code at portal.treasury.gov/compliance.
• If you don’t have access to your County’s Account Identifier – reach out to ehurley@naco.org and NACo will work directly with Treasury to get you set up quickly.

5. I am having an issue with the Treasury portal and cannot submit my report. What do I do?

Email SLFRF@treasury.gov and copy NACo (ehurley@naco.org). In your email, include your full name, your county’s name, a description of your issue and screenshots. This will help Treasury solve the issue faster. Please DO NOT submit multiple emails as this will backup Treasury’s email inbox.

6. I’ve already received a letter of recoupment. What can I do now?

If you are receiving a letter because you are out of compliance due to reporting, submit the 2024 report immediately.
For help, contact your state association of NACo at questions@naco.org. 

7. I’ve received an Information Document Request (IDR) from the Department of Treasury. What am I supposed to do?

An Information Document Request means that Treasury needs more details to confirm compliance. Respond to their request promptly and thoroughly and provide clear documentation.

For more information, see Treasury’s video on the subject here.

8. My county spent all of its funds already. Do we still need to submit reports?

Yes. Even if funds are fully spent, you must continue submitting P&E Reports until Treasury officially closes out your award.

For annual reporters, the 2025 report is due April 30, 2025. For quarterly reporters, the Q1 report was due on January 31, 2025, and the Q2 report is due on April 30, 2025.

Treasury and the Office of Management and Budget (OMB) are working on final closeout instructions, but until those are issued, counties must continue to report.

9. What happens if my county hasn’t obligated all of its funds?

The obligation deadline (12/31/2024) has passed.

• If your county has unobligated funds and is not taking Revenue Replacement, those funds must be returned to the federal government.
• If your county is claiming Revenue Replacement (up to $10 million per entity), you can report that in your April 2025 report, including how the funds will be used.

10. Do I need to submit a 2025 report now that I’m back in compliance?

Yes. To stay compliant, you must submit the 2025 report. Failing to do so will return your county to non-compliance and could trigger recoupment.

11. Do you have any resources on how to fill out the reports?

Yes. Visit NACo’s ARPA Resource Hub that includes all the latest information and resources.

Counties must take steps now to resolve outstanding compliance and reporting issues. If you’re unsure of your status, log in and check, or contact Treasury for help at SLFRF@treasury.gov.