Guidance for Counties with Project and Expenditure Report due January 31, 2022
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Tier 1 and 2 Recovery Fund County Recipients: Your Project and Expenditure Report is due on January 31, 2022
The U.S. Department of Treasury (Treasury) released the Project and Expenditure Report User Guide to be used by counties to submit data associated with the Recovery Fund. The following counties are required to submit a Project and Expenditure (P&E) Report to Treasury by January 31, 2022:
- Counties with populations that exceed 250,000 residents (referred to as Tier 1 recipients)
- Counties that received more than $10 million in Recovery Funds with populations below 250,000 residents (referred to as Tier 2 recipients)
To determine your county’s status, please look in the Treasury’s Compliance and Reporting Guidance, page 13.
If you county is Tier 1 or Tier 2, NACo strongly recommends filing by the deadline, January 31, 2022. Filing by the deadline will eliminiate your county’s risk of noncompliance. Completing the report as early as possible will ensure your county will not be considered late, which may lead to a finding of non-compliance.
The best source of information on how to submit reports is the User Guide, which contains detailed submissions instructions and includes answers to frequently asked questions (FAQs) for reporting.
Importantly, Treasury has been clear that most submitted information is revisable in your subsequent quarterly report due in April 2022.
Several NACo members have noted key questions about information required in the Treasury’s P&E Reporting Portal. Please see below for the FAQs and Treasury’s suggestions on how to proceed.
If your county has neither obligated nor expended any Recovery Funds
If your county has not yet identified any projects to report, please know that maintaining a project list is a core requirement of the Recovery Fund program. For the Project and Expenditure Report due January 31, 2022, Treasury will be offering an option to select “No Projects to Report” at this time. Selecting this option will require providing a written explanation and may result in additional compliance follow-up from Treasury.
If your county has not decided whether or not to take the $10 million revenue loss standard allowance
First, the Project and Expenditure Report does not build on the information of recipient’s Interim Report, unless you choose to import that information.
Second, if your county has not yet decided whether or not to take the standard allowance, Treasury will not commit them to their reported choice in the January 31st report. Decisions made in the reporting around the standard allowance as part of the January 31 P&E Report may be changed in the April 2022 P&E Report when the Final Rule takes effect. More guidance on this will be released by Treasury as we approach April. If your county has nothing to report in the Revenue Replacement section, you may they may enter “$0” in the required fields and use the description box to explain why you haven’t allocated funds under revenue loss and will update their response in future reporting cycles. Treasury may choose to follow up in these cases for further details.
US Treasury Portal Screen Shot
Process recommendation for jurisdictions who have used or plan to use Revenue Loss (6.1):
Revenue Loss (6.1) – This is a required input, but the Treasury will not commit recipients to their reported choice in the January 31 P&E Report. Decisions made in the reporting around the standard allowance as part of the January 31 P&E Report may be changed in the April P&E Report when the Final Rule takes effect.
If your county has projects with transactions above $50,000
Treasury requires that all projects identify information for each subaward or direct payment of federal funding greater than $50,000. However, Treasury is using the term “subrecipient” to include the contractor relationship (I.e. purchase orders, delivery orders, blanket purchase agreement, definitive contract, etc.) as well as any grants, loans, direct payments or transfers. Said plainly, Treasury goes beyond the definition of subrecipient in Uniform Guidance. See the below screen shot for a description of all transaction types considered “subaward types” for portal reporting purposes.
NACo recommends recipients proceed with inputting financial information by project by selecting a category of subaward, which is a broad range of types of expenditures, though not necessarily subawards as defined in Uniform Guidance 2 CFR 200.92.
US Treasury Portal Screen Shot
