PSATS has received many questions recently on the American Rescue Plan funds, when to expect new regulations, and when and where townships will need to report on the use of these funds. Here are a few updates:
Reporting: Municipalities with populations of less than 50,000 (non-entitlement units) are required to file one report each year, an annual report due on October 31, beginning with October 31, 2021. Reports will cover the timeframe of October 1-September 30 (the federal fiscal year). Your first report will cover from the time you received the funds until September 30. We know that the report will be made online to Treasury, but few details have been released to date. Treasury is expected to provide a user’s guide for this report by the end of September.
Note that states, counties, and municipalities with populations of more than 50,000 are required to file additional reports, such as interim and quarterly reports.
Final Regulations: In May, the U.S. Treasury released an Interim Final Rule on the use of the funds and compliance. Treasury asked for comments on the rule and received a significant amount of input, including a lengthy letter submitted by PSATS. Since the July 16 deadline for comments, Treasury has been working on a new rule, which is expected to be released by October. To date, additional guidance has provided more flexibility and direction on the use of funds, but the final rule could also be more restrictive.
PSATS will notify our members once Treasury releases the final rule, as well as the users’ guide for the annual report, and will provide direction on these documents.
PSATS Advice: Because of the reporting period for the first annual report ends September 30 and the final rules for the use of the funds have not yet been released, townships may want to consider waiting until after October 1 to spend any funds to simplify the first report and ensure that funds are properly spent.
Learn more: If your township is trying to determine allowable uses under the Interim Final Rule, we recommend that you review the rule itself, as well as the Frequently Asked Questions provided by Treasury that further explain the allowable uses. In addition, township officials should review the Compliance and Reporting Guidance provided by Treasury. When reading these documents, particularly the Compliance and Reporting Guidance, be careful to only read those sections that apply to non-entitlement units (NEUs) if your population is less than 50,000. Note that larger municipalities and counties have different reporting requirements than NEUs. At the request of members, PSATS is working on a checklist to assist with project eligibility.
PSATS Premier Partner: While PSATS cannot guarantee that a particular project will meet program requirements, PSATS’ new Premier Partner, Zelenkofske Axelrod LLC, will work with your township to find eligible uses for the funds that benefit your community and help you navigate federal compliance and reporting requirements. The company can guarantee that an eligible use meets the program requirements and ensure that your documentation is complete. There is an additional fee for this service, which is an eligible use of the ARP funds, and the company is offering discounted pricing to PSATS members. To learn more, contact Pat Kirk at firstname.lastname@example.org or Cory Johnson at cjohnson@ zallc.org or call (717) 561-9200, ext. 5300