April 3, 2024

ARPA/SLFRF Reporting Deadline Remains Unchanged

Many cities received an email from the US Department of Treasury that may cause confusion about the next deadline for cities to report ARPA State and Local Fiscal Recovery Fund (SLFRF) expenditures. Despite the Treasury’s email announcing new guidance in the updated FAQs, a vast majority of Kentucky cities are not affected.

The Treasury’s email applies only to those SLFRF recipients who will report eligible administrative costs as an expenditure. If administrative costs associated with SLFRF funds extend beyond Dec. 31, 2024, the recipient reporting deadline is extended. For the nine cities that report quarterly, the deadline to report estimated administrative costs is July 31, 2024. For the remaining cities that report annually, the deadline for reporting estimated administrative costs extending beyond Dec. 31, 2024, is the April 2025 report period.

As previously stated, most cities will not be affected by this change unless the city intends to claim administrative costs associated with SLFRF funds. For example, some cities retained consultants to assist with the reporting and compliance requirements of SLFRF funds. If a recipient incurs obligations that extend through Dec. 31, 2026, the consultant contracts that assist in reporting and compliance may continue as well.

In another city, the city clerk may oversee SLFRF reporting and compliance. SLFRF funds can be used to pay the percentage of the city clerk’s salary equal to the amount of time dedicated to administering SLFRF funds. If the city has a capital project with construction contracts that extend beyond the Dec. 31, 2024, obligation deadline, then the clerk’s SLFRF administration duties will likewise extend. In that case, the portion of the clerk’s salary dedicated to the administration of SLFRF funds for the duration of the contract period should be estimated for the April 2025 report period.

Many cities have obligated and spent all SLFRF funds by Dec. 31, 2024. If no additional reporting or compliance work is required after Dec. 31, 2024, the deadline extension for reporting administrative costs will not affect the city.

The Treasury is hosting webinars on May 8 and May 9, 2024, to explain the Nov. 2023 clarification on the definition of “obligation” as it pertains to SLFRF funds and other guidance. You can register for the webinars at the below links:

Date: May 8, 2024
Time: 10:00am-11:30am ET / 9:00am-10:30am CT 

Date: May 9, 2024
Time: 1:00pm-2:30pm ET / 12:00pm-1:30pm CT

For questions on ARPA/SLFRF or any other municipal law matters, please contact the KLC Department of Municipal Law.