Information for NEUs. Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1)Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2)Follows an appointment made in accordance with a non-Federal entitys laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and. American Rescue Plan Act of 2021: Allowable Costs and Cost Principles (Including Sample Policy and Implementation Tools), -Boards of Mental Health, Developmental Disabilities, & Substance Abuse, -Affordable Housing & Minimum Housing Codes, -Professional Responsibility for Government Attorneys, Purchasing, Construction, Property Transactions, -Purchasing / Purchase Contracts / Purchase Orders, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 CFR Part 200, Assistance Listing: Coronavirus State and Local Fiscal Recovery Funds, US Treasury State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, Subpart C, Pre-Federal Award Requirements and Contents of Federal Awards, Subpart D, Post Federal; Award Requirements, Individual Time and Effort Certification Form_Sample, Accessibility: Report a Digital Access Issue, and the use is an enumerated (safe harbor) project, Written Justification required but recipients are not required to submit as part of regular reporting to Treasury. Recipients of Federal financial assistance from the Treasury are required to meet legal requirements relating to nondiscrimination and nondiscriminatory use of Federal funds. T o apply, you must submit a grant application online during the program's open application period. Funds will be available to child care providers in the form of: Licensed Child Care Stabilization Grant Commented [CO10]: Tool Tip: Amount of ARPA Child However, we have to read this provision in context with the ARP law and Final Rule. (3)Is determined and supported as provided inparagraph (i)of this section, when applicable. Treasury intends to provide additional guidance regarding program income and the application of 2 CFR 200.307(e)(1). Allocable. Many local governments will use their ARP/CSLFRF funds fro capital expenditures. (6)Cognizant agencies for indirect costs are encouraged to approve alternative proposals based on outcomes and milestones for program performance where these are clearly documented. The ARPA grant program is administered at the federal level by the Institute of Museum and Library Services (IMLS). Los Angeles | Expenditures of ARP/CSLFRF Funds continue to be subject to most of the federal Uniform Guidance provisions, including those related to Cost Prinicples/Allowable Costs discussed below. Each project must fit within a single Expenditure Category, as defined in US Treasurys Final Rule. | Careers Campus Box 3330 ARPA dashboard. The Uniform Guidance outlines the requirements that pertain to program income at 2 CFR 200.307. Cherry Bekaert LLP is a licensed CPA firm that provides attest services, and Cherry Bekaert Advisory LLC and its subsidiary entities provide tax and advisory services. Jersey City | Further, costs must be reasonable and allocable as outlined in 2 CFR 200.404 and 2 CFR 200.405. Ongoing monitoring of any given subrecipient should reflect its assessed risk and include monitoring, identification of deficiencies, and follow-up to ensure appropriate remediation. (For example, a specific roadmap for standard allowance local governments looking to spend their full allotment on salaries and benefits.) It also will identify grey areas that may require further legal scrutiny before finalizing expenditure decisions. And I strongly recommend that you have any sample (or example) policy reviewed by your local attorney. Basic parameters were set by Congress and the Department of Health and Human Services for eligibility and conditions of receiving the funding. It will include a detailed look at the various UG provisions and sample policies. Who is eligible? This blog post is for educational and informational use and may be used for those purposes without permission by providing acknowledgment of its source. Such systems may include, but are not limited to, random moment sampling, rolling time studies, case counts, or other quantifiable measures of work performed. And it should incorporate appropriate documentation and oversight measures. Thus, non-profit or private organizations should seek funds from CSFRF/CLFRF recipient(s) in their jurisdiction (e.g., a State, local, territorial, or Tribal government). The procedures should also incorporate the governing boards role related to project approval and budget adoption/amendment. Nashville | As an example, the Infrastructure Investment and Jobs Act provides that SLFRF funds may be used to meet the non-federal match requirements of authorized Bureau of Reclamation projects and certain broadband deployment projects. See 2 CFR 200.413. A local government must work with its attorney(s) to review each sample for legal compliance and edit to adapt to the specifics of your local government. MS Child Care Stabilization Grant: Eligibility, FAQs, Award Calculation, Application Process, and Application Guide Note: Application and Application Guides are available in English, Spanish, and Vietnamese on this page. Planning, Preparing and Complying with the American Rescue Plan Act of 2021 (ARPA) Grant Administration Program. A local government is free to engage in those capital expenditures without further process or approval, was long as they are consistent with the eligibility requirements of the category. On March 11, 2021, President Biden signed the American Rescue Plan Act (ARPA) of 2021 into law. As such, the State Library used federal guidelines to develop a fair plan of distribution that maximized spending flexibility while adhering to the overall spirit and priorities of the legislation. Please review the Final Rule to learn more about the updated CSLFRF program requirements. Per 2 CFR Part 200.303, your organization must develop and implement effective internal controls to ensure that funding decisions under the SLFRF award constitute eligible uses of funds, and document determinations. The process does not utilize a single form or national "clearinghouse" through which providers apply for funds. A one-size-fits-all policy may work on paper, but it will not work in practice. First, your organization must clearly identify to the subrecipient: (1) that the award is a subaward of SLFRF funds; (2) any and all compliance requirements for use of SLFRF funds; and (3) any and all reporting requirements for expenditures of SLFRF funds. Chapel Hill, NC27599-3330 The latest COVID-19 relief package provides $1.9 trillion in mandatory funding, program changes and tax policies aimed at mitigating the continuing effects of the pandemic. To browse a complete catalog of School of Government publications, please visit the Schools website at www.sog.unc.edu or contact the Bookstore, School of Government, CB# 3330 Knapp-Sanders Building, UNC Chapel Hill, Chapel Hill, NC 27599-3330; e-mail sales@sog.unc.edu; telephone 919.966.4119; or fax 919.962.2707. It may take a few reads to put all the pieces together. The entities falling under the Cherry Bekaert brand are independently owned and are not liable for the services provided by any other entity providing services under the Cherry Bekaert brand. Be ready. The ARP/CSLFRF explicitly authorizes local governments to use ARP/CSLFRF funds to make certain capital expenditures (e.g necessary water, wastewater, and broadband infrastructure, certain affordable housing, general government capital expenditures under the revenue replacement category, etc.). (b)Reasonableness. It will be equally problematic from a compliance standpoint to have a policy your unit cannot or does not follow than to not have one at all. Finally, in addition to my colleagues Rebecca Badgett, who drafted some of the above UG policies, and Connor Crews, who is working on procurement and conflict of interest policies, we want to thank our two amazing research assistants, Tiffany Oliva and Abby Gostling, who drafted several of our templates and other tools. Update: On January 6, 2022, the U.S. Department of the Treasury issued the Final Rule, which governs the eligible uses of Coronavirus State and Local Fiscal Recovery Funds (SLFRF) under the American Rescue Plan Act (ARPA). If a local government does not have a NICRA (or chooses not to use its NICRA), it may elect to use the de minimis rate of 10 percent of the modified total direct costs(MTDC). (viii)Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A)The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B)Significant changes in the corresponding work activity (as defined by the non-Federal entitys written policies) are identified and entered into the records in a timely manner. Weights include: To achieve the American Rescue Plan Acts purposes with respect to Grants to States, this funding is to be used by September 30, 2022, in helping communities respond directly and immediately to the pandemic, as well as to related economic and community needs through equitable approaches. Due to this, all providers wishing to receive a Stabilization Subgrant must submit a new application. Spending priorities are as follows: First, to enable libraries to reach residents with internet hotspots, accessible Wi-Fi, and other digital inclusion efforts, particularly in support of education, health, and workforce development. For construction procurement, the Federal guidelines say that a request for competitive . Please click here for GFOA's analysis of ARPA. ARPA includes a provision appropriating an additional $200 million for IMLS to carry out . 2000d-1 et seq., and the Departments implementing regulations, 31 CFR part 22; Section 504 of the Rehabilitation Act of 1973 (Section 504), Public Law 93-112, as amended by Public Law 93-516, 29 U.S.C. New Orleans | We also will be holding at least two courses this spring: April 4, 2022: Basics of ARP/CSLFRF and UG for Local Government Attorneys and Grant Managers. Completed forms submitted via email (preferred) to Manager of Grants and Special Projects Debbie Hall, or via USPS. A cost is reasonable when, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. In the Final Rule, US Treasury did establish a process for evaluating certain capital expendituresspecifically those that fall within the responding to the COVID-19 public health crisis and its negative economic impact category. Depending on state and local requirements, cities can then develop a scope and select a procurement instrument. | Privacy Policy ARPA) 2021-2022. https://canons.sog.unc.edu/2021/08/american-rescue-plan-act-of-2021-arp-us-treasurys-reporting-requirements-and-deadlines/, https://canons.sog.unc.edu/2021/06/budgeting-for-american-rescue-plan-act-funds/, https://canons.sog.unc.edu/2021/06/american-rescue-plan-act-of-2021-arp-local-government-expenditures-of-arp-funds-for-general-government-purposes/, https://canons.sog.unc.edu/2021/12/american-rescue-plan-act-of-2021-allowable-costs-and-cost-principles-including-sample-policy-and-implementation-tools/. Come with your questions and share your experiences and insights with colleagues across the State. Ive highlighted several cost items that likely will be of particular importance to local governments. Funds may be used for allowable expenses incurred prior to the grant period (i.e., you can reimburse yourself for allow-able expenses that you already had prior to receiving the grant). These records must: (i)Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii)Be incorporated into the official records of the non-Federal entity; (iii)Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHEs definition of IBS); (iv)Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entitys written policy; (v)Comply with the established accounting policies and practices of the non-Federal entity; and. ); 45 CFR Parts 98 and 99; The American Rescue Plan (ARP) Act of 2021 (Public Law 117-2) . Recipients that receive an aggregate amount of federal financial assistance in a given fiscal year that exceeds the Single Audit threshold are subject to the requirements in 2 CFR 200 Subpart F, Audit Requirements, unless otherwise specified in program-specific guidance. SLFRF funds transferred to subrecipients are also subject to reporting and Uniform Guidance requirements. 794; Title IX of the Education Amendments of 1972 (Title IX), 20 U.S.C. Cost principles apply to cost items, which are the specific cost objects or functions. The Child Care Stabilization Subgrant Program is funded by ARPA. https://canons.sog.unc.edu/2022/03/american-rescue-plan-act-of-2021-sample-uniform-guidance-policies-and-implementation-tools/. AHCCCS submitted a spending plan for . All rights reserved. The UG requirements are in addition to those imposed by the Final Rule related to project eligibility. 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