American Rescue Plan Act Guidance from the Office of Budget and Management (OBM)
The Ohio Office of Budget and Management held a Local Government Update informational webinar last Thursday, June 24, 2021, on very recently released Compliance and Reporting Guidance for the American Rescue Plan Act (ARPA) State and Local Fiscal Recovery funding.
- Counties (Direct from U.S. Treasury)
- Metropolitan Cities (Direct from U.S. Treasury) municipalities with populations of at least 50K using a modified Community Development Block Grant formula
- Non-Entitlement units of local government or NEUs (Passed through the State) municipalities with populations of less than 50K based on each jurisdiction’s percentage of the state’s population
- The Office of Budget & Management will assist eligible NEUs with registering for funding in order to meet Treasury requirements. This process will begin once SB111 is enacted. Once registration is open, the OBM website portal at https://grants.ohio.gov/fundingopportunities.aspx will be open for 60 days.
- Please contact the OBM office for follow-up questions related to registration for Non-Entitlement Units (NEU) at email@example.com. For authoritative guidance, contact the U.S. Treasury at SLFRP@treasury.gov.
Below are a few takeaways that may be helpful:
- General infrastructure projects are NOT allowable unless funded as a government service with revenue reduction amounts, or it responds to a specific pandemic-related public health need, or it responds to a specific negative economic impact
- Eligible Water/Sewer Infrastructure projects are defined by what is eligible under the Clean Water State Revolving Fund or the Drinking Water State Revolving Fund
- For Water/Sewer Infrastructure projects NEPA does not apply to this funding
- For eligible Water/Sewer/Broadband Infrastructure projects, pre-project development does qualify if occurs from March 3, 2021, on
- Can only be used for project costs incurred starting March 3, 2021 – through December 31, 2024. Must obligate funds by the 2024 deadline, but the performance period to finish up projects goes through December 31, 2026
- Can be used on eligible projects planned or started prior to March 3, 2021, with the limitation only eligible for invoices/work done on the project after the March 3, 2021 date. (Forward-looking activity only from that March 3, 2021 date.)
- Can NOT be used as non-federal match for other federal grant programs
- Transfer funds are considered a sub-recipient (and they must exist within the county borders) a few examples include villages, fire departments, non-profits
- Reporting requirements expanded from Coronavirus Relief Fund to three types: interim report, project/expenditure reports (including annual reports due Oct 31), recovery plan performance report
- Expenditures under $50K use Aggregate Reporting
- OBM is tracking NEU Recipient Number after they register
- 60+ expenditure categories, OBM advises to assign categories at the beginning of the project and track them separately
- Latest guidance defined “General Revenue” and a 4-step process/formula for calculating General Revenue Loss calculations
To view the webinar slides on-demand click here. The webinar will soon be posted for on-demand viewing here. FAQs from US Treasury are HERE for additional context to the rule (and this document is updated frequently).