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US Treasury Releases ARPA Pre-Award Requirements

Posted on April 21, 2021 by Dene Westbrook

Late last week, the US Treasury Department released the pre-award requirements that local governments will need to comply with in order to receive their allocated payments from Treasury for the Coronavirus State & Local Fiscal Recovery Fund in a timely fashion.  These requirements are similar to what local units needed to follow to access the CARES dollars that were distributed last year.

The following text was taken from the US Treasury webpage and provides the pre-award criteria to follow for municipalities that have been classified as Metropolitan Cities according to the ARPA (those cities that will receive a direct payment from Treasury) and those cities, villages, and townships that are classified as Non-Entitlement Units of Local Government that will receive their funds following pass-through from the state budget.  All League members should note that US Treasury has not finalized allocations or final classifications for cities and expect to have necessary spending guidance out in the coming weeks.

Prior to the formal launch of the Coronavirus State and Local Fiscal Recovery Funds Program, those entities that are eligible to receive a direct payment of funds from Treasury under the program should prepare certain information in advance as outlined below. By undertaking these preparatory steps, eligible entities will be better positioned to receive payments from Treasury in a more timely manner after the program is launched.
Direct payment from Treasury will be made to:

  • States (defined to include the District of Columbia)
  • Territories
  • Tribal governments
  • Counties
  • Metropolitan cities

All Federal financial assistance recipients must have a Data Universal Numbering System (DUNS) number and an active registration with the System for Award Management (SAM) database at SAM.gov. As a result, all eligible entities receiving direct payment from Treasury under the State and Local Fiscal Recovery Funds Program will need a DUNS number and an active SAM registration to receive payment. The DUNS and SAM registration process may take several business days to complete. Therefore, Treasury recommends that eligible entities begin those registration processes if they have not already completed them.

As soon as possible, these governments should take the steps below.

  1. Ensure the entity has a valid DUNS number. A DUNS number is a unique nine-character number used to identify an organization and is issued by Dun & Bradstreet. The federal government uses the DUNS number to track how federal money is allocated. A DUNS number is required prior to registering with the SAM database, which is outlined below. Registering for a DUNS number is free of charge.
    If an entity does not have a valid DUNS number, please visit https://fedgov.dnb.com/webform/ or call 1-866-705-5711 to begin the registration process.
  2. Ensure the entity has an active SAM registration. SAM is the official government-wide database to register with in order to do business with the U.S. government. All Federal financial assistance recipients must register on SAM.gov and renew their SAM registration annually to maintain an active status to be eligible to receive Federal financial assistance. There is no charge to register or maintain your entity SAM registration.
    If an entity does not have an active SAM registration, please visit, SAM.gov to begin the entity registration or renewal process. Please note that SAM registration can take up to three weeks; delay in registering in SAM could impact timely payment of funds.
    Click here for a quick overview for SAM registration
  3. Gather the entity’s payment information, including:
    • Entity Identification Number (EIN), name, and contact information
    • Name and title of an authorized representative of the entity
    • Financial institution information (e.g., routing and account number, financial institution name and contact information)

Eligible Non-entitlement Units of Local Government will receive a distribution of funds from their respective state government. “Non-entitlement units of local government” are defined in 42 U.S.C. 5302(a)(5) that are not metropolitan cities. For these Non-entitlement units of local government, Treasury will allocate and pay funds to state governments, and the state will distribute funds to non-entitlement units of local government in proportion to population. Non-entitlement units must have a valid DUNS number to meet reporting the requirements under the program. If an entity does not have a valid DUNS number, please visit https://fedgov.dnb.com/webform/ or call 1-866-705-5711 to begin the registration process.

Program guidance for the Coronavirus State and Local Fiscal Recovery Fund will be released in the coming weeks. Please continue to check this website for further updates.

Communities are encouraged to track updates from US Treasury and the National League of Cities as new guidance and estimates are prepared. Additionally, last week Treasury announced the formation of a new Office of Recovery Programs to assist with the implementation of many of the federal stimulus programs. The Office of Recovery Programs will oversee programs authorized through the CARES Act, the Consolidated Appropriations Act of 2021, and the American Rescue Plan Act, as well as other legislation. These programs include the State and Local Fiscal Recovery Fund, Emergency Rental Assistance, the Homeowner Assistance Fund, the State Small Business Credit Initiative, the Capital Projects Fund, the Coronavirus Economic Relief for Transportation Services (CERTS) Program, the Payroll Support Program, the Coronavirus Relief Fund and the Airline and National Security Loan Program.  Additional information on this new office is expected in the coming weeks.

Chris Hackbarth is the League’s director of state & federal affairs. He can be reached at 517-908-0304 and chackbarth@mml.org.

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