U.S. Capitol Building with a dramatic sky

On Feb. 28, 2022, the U.S. Department of the Treasury updated the Compliance and Reporting Guidance to reflect the Final Rule and made modifications to required reporting. Highlights include:

  • Re-shuffling of Expenditure Categories – This is significant because each Fiscal Recovery Fund (FRF) project must be charged to a single, specific Expenditure Category. Entities will need to check the Expenditure Categories they have been using presently to make sure the category still exists and that the number is unchanged. If a change has occurred, they will need to select a new Expenditure Category or modify the number.
  • New programmatic data – Some Expenditure Categories require reporting on specific programmatic data. The programmatic data reporting requirements are greatly changed in the revised reporting guidance. Entities will need to review each Expenditure Category they are utilizing to make sure they collect the required data. New eligibility and reporting requirements were created for capital expenditures outside of the Infrastructure Expenditures Category.
  • Non-Entitlement Units (NEUs) with awards over $10 million must report quarterly – Previously, NEU’s (regardless of award amount) prepared Project and Expenditure Reports annually.

If they have not already done so, NEUs should take steps to access the U.S. Treasury reporting portal and upload the Terms and Conditions and Title VI compliance and budget documents provided to their state government when requesting the ARPA award. Entities should also register on SAM.gov. SAM.gov registration is not required to gain access to the portal and upload the documents. It is required, however, for the Project and Expenditure Report due April 30, 2022.

For more information on how to address capital projects in excess of $1 million and outside of the Infrastructure Expenditure Category, connect with us.

Tom L. Kaleko
Principal, CIPMA
cybersecurity businessman touching web
Next up

SEC proposes improved uniformity and comparability of cybersecurity disclosures