HomeMy WebLinkAbout21- Grant Subrecipient Agreement - ARPA Household Efforts Sub Award - Family Promise
FY 2022/2023 Subrecipient Grant Agreement – ARPA Household
Efforts Page 1
GRANT SUBRECIPIENT AGREEMENT
AMERICAN RESCUE PLAN HOUSEHOLD EFFORTS SUB AWARD
THIS AGREEMENT is made and entered into this 24th day of November, 2021 by and between
the City of Bozeman, Montana, a self-governing municipal corporation located at 121 N. Rouse
Ave., Bozeman MT 59771 (“City”) as GRANTOR and Family Promise of Gallatin Valley, a non-
profit located at 429 E Story St, Bozeman, MT 59715 as SUBRECIPIENT.
WHEREAS, on October 17, 2005 the Bozeman City Commission adopted Resolution No. 3866
establishing policies for the granting of funds from the City of Bozeman to a requesting entity;
and
WHEREAS, Family Promise submitted a proposal to the City for a program that complies with
the term of the American Rescue Plan for household assistance efforts for $75,630; and
THE PARTIES AGREE:
1. The Sub Award. The City will award and release to SUBRECIPIENT a sum of up to
seventy-five thousand six hundred and thirty dollars ($75,630) from its American Result
Plan Act (ARPA) award [name of fund] Fund, (the “Grant”) pursuant to the payment
terms in Section 3.
2. Use of Funds. Grant funds in the amount of up to seventy-five thousand six hundred
and thirty dollars ($75,630) will be used by SUBRECIPIENT for the sole purpose of
Household aid to families in shelter program, which is a permissible use of ARPA funds,
as described in the proposal submitted by Subrecipient, attached hereto as Exhibit A
and by this reference incorporated herein.
3. Term. Program and expenditures must be performed during the term of the date of
execution of this agreement through June 30, 2023 (FY24).
4. Payment of Funds
a. The agrees to reimburse Subrecipient for costs actually incurred and paid by
Subrecipient in accordance with the Approved Budget attached hereto as Exhibit
B and for the performance of the Approved Services under this Agreement in an
amount not to exceed $75,630 (the “Total Agreement Funds”).
b. The amount of Total Agreement Funds, however, is subject to adjustment by City
if a substantial change is made in the Approved Services that affects this
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Agreement or if this Agreement is terminated prior to the expiration of the
Agreement as provided in Section 3 above. Program funds shall not be
expended prior to the Effective Date, or following the earlier of the expiration or
termination of this Agreement.
c. Costs incurred shall only be as necessary and allowable to carry out the purposes
and activities of the Approved Services and may not exceed the maximum limits
set in the Approved Budget.
d. Expenses charged against the Total Agreement Funds shall be incurred in
accordance with the American Rescue Plan and the Federal Treasury’s guidance,
Office of Budget and Management Guidance, and City purchasing policies.
e. Invoices. On or before the twentieth (20th) day of each month and in any event
no later than thirty (30) days after the earlier of the expiration or termination of
this Agreement, Subrecipient shall submit invoices, in a form supplied by City, for
the most recent month ended, to City, setting forth actual expenditures of
Subrecipient in accordance with this Agreement. Within ten (10) working days
from the date it receives such invoice, City may disapprove the requested
compensation. If the compensation is so disapproved, City shall notify
Subrecipient as to the disapproval. If payment is approved, no notice will be
given.
f. Subrecipient may request the Grant funds during the fiscal year ending June 30,
2022 and June 30, 2023 as needed by providing proof of expenses paid.
Acceptable forms of proof of payment shall be as determined in the sole
discretion of the City’s Director of Finance.
g. Any funds from the sub award not awarded during the fiscal year ending June
30, 2023 will remain in the City’s ARPA Fund and will be available for other
appropriation.
5. Subrecipient Representations
a. SUBRECIPIENT has familiarized itself with the nature and extent of this
Agreement and with all local conditions and federal, state and local laws,
ordinances, rules, and regulations that in any manner may affect Subrecipient’s
performance under this Agreement. Specific Treasury Guidance attached in
Exhibit B.
b. SUBRECIPIENT represents and warrants to City that it has the experience and
ability to perform its obligations under this Agreement; that it will perform said
obligations in a professional, competent and timely manner and with diligence
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and skill; that it has the power to enter into and perform this Agreement and
grant the rights granted in it; and that its performance of this Agreement shall
not infringe upon or violate the rights of any third party, whether rights of
copyright, trademark, privacy, publicity, libel, slander or any other rights of any
nature whatsoever, or violate any federal, state and municipal laws. The City will
not determine or exercise control as to general procedures or formats necessary
for SUBRECIPIENT to meet this warranty.
c. SUBRECIPIENT represents and warrants to City that the Grant funds are
necessary to accomplish the financial requirements of the Economic Impact
Response- Childcare subsidies, unexpected household expenses and Financial
Coaching.
d. SUBRECIPIENT shall maintain a financial management system and financial
records and shall administer funds received pursuant to this Agreement in
accordance with all applicable federal and state requirements. Subrecipient
shall adopt such additional financial management procedures as may from time
to time be prescribed by City if required by applicable laws, regulations or
guidelines from its federal and state government funding sources. Subrecipient
shall maintain detailed, itemized documentation and records of all income
received and expenses incurred pursuant to this Agreement.
e. Any item of expenditure by Subrecipient under the terms of this Agreement
which is found by auditors, investigators, and other authorized representatives
of City, the City’s external Auditor, the U.S. Government Accountability Office or
the Comptroller General of the United States to be improper, unallowable, in
violation of federal or state law or the terms of the Notice of Prime Award or this
Agreement, or involving any fraudulent, deceptive, or misleading
representations or activities of Subrecipient, shall become Subrecipient’s
liability, to be paid by Subrecipient from funds other than those provided by City
under this Agreement or any other agreements between City and Subrecipient.
This provision shall survive the expiration or termination of this Agreement.
f. In any fiscal year in which Subrecipient expends $750,000 or more in federal
awards during such fiscal year, including awards received as a subrecipient,
Subrecipient must comply with the federal audit requirements contained in the
Uniform Guidance, [45 CFR Part 75], including the preparation of an audit by an
independent Certified Public Accountant in accordance with the Single Audit Act
Amendments of 1996, 31 U.S.C. 7501-7507, and with Generally Accepted
Accounting Principles. If Subrecipient expends less than $750,000 in federal
awards in any fiscal year, it is exempt from federal audit requirements, but its
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records must be available for review by City and appropriate officials.
Subrecipient shall provide City with a copy of Subrecipient’s most recent audited
financial statements, federal Single Audit report, if applicable (including financial
statements, schedule of expenditures of federal awards, schedule of findings and
questioned costs, summary of prior audit findings, and corrective action plan, if
applicable), and management letter within thirty (30) days after execution of this
Agreement and thereafter within nine (9) months following the end of
Subrecipient’s most recently ended fiscal year.
g. Final payment request(s) under this Agreement must be received by City no later
than thirty (30) days from the earlier of the expiration date or termination date
of this Agreement. No payment request will be accepted by City after this date
without authorization from City. In consideration of the execution of this
Agreement by City, Subrecipient agrees that acceptance of final payment from
City will constitute an agreement by Subrecipient to release and forever
discharge City, its agents, employees, representatives, affiliates, successors and
assigns from any and all claims, demands, damages, liabilities, actions, causes of
action or suits of any nature whatsoever, which Subrecipient has at the time of
acceptance of final payment or may thereafter have, arising out of or in any way
relating to any and all injuries and damages of any kind as a result of or in any
way relating to this Agreement. Subrecipient’s obligations to City under this
Agreement shall not terminate until all closeout requirements are completed to
the satisfaction of City. Such requirements shall include, without limitation,
submitting final reports to City and providing any closeout-related information
requested by City by the deadlines specified by City. This provision shall survive
the expiration or termination of this Agreement.
6. Cooperation in Monitoring and Evaluation.
a. City Responsibilities. City shall monitor, evaluate and provide guidance and
direction to Subrecipient in the conduct of Approved Services performed under
this Agreement. City has the responsibility to determine whether Subrecipient
has spent funds in accordance with applicable laws, regulations, including the
federal audit requirements and agreements and shall monitor the activities of
Subrecipient to ensure that Subrecipient has met such requirements. City may
require Subrecipient to take corrective action if deficiencies are found.
b. Subrecipient Responsibilities.
i. Subrecipient shall permit City to carry out monitoring and evaluation
activities, including any performance measurement system required by
applicable law, regulation, funding sources guidelines or by the terms and
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conditions of the applicable Notice of Prime Award, and Subrecipient
agrees to ensure, to the greatest extent possible, the cooperation of its
agents, employees and board members in such monitoring and
evaluation efforts. This provision shall survive the expiration or
termination of this Agreement.
ii. Subrecipient shall cooperate fully with any reviews or audits of the
activities under this Agreement by authorized representatives of City, the
U.S. Government Accountability Office or the Comptroller General of the
United States and Subrecipient agrees to ensure to the extent possible
the cooperation of its agents, employees and board members in any such
reviews and audits. This provision shall survive the expiration or
termination of this Agreement.
7. Reports/Accountability/Public Information. SUBRECIPIENT must allow the City, its
auditors, and other persons authorized by the City to inspect and copy its books and
records for the purpose of verifying that monies provided to SUBRECIPIENT pursuant to
this Agreement were used in compliance with this Agreement and all applicable
provisions of federal, state, and local law. SUBRECIPIENT will retain such records for
seven years after receipt of final payment under this Agreement unless permission to
destroy them is granted by the City. SUBRECIPIENT shall not issue any statements,
releases or information for public dissemination without prior approval of the City.
8. Permits and Compliance With Laws. Subrecipient will obtain, in a timely manner, all
required permits, licenses and approvals, and will meet all requirements of all local,
state and federal laws, rules and regulations which must be obtained or met in
connection with construction of the Project
9. Independent Contractor Status. The parties agree that SUBRECIPIENT, its agents,
employees, contractors, or subcontractors, are independent contractors for purposes of
this Agreement and are not to be considered employees or agents of the City for any
purpose. SUBRECIPIENT and its agents, employees, contractors, or subcontractors, are
not subject to the terms and provisions of the City’s personnel policies handbook and
may not be considered a City employee for workers’ compensation or any other
purpose. SUBRECIPIENT, its agents, employees, contractors, or subcontractors, are not
authorized to represent the City or otherwise bind the City in any way.
10. Default and Termination. If SUBRECIPIENT fails to comply with any condition of this
Agreement at the time or in the manner provided for, the City may terminate this
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Agreement if the default is not cured within fifteen (15) days after written notice is
provided to SUBRECIPIENT. The notice will set forth the items to be cured. If this
Agreement is terminated pursuant to this Section, SUBRECIPIENT will repay to the City
any Grant funds already delivered to SUBRECIPIENT for the Economic Impact Response-
Childcare subsidies, unexpected household expenses and Financial Coaching.
11. Limitation on SUBRECIPIENT’s Damages; Time for Asserting Claim
a. In the event of a claim for damages by SUBRECIPIENT under this Agreement,
SUBRECIPIENT’s damages shall be limited to contract damages and
SUBRECIPIENT hereby expressly waives any right to claim or recover
consequential, special, punitive, lost business opportunity, lost productivity, field
office overhead, general conditions costs, or lost profits damages of any nature
or kind.
b. In the event SUBRECIPIENT wants to assert a claim for damages of any kind or
nature, SUBRECIPIENT must first provide City with written notice of its claim, the
facts and circumstances surrounding and giving rise to the claim, and the total
amount of damages sought by the claim, within ninety (90) days of the facts and
circumstances giving rise to the claim. In the event SUBRECIPIENT fails to
provide such notice, SUBRECIPIENT shall waive all rights to assert such claim.
12. Representatives
a. City’s Representative. The City’s Representative for the purpose of this
Agreement shall be Anna Rosenberry or such other individual as City shall
designate in writing. Whenever approval or authorization from or
communication or submission to City is required by this Agreement, such
communication or submission shall be directed to the City’s Representative and
approvals or authorizations shall be issued only by such Representative;
provided, however, that in exigent circumstances when City’s Representative is
not available, SUBRECIPIENT may direct its communication or submission to
other designated City personnel or agents and may receive approvals or
authorization from such persons.
b. SUBRECIPIENT’s Representative. SUBRECIPIENT’s Representative for the
purpose of this Agreement shall be Christel Chvilicek or such other individual as
SUBRECIPIENT shall designate in writing. Whenever direction to or
communication with SUBRECIPIENT is required by this Agreement, such direction
or communication shall be directed to SUBRECIPIENT’s Representative; provided,
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however, that in exigent circumstances when SUBRECIPIENT’s Representative is
not available, City may direct its direction or communication to other designated
SUBRECIPIENT personnel or agents.
13. Indemnity/Waiver of Claims/Insurance. To the fullest extent permitted by law,
SUBRECIPIENT agrees to defend, indemnify and hold the City and its agents,
representatives, employees, and officers (collectively referred to for purposes of this
Section as the City) harmless against all third party claims, demands, suits, damages,
losses, and expenses, including reasonable defense attorney fees, which arise out of,
relate to or result from SUBRECIPIENT’s (i) negligence, or (ii) willful or reckless
misconduct.
Such obligations shall not be construed to negate, abridge, or reduce other rights or
obligations of indemnity that would otherwise exist. The indemnification obligations of
this Section must not be construed to negate, abridge, or reduce any common-law or
statutory rights of the indemnitee(s) which would otherwise exist as to such
indemnitee(s). SUBRECIPIENT’s indemnification obligations under this Section shall be
without regard to and without any right to contribution from any insurance maintained
by City.
Should any indemnitee described herein be required to bring an action against
SUBRECIPIENT to assert its right to defense or indemnification under this Agreement or
under SUBRECIPIENT’s applicable insurance policies required below the indemnitee shall
be entitled to recover reasonable costs and attorney fees incurred in asserting its right
to indemnification or defense but only if a court of competent jurisdiction determines
SUBRECIPIENT was obligated to defend the claim(s) or was obligated to indemnify the
indemnitee for a claim(s) or any portion(s) thereof.
In the event of an action filed against City resulting from the City’s performance under
this Agreement, the City may elect to represent itself and incur all costs and expenses of
suit.
SUBRECIPIENT also waives any and all claims and recourse against the City or its officers,
agents or employees, including the right of contribution for loss or damage to person or
property arising from, growing out of, or in any way connected with or incident to the
performance of this Agreement except “responsibility for his own fraud, for willful injury
to the person or property of another, or for violation of law, whether willful or
negligent” as per 28-2-702, MCA.
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These obligations shall survive termination of this Agreement.
In addition to and independent from the above, SUBRECIPIENT shall at SUBRECIPIENT’s
expense secure insurance coverage through an insurance company or companies duly
licensed and authorized to conduct insurance business in Montana which insures the
liabilities and obligations specifically assumed by SUBRECIPIENT in this Section. The
insurance coverage shall not contain any exclusion for liabilities specifically assumed by
SUBRECIPIENT in this Section unless and to the extent coverage for such liability is not
reasonably available.
The insurance shall cover and apply to all claims, demands, suits, damages, losses, and
expenses that may be asserted or claimed against, recovered from, or suffered by the
City without limit and without regard to the cause therefore and which is acceptable to
the City and SUBRECIPIENT shall furnish to the City an accompanying certificate of
insurance and accompanying endorsements in amounts not less than as follows:
• Workers’ Compensation – statutory;
• Employers’ Liability - $1,000,000 per occurrence; $2,000,000 annual aggregate;
• Commercial General Liability - $1,000,000 per occurrence; $2,000,000 annual
aggregate
The City of Bozeman, its officers, agents, and employees, shall be endorsed as an
additional or named insured on a primary non-contributory basis on the Commercial
General Liability policy. The insurance and required endorsements must be in a form
suitable to City and shall include no less than a thirty (30) day notice of cancellation or
non-renewal. The City must approve all insurance coverage and endorsements prior to
delivery of Grant funds to SUBRECIPIENT. SUBRECIPIENT shall notify City within two (2)
business days of SUBRECIPIENT’s receipt of notice that any required insurance coverage
will be terminated or SUBRECIPIENT’s decision to terminate any required insurance
coverage for any reason.
14. Nondiscrimination and Equal Pay. SUBRECIPIENT agrees that all hiring by Subrecipient
of persons performing this Grant Agreement shall be on the basis of merit and
qualifications. SUBRECIPIENT will have a policy to provide equal employment
opportunity in accordance with all applicable state and federal anti-discrimination laws,
regulations, and contracts. SUBRECIPIENT will not refuse employment to a person, bar a
person from employment, or discriminate against a person in compensation or in a
term, condition, or privilege of employment because of race, color, religion, creed,
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political ideas, sex, age, marital status, national origin, actual or perceived sexual
orientation, gender identity, physical or mental disability, except when the reasonable
demands of the position require an age, physical or mental disability, marital status or
sex distinction.
SUBRECIPIENT represents it is, and for the term of this Agreement will be, in compliance
with the requirements of the Equal Pay Act of 1963 and Section 39-3-104, MCA (the
Montana Equal Pay Act). SUBRECIPIENT must report to the City any violations of the
Montana Equal Pay Act that Contractor has been found guilty of within 60 days of such
finding for violations occurring during the term of this Agreement.
SUBRECIPIENT shall require these nondiscrimination terms of its subcontractors
providing services under this Grant Agreement.
15. Public Meetings and Access to Public Records
a. Meetings of SUBRECIPIENT that pertain to the receipt or expenditure of Grant funds
from the City are subject to the open meeting requirements of Montana law,
including those set forth in Title 7, Chapter 1, Part 41, MCA and Title 2, Chapter 3,
MCA. To ensure compliance, SUBRECIPIENT will provide agendas for meetings that
pertain to the receipt or expenditure of Grant funds covered by this Agreement to
the City Clerk’s office no later than 72 working hours prior to meeting for notice on
the City’s official posting board and any other sites deemed reasonable by the
Clerk’s office. In addition, meeting minutes will be kept by SUBRECIPIENT and
provided to the City Clerk’s office no later than 90 days after the meeting. These
minutes shall be posted and made available to the public by the City Clerk’s office
except for those minutes taken during a closed meeting in accordance with 2-3-203,
MCA. Minutes taken during a closed meeting shall also be provided to the City
Clerk’s office but shall be handled in accordance with the City Clerk’s regular
executive session protocol and kept private in a secured cabinet.
b. In accordance with 7-1-4144, MCA and subject to any applicable legal obligation to
protect and preserve individual confidential or private information, upon reasonable
request and at reasonable times during normal business hours, SUBRECIPIENT shall
make such records available for inspection and copying by members of the public.
SUBRECIPIENT may charge for such copying in accordance with the policies of the
City, which SUBRECIPIENT hereby adopts for such purposes.
c. To determine whether a meeting or part of a meeting may be closed to the public
and to determine whether information contained in SUBRECIPIENT documents is
protected by law from disclosure, SUBRECIPIENT may seek a determination of the
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City Attorney at no cost to SUBRECIPIENT. Such request and determination shall not
create an attorney-client relationship between SUBRECIPIENT and the City.
16. Attorney’s Fees and Costs. In the event it becomes necessary for a party to this
Agreement to retain an attorney to enforce any of the terms or conditions of this
Agreement or to give any notice required herein, then the prevailing party shall be
entitled to reasonable attorney’s fees and costs, including fees, salary, and costs of in-
house counsel to include City Attorney.
17. Integration and Modification. This document contains the entire agreement between
the parties and no statements, promises or inducements made by either party or agents
of either party not contained in this written Agreement may be considered valid or
binding. This Agreement may not be modified except by written agreement signed by
both parties.
18. Dispute Resolution
a. Any claim, controversy, or dispute between the parties, their agents, employees,
or representatives shall be resolved first by negotiation between senior-level
personnel from each party duly authorized to execute settlement agreements.
Upon mutual agreement of the parties, the parties may invite an independent,
disinterested mediator to assist in the negotiated settlement discussions.
b. If the parties are unable to resolve the dispute within thirty (30) days from the
date the dispute was first raised, then such dispute may only be resolved in a
court of competent jurisdiction in compliance with the Applicable Law provisions
of this Agreement.
19. No Assignment. SUBRECIPIENT may not subcontract or assign SUBRECIPIENT’s rights,
including the right to Grant payments, or any other rights or duties arising hereunder,
without the prior written consent of City.
20. No Third Party Beneficiary. The terms and provisions of this Agreement are intended
solely for the benefit of each party and their respective successors and assigns. It is not
the parties’ intent to confer third party beneficiary rights upon any other person or
entity.
21. Choice of Law. This Agreement shall be governed and construed in accordance with the
laws of the State of Montana without regard to conflict of law provisions. The Parties
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agree to submit to the personal and exclusive jurisdiction of the courts located within
Gallatin County, Montana.
22. Non-Waiver. A waiver by either party of any default or breach by the other party of any
terms or conditions of this Agreement does not limit the other party’s right to enforce
such term or conditions or to pursue any available legal or equitable rights in the event
of any subsequent default or breach.
23. Severability. If any portion of this Agreement is held to be void or unenforceable, the
balance of the Agreement shall continue in effect.
24. Counterparts. This Agreement may be executed in counterparts, which together
constitute one instrument.
25. Consent to Electronic Signatures. The Parties have consented to execute this Agreement
electronically in conformance with the Montana Uniform Electronic Transactions Act,
Title 30, Chapter 18, Part 1, MCA.
IN WITNESS WHEREOF, the parties hereto have executed this instrument the day and year
indicated below.
_______________________ Date: __________
Jeff Mihelich, City Manager
City of Bozeman
_______________________ Date: __________
Print name and Title:___________________________
SUBRECIPIENT
Approved as to form:
_______________________ Date: __________
Greg Sullivan, City Attorney
City of Bozeman
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Executive DirectorChristel Chvilicek
11/24/2021
11/29/2021
11/29/2021
FY 2022/2023 Subrecipient Grant Agreement – ARPA Household Efforts
Exhibit
Exhibit A
Program Proposal
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Family Promise of Gallatin Valley Grant Proposal to the City of Bozeman as a Subrecipient of
American Rescue Local Government Funding
September 28, 2021
Executive Summary of the Project
Family Promise of Gallatin Valley’s Emergency Shelter Program, Prevention Program, and
Stabilization Programs uniquely serves low-income households with children. COVID-19 affected
households with children in ways that are specific to the housing challenges found in the Gallatin
Valley. To assist families experiencing homelessness, Family Promise expanded its shelter program,
and in turn, increased direct financial support to families in our shelter programming. We are expecting
to serve 30 families in our shelter program this year. On average, $2,521.00 in direct financial support
is provided per family for their unique needs in their efforts to regain self-sufficiency and independent
housing. In total, this year we expect to provide families with $75,630 in direct financial support to
households affected by the negative economic impacts caused by the COVID – 19 pandemic.
Firm Profile
Since 2006, FPGV has been committed to serving homeless families, and today we remain the only
year-round shelter option for homeless families in the Gallatin Valley. Our mission continues to be
realized every day as we mobilize over 2,000 trained volunteers to deliver transformational programs
that lift families out of the crisis of homelessness and into long term, sustainable housing.
The central component of our programming is our Emergency Shelter Program (ESP) where we offer
shelter for homeless families by coordinating with over 2,000 volunteers that provide evening meals.
We currently have three shelter locations: Roxy’s House at St. James Rectory, Stepping Stones at
Wheat Suites (building owned by HRDC), and the Story House Day Center. The Day Center also
houses our Family Case Manager’s office where families receive intensive case management services,
assistance with completing housing applications, and more. Prior to COVID – 19 all staff members
had offices in the Story House, but in our effort to serve more families, we converted our offices into
bedrooms and secured 13 rooms at Wheat Suites, formerly known as the Rodeway Inn. In just 12
months, we went from serving 4 families at a time in ESP to 19 families at a time. Over the past 15
years, Family Promise has graduated more than 70% of the more than 200 families we served in our
Shelter Program with gainful employment, childcare, and affordable housing.
Once families exit our ESP they enter our Graduated Support Program (GSP) where we aim to continue
our commitment by providing support and services to families, and ultimately, reduce recidivism back
into emergency shelter.
Our Transitional Housing Program (THP) has transformed into 9 units strong, providing a place where
graduated families can call home. Because the valley’s housing market is so tight and even the most
successful families struggle to find housing, it was imperative for FPGV to create a solution that gave
families a chance. THP provides families with the opportunity to stay in our housing for up to two
years while following a graduated rental plan. While all families start off paying a below-market rate,
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rent increases over the length of their 2-year stay. This is a great method for families to establish
savings, create a positive rental history, pay off debts, and establish goals to break down the barriers
of their past. We anticipate our combination of quality, affordable housing, and comprehensive services
will empower homeless families to lead stable and productive lives while providing the necessary
consistency for their children.
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Most Recent Financial Statement Audit report and Management Letter
To Whom It May Concern,
At this time Family Promise of Gallatin Valley has not received an audit, so we cannot
provide a management letter as requested.
We are currently in the bidding process to conduct our first audit for Family Promise
of Gallatin Valley. Bids are due by October 15, 2021. This audit will take place next
fiscal year, which begins July 1, 2022.
We currently operate under a strong set of financial controls, which are included, along
with our financial statements for fiscal year 2020-2021.
Please let me know if you have any questions,
Christel Chvilicek
Executive Director
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Balance Sheet
As of June 30, 2021
Jun 30, 21
ASSETS
Current Assets
Checking/Savings
1 · Operating Funds (nonposting)
1011 · Operating Checking 0.00
1021 · Opportunity Bank Checking 160,562.36
1022 · Opportunity Bank Expense Acc 2,334.80
1023 · Opportunity Bank Savings 100.00
1041 · Expense Cash Account 0.00
1077 · Charles Schwab Short-Term Inv 100,001.57
Total 1 · Operating Funds (nonposting)262,998.73
2 · Reserve Funds
1076 · Charles Schwab Investment Acct 100,002.57
Total 2 · Reserve Funds 100,002.57
Total Checking/Savings 363,001.30
Accounts Receivable
1240 · Grants receivable 154,703.00
1241 · Pledge Receivable 424,589.28
Total Accounts Receivable 579,292.28
Other Current Assets
1299 · Undeposited Funds 50,502.45
1316 · Tenant Receivable 1,926.94
1450 · Prepaid expenses and Deposits 22,440.82
Total Other Current Assets 74,870.21
Total Current Assets 1,017,163.79
Fixed Assets
1600 · South Church Day Center 373,677.81
1602 · Davis-Povah House Property 165,046.41
1603 · Belgrade Cabins 100,000.00
1604 · Marjorie House 250,000.00
1630 · Leasehold improvements 33,591.00
1640 · Furniture, fixtures, & equip 79,042.471650 · Vehicles 36,349.00
1660 · Construction in progress
1661 · Land 358,934.00
1660 · Construction in progress - Other 2,159,554.74
1660 · Construction in progress 2,518,488.74
1760 · Accumulated Depreciation -196,989.37
Total Fixed Assets 3,359,206.06
Other Assets1805 · Pledges Receivable - long term 8,000.00Total Other Assets 8,000.00
TOTAL ASSETS 4,384,369.85
LIABILITIES & EQUITY
LiabilitiesCurrent Liabilities
Accounts Payable
2010 · Accounts payable 11,285.48
Total Accounts Payable 11,285.48
Credit Cards
2060 · Master Card - Lara 0.00
2075 · Mastercard - Jill 0.00
2079 · Mastercard - Christel 0.00
2090 · Visa - Jill 0711 1,130.31
2091 · Visa - Kylie 0653 980.69
2092 · Visa - Emily 0869 386.59
2095 · Visa - Zak 0646 727.72
2096 · Visa - Hanna 0737 207.92
2097 · Visa - Elliott 0877 534.11
2099 · Visa - Christel 0638 1,023.00
Total Credit Cards 4,990.34
Other Current Liabilities
2100 · Payroll Liabilities
2101 · Health, Dental, Vision Payable -3,020.86
2103 · FWH, FICA, Medicare Payable 7,259.58
2104 · SWH, SUTA Payable 2,091.69
2110 · Accrued Paid Time Off payable 6,177.13
2100 · Payroll Liabilities - Other 0.00
2100 · Payroll Liabilities 12,507.54
2135 · SBA Payroll Protection Program 0.00
2136 · SBA EIDL Payable 0.00
2345 · Security Deposits
2346 · Security Deposit - Unit 11 350.00
2347 · Security Deposit - Unit 12 700.00
2348 · Security Deposit-Canterbury 350.00
2349 · Security Deposit-Basement 350.00
2351 · Security Deposit - DP NR 237.04
2352 · Security Deposit-DP SL 350.00
2353 · Security Deposit-North Kennedy 150.02
2354 · Security Deposit - Hope Harbor 350.00
Total 2345 · Security Deposits 2,837.06
2360 · Transitional Housing Liability
2361 · Basement 0.00
2362 · DP Right North 580.00
2363 · DP Left South 1,950.00
2365 · Belgrade Unit 11 0.002366 · Belgrade Unit 12 600.002367 · Canterbury House 0.002380 · Stepping Stone
2380-1 · Myer 100.00
2380-2 · Bear Crane 100.00
Total 2380 · Stepping Stone 200.00
Total 2360 · Transitional Housing Liability 3,330.00
Total Other Current Liabilities 18,674.60
Total Current Liabilities 34,950.42
Long Term Liabilities
2600 · Opp Bank Cons Loan Payable 328,024.32
Total Long Term Liabilities 328,024.32
Total Liabilities 362,974.74
Equity
3010 · Unrestrict (retained earnings)-1,031,692.56
3100 · Temporarily restrict net asset
3110 · Use restricted net assets 288,299.58
3115 · TempRest NA-Learning Center 2,402,888.89
Total 3100 · Temporarily restrict net asset 2,691,188.47
Net Income 2,361,899.20
Total Equity 4,021,395.11
TOTAL LIABILITIES & EQUITY 4,384,369.85
Page 1 of 1 Restricted For Management Use Only.
DocuSign Envelope ID: E2200FFA-29A9-418F-8E01-8059345CCD21
Family Promise of Gallatin Valley, Inc.
Profit & Loss
July through August 2021
Jul - Aug 21 Jul - Aug 20
Ordinary Income/Expense
Income
4 · Contributed support 127,090.87 120,543.11
5 · Earned revenues 7,509.54 8,141.34
5800 · Special events 8,988.64 9,458.43
Total Income 143,589.05 138,142.88
Gross Profit 143,589.05 138,142.88
Expense
7200 · Salaries & related expenses 67,159.37 45,370.78
8100 · Operating Expenses 36,587.55 30,905.80
8200 · Occupancy exp - Day Center 1,514.72 1,065.20
8300 · Travel & meetings expenses 27.52 14.15
8500 · Misc expenses 7,132.01 1,094.73
8700 · Volunteer Training/Appreciation 315.51 0.00
8800 · Learning Center 6,155.40 0.00
9200 · Occupancy Exp-Transitional Hous 5,390.61 3,840.35
Total Expense 124,282.69 82,291.01
Net Ordinary Income 19,306.36 55,851.87
Other Income/Expense
Other Income
9020 · Unrealized Gains/Losses 0.00 -14,144.24
9021 · Realized Gains/Losses on Invest 0.00 26,706.60
9130 · Gifts in kind - goods 6,316.00 7,838.00
Total Other Income 6,316.00 20,400.36
Other Expense
9530 · Donations in kind - expense 6,316.00 7,838.00
9805 · Interest Expense 0.00 0.00
Total Other Expense 6,316.00 7,838.00
Net Other Income 0.00 12,562.36
Net Income 19,306.36 68,414.23
Page 1 of 1 Restricted for Management Use Only
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FAMILY PROMISE OF GALLATIN VALLEY (FPGV)
FINANCIAL CONTROLS POLICY
Adequate controls must be established and maintained to prevent errors or irregularities in policies.
These controls will ensure the organization’s accounts and records are accurate and reliable,
transactions are properly authorized, and assets are adequately safeguarded. Although the possibility
for error always exists, a sound system of internal controls can help to uncover errors as soon as
possible and allow for their timely correction. The board of directors acknowledges that effective
management of the organization depends on the receipt of accurate and timely information. This
policy will be reviewed, updated (as needed) and presented to the Board of Directors for approval
annually.
Purpose:
The purpose of this Financial Controls Policy is to provide for the effective control over, ensuring
transparency and accountability of all funds received and held by Family Promise of Gallatin Valley,
Inc.
General:
A professional services firm(s) will be contracted with to provide accounting and bookkeeping
duties. All items will be tracked on formal accounting software (e.g. QuickBooks). The Executive
Director (ED) and Board Treasurer (Treasurer) will have full access to the professional services
firm(s) to view all transactions. The ED will send financial reports to the Finance Committee for
review each month. A financial summary will be made available to all board members prior to the
monthly board meeting.
Financial Accounts:
Operating Account:
An operating account will be maintained. Funds will be maintained at the ED’s discretion to
support day-to-day operational needs (ideally 1 to 2 months of operating expenses). Excess
funds will be transferred to a cash or cash equivalent interest-bearing account.
Expense Account:
An additional checking account is established to provide the ED with access to funds and
checks for day-to-day operations. Funds may be used to pay for expenses authorized in the
approved budget.
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Investment Account:
The Finance Committee can engage a professional service provider (e.g. Wells Fargo
Advisors) to manage one or more investment account(s) pursuant to FPGV’s investment
policy (appendix A). Level of funding of the investment account will be at the discretion of
the Board and Finance Committee.
The following shall be signors on the accounts detailed above: Board President, Vice President,
Treasurer, Secretary, and ED.
Credit Card:
Credit card account(s) exists to pay for expenses authorized in the approved budget. All
expenses incurred on these accounts will be supported by appropriate documentation for
review by the board or its designee.
Credit Card Processing:
A Credit Card Processing account exists for the convenience of the organization’s supporters
to make donations or purchase tickets to FPGV sponsored events. The ED is the primary user
on the account. Records of account transactions will be provided to the agency’s professional
service firm for regular reconciliation.
Bank Reconciliation:
All accounts shall be reconciled to the bank statements monthly. Reconciliation shall be performed
by an individual who is independent of the receipts and posting processes. The organization’s
professional services firm(s) will handle reconciliations. The ED and Treasurer will verify
reconciliations are completed on a regular basis and in a timely fashion. Monthly reconciliation
detailed reports will be made accessible to the ED and Treasurer.
Receipt and Disbursement of Funds:
Segregation of duties in the handling of receipts and disbursement of funds is the recommended
method for assuring fiscal accountability. No individual should have complete control in the
handling of receipts or disbursement of funds. Specifically, no one individual’s duties should include
the actual handling of receipts, recording receipt of money, disbursing funds, and the reconciliation
of bank accounts. Incoming receipts must be made a matter of record as soon as possible.
Disbursement will be made in a timely manner.
Employee Expense Reimbursement:
Employee expense reimbursement will be made pursuant to FPGV’s employee handbook.
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Board Expense Reimbursement
Board members may occasionally incur expenses that need reimbursement. All expenses incurred by
directors must be properly documented and approved by the ED prior to payment. Directors and any
volunteer will use FPGV’s current expense reimbursement form (appendix B) for all expense
reimbursements.
Payroll:
The organization will engage a professional services firm(s) to handle all payroll activities, including
salary disbursements, required report filings and payments, and reporting to the ED. Employees shall
be paid according to the Salary Administration section of the FPGV Employee Handbook.
In-Kind Donations:
FPGV welcomes most in-kind donations that support our mission, are consistent with our policies
and are properly accounted for and acknowledged. Please see FPGV’s gift acceptance policy
(appendix C) for additional information.
Capital Expenditures:
All assets acquired under $2,500 should normally be expensed. If a multiple of items are purchased
and, in the aggregate, exceed $2,500, they should be capitalized. Typically, the items are expensed
when purchased, where they are budgeted until year-end, they are moved to the balance sheet and
depreciated.
Board Review of Financial Documents:
The BOD receives and reviews sufficient and relevant information pertaining to the financial
condition of the organization at each board meeting. Report may include, but is not limited to;
• Donations for Month
• Profit & Loss for Month
• Profit & Loss: Budget vs. Actual for Month
• Profit & Loss YTD: Prior Year Comparison
• Balance Sheet: Prior Year Comparison
• Investments Recap (quarterly)
The BOD receives and reviews sufficient and relevant information pertaining to the financial
condition of the organization at the close of the fiscal year. Report may include, but are not limited
to;
• End of Year Profit and Loss Statement (summary and details)
• End of Year Profit and Loss Statement vs. Budget
• End of Year Balance Sheet
• End of Year Investments Recap
While the organization utilizes a professional firm to compile the required Form 990 Return of
Organization Exempt from Income Tax filings, the Board receives, reviews and approves the
completed 990 prior to filing.
Audit and/or Financial Review:
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An audit or financial review of agency finances may be completed at the discretion of the Board.
The Board shall approve the firm to be used for each audit and/or financial review.
Appendix A: Family Promise of Gallatin Valley Investment Policy (adopted 12/6/17)
Overview
Responsibility for all financial matters of the organization rests with the board; however, consistent
with that responsibility, authority for making recommendations on investments is delegated to the
Finance Committee. Organization funds may be invested in a variety of investment vehicles to
maximize total return consistent with a prudent level of risk to ensure continued success of the
charitable purposes of the organization. Preservation of principal is core to the organization
investment policy. A Financial Advisor may be selected through a process as deemed necessary by
the Finance Committee and approved by the board, the Finance Committee may also recommend
whether or not the board authorize a discretionary agreement with the Financial Advisor.
Performance will be reviewed at least annually, and compared to overall investment objectives and
capital market returns which are benchmarked against appropriate market indices and other pertinent
measures. The Financial Advisor will keep the Finance Committee informed of any material changes
to investments as well as any other pertinent information potentially affecting the performance of
investments. The Finance Committee will report to the board at monthly board meetings regarding
noteworthy changes as they come about. Quarterly reports from investments will be provided to the
Finance Committee and the board. Annual reports will be presented to the board at a regularly-
scheduled board meeting.
Operating Funds
Upon approval of the board, FPGV may invest a reasonable amount of cash in short term investments
in the following manner: savings accounts, money market accounts, certificate of deposits, and
treasury bills, as well as any other risk free assets. These investments may be made with some or all
of the funds which the organization holds in its: (1) operating funds; (2) operating reserves; (3)
temporarily restricted net assets. The organization will ensure cash and cash equivalents are
FDIC/NCUA insured.
Long Term
The organization may invest cash assets designated for long term growth otherwise not deemed as
operating funds in equities and bonds, with the objective of long-term growth of the assets in
mind. The asset allocation recommended is:
• 60% equities
• 40% bonds
• Plus or minus 10%
The Finance Committee will be responsible for recommending to the board the amount of said long
term investments, and the actual placement of the funds with a Financial Advisor upon board
approval.
Donated Stock
Individual stocks received as donations to the agency may be liquidated upon receipt at the direction
of the organization’s Financial Advisor. Funds may be kept in the investment account and reinvested
to maintain the recommended asset allocation.
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Appendix B: Family Promise of Gallatin Valley Expense Reimbursement Request
Name: ______________________ FPGV Position: ______________________
Mailing Address: _________________________________________________________
Request Date: ____________________
EXPENSE DETAILS
Date
Incurred
Vendor, Description & Purpose, Attendees (when
applicable) Amount Budget
Code
Total
TRAVEL
Date Starting
Point
Time of
Departure Destination Time of
Return
Total
Miles
Mileage
at $.58
Daily
Total
Budget
Code
Travel Amount Due Employee
DocuSign Envelope ID: E2200FFA-29A9-418F-8E01-8059345CCD21
I am requesting reimbursement of the above itemized expenses incurred by me on behalf of Family
Promise of Gallatin Valley.
Signature: ________________________________________________________
Date: ____________
Reimbursement Authorization: ________________________________________
Date: ____________
Appendix C: Gift Acceptance Policy (adopted 4/17/19)
Gift Acceptance
The Executive Director of Family Promise of Gallatin Valley, Inc. (“FPGV”) and the Board of
Directors (Board) has the authority to solicit and/or accept gifts on behalf of FPGV in order to further
the mission of the organization and to support special projects authorized by the Board.
Gifts generally accepted include gifts of cash, marketable securities, bequests and beneficiary
designations under wills and trusts [charitable remainder trust and charitable lead trust].
Restrictions on Gifts
FPGV will not accept gifts that 1) would result in FPGV violating its corporate charter, 2) would
result in FPGV losing status as a 501(c)(3) organization, (3) are too difficult or too expensive to
administer in relation to their value, or (4) are from individuals or entities whose practices, policies,
or operations are deemed unacceptable and contrary to the values, mission, and well-being of the
organization. Decisions on the restrictive nature of a gift, and its acceptance or refusal, shall be made
by the Executive Committee, in consultation with the Executive Director.
Gifts Subject to Review
The following gifts may be subject to review by the Executive Committee and the Executive
Director. FPGV will also seek the advice of legal counsel in matters relating to acceptance of gifts
when appropriate. Review by the Executive committee and/or legal counsel is recommended for, but
not limited to the following:
1. Restricted marketable securities
2. Closely held stock
3. Life Insurance policies
4. Real Estate
Total Requested for
Reimbursement
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5. Tangible personal property that is not readily marketable or that cannot be readily used in
furtherance of the FPGV’s mission
6. Gifts naming FPGV as a fiduciary or requiring FPGV to act in a fiduciary capacity
7. Gifts requiring FPGV to assume financial or other obligations
8. Transactions with potential conflicts of interest
9. Gifts of property which may be subject to environmental or other regulatory restrictions
In-Kind Donations
FPGV accepts services or equipment that can be of use or can be quickly sold. This includes, but is
not limited to: rental space, professional services, office furnishings, vehicles, fixtures, and other
operational equipment. The donor must supply an appraisal for equipment or goods contributed and
valued over $5,000. If the value appears unreasonable, FPGV retains the right to adjust the value for
accounting purposes.
In-kind donations are to be used exclusively for the organization and are not to be used by Board
members, volunteers or employees for personal purposes.
For more guidance on vehicle donations, please review FPGV’s Vehicle Acceptance Guidelines.
Related Experience with Projects Similar to the Scope of Services
Family Promise of Gallatin Valley Mission and Vision:
For 15 years Family Promise has been dedicated the mission of empowering homeless families with
children to achieve self-sufficiency through partnerships, services and advocacy. Our vision is to end
homelessness in the Gallatin Valley, one family at a time.
Outline of Current Programs and Services:
FPGV has three central areas of assisting families experiencing homelessness or at risk of becoming
homeless: Prevention, Emergency Shelter, and Stabilization.
1. Prevention: Our prevention program model is based on a combination of case management,
opportunity, and community involvement. We empower the families we serve and ensure
they are homeless no more.
Family Promise of Gallatin Valley prevents family homelessness in two ways:
a. Eviction Prevention: We assist families in the mediation of evictions, provide rental and
utility assistance, and provide case management. Our approach prevents homelessness and
keeps children in stable homes.
b. Help Us Move In (HUMI): We prevent families from experiencing homelessness by assisting
with finding housing quickly. Coupled with case management, we provide financial
assistance with move-in costs, including first and last month's rent and security deposits.
DocuSign Envelope ID: E2200FFA-29A9-418F-8E01-8059345CCD21
2. Emergency Shelter: The central component of our programming is our Emergency Shelter
Program (ESP) where we offer shelter for homeless families by coordinating with over 2000
volunteers that provide evening meals. We currently have two shelter locations: St. James
Rectory and the Family Promise Day Center. The Day Center also houses our Family Case
Manager’s office where families receive intensive case management services, assistance with
completing housing applications, and more. Prior to COVID – 19 all staff members had offices
in the Day Center, but in our effort to serve more families, we converted our offices into
bedrooms. Over the past 15 years, Family Promise has graduated more than 70% of the 200
families we served in our Shelter Program with gainful employment, childcare, and affordable
housing.
3. Stabilization: Our goal is not simply getting families into housing, it is keeping them in
housing. We do this in two ways:
a. Transitional Housing: The Families Forward Transitional Housing Program is for families
that have graduated from our Emergency Shelter Program. It is intended to help families with
their next step in becoming self-sufficient. We believe that by providing transitional housing,
coupled with a case management plan, families will be equipped to successfully navigate
Bozeman’s unique housing environment.
Currently, we operate 9 different housing units. Families have the opportunity to stay in
transitional housing for up to 2 years. This length of time provides consistency and stability
for children, gives families time to create and implement a savings plan, and builds positive
rental history. Families will continually be working towards finding permanent housing
during their participation.
Rent for families in our Transitional Housing Program starts off below market rate ($350),
and every 6 months is increased by $150. Families build this increase in rental rate into their
budget, with the goal of paying a near market rate for rent by the time the family is ready to
leave our Transitional Housing Program. With this strategy, families are more successful at
securing affordable housing when they leave Family Promise. We want families to experience
lasting success. To help with the cost of a future security deposit, first and last month rent, or
moving costs, Family Promise returns to the family exiting our transitional housing any
monies paid for rent that are over the costs of operating the apartment, if families work
continuously with our case managers and appropriately maintain their transitional housing
home.
b. Graduate Support Services: As families get closer to graduating from our emergency shelter
program, they may experience anxiety as well as excitement. The anticipation of being in
their own home, with their own bed to sleep in, is rivaled by the fear of falling back on hard
times and not having the safety net of FPGV staff and volunteers. Through the Moving
Mountains graduate support program, FPGV works with families who have participated and
graduated from our emergency shelter program. During their time at Family Promise, families
have received intensive case management and support, and this should not stop after 90 days.
We remain focused on helping families engage in the local community and continue their
successes and achievements.
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Description of Program
COVID-19 affected Gallatin Valley households in unprecedented ways. Over the past year, the Gallatin
Valley has experienced a population increase of remote workers and others seeking to live in the
Bozeman area. The overall reasoning behind this population boom is still speculation, but its affects
have undoubtedly disrupted the economic stability of the Gallatin Valley and has caused housing
insecurities for our community’s most vulnerable members. To meet this increase of families who
have been displaced due to an increase of rental costs, the sale of their rental home, the inability to find
a home due to an extremely competitive market, etc.., Family Promise has increased its shelter capacity
from just four families a time a year ago, to currently serving 19 families at a time.
The families we serve require more assistance than just a safe shelter space for sleeping, making meals,
and getting ready for school and work. They also need direct assistance with paying for gas, paying
cell phone bills, and the cost of work uniforms and work clothes. They also need assistance with rental
application fees, car maintenance costs, mental health and well-being costs, and childcare costs while
they are working or attending vital appointments.
When housing was more readily available, families would average less than 90 days in our shelter
program, but with a shortage of affordable rentals combined with a highly competitive housing market,
families are averaging 180 day stays. With this in mind, we are expecting to serve 30 families in our
shelter program this year. On average, $2,521.00 in direct support is provided per family for their
unique needs in their efforts to regain self-sufficiency and independent housing. In total, this year we
expect to provide families with $75,630 in direct support to households affected by the negative
economic impacts caused by the COVID – 19 pandemic.
Many of the families that come to Family Promise for shelter have exhausted their finances on motel
costs, and oftentimes, only one parent is able to have employment due to a lack of childcare. When
they enter our shelter program, we provide them with financial assistance that many other organizations
in Bozeman cannot provide.
Family Promise of Gallatin Valley is requesting $75,630 in funding to directly assist families
experiencing homelessness. Family Promise serves families of all compositions. We welcome
everyone in the community to be a part of the solution to empower families experiencing homelessness,
and ultimately, regain and retain the safety, security, and opportunity that comes with have a home.
Family Promise will comply with all Federal Requirements and will comply with reporting
requirements the city sets forth. FPGV serves economically disadvantaged families of all color,
disabilities, genders, and languages. The only requirement we have across our programming is that the
household must have children under their primary custody and/or be pregnant.
Funds granted will be distributed to families during the calendar year of year granted.
Proposed Schedule for Program Distribution and Funding Distribution
Funds granted will be distributed directly to families on a need basis to directly pay for goods or
services deemed essential by Family Promise in the care of families experiencing homelessness and
their efforts at regaining housing stability. We estimate $2,521.00 per family of direct support. Monies
granted will be distributed to families during the calendar year.
DocuSign Envelope ID: E2200FFA-29A9-418F-8E01-8059345CCD21
Attachment A NONDISCRIMINATION AND EQUAL PAY AFFIRMATION
Family Promise of Gallatin Valley (name of entity submitting) hereby affirms it
will not discriminate on the basis of race, color, religion, creed, sex, age, marital status,
national origin, or because of actual or perceived sexual orientation, gender identity or
disability and acknowledges and understands the eventual contract will contain a
provision prohibiting discrimination as described above and this prohibition on
discrimination shall apply to the hiring and treatments or proposer's employees and to all
subcontracts.
In addition, Family Promise of Gallatin Valley (name of entity submitting) hereby
affirms it will abide by the Equal Pay Act of 1963 and Section 39-3-104, MCA (the
Montana Equal Pay Act), and has visited the State of Montana Equal Pay for Equal Work
"best practices" website, https://wayback.archive-
it.org/499/20210701223409/https:/equalpay.mt.gov/, or equivalent "best practices publication
and has read the material.
Christel Chvilicek, Executive Director
Name and title of person authorized to sign on behalf of submitter
DocuSign Envelope ID: E2200FFA-29A9-418F-8E01-8059345CCD21
FY 2022/2023 Subrecipient Grant Agreement – ARPA Household Efforts
Exhibit
Exhibit B
Treasury Guidance
DocuSign Envelope ID: E2200FFA-29A9-418F-8E01-8059345CCD21
Coronavirus State and Local Fiscal Recovery Funds
Compliance and Reporting Guidance
1
ted ieethe due
ADD cover page
November xx, 2021
Version: 2.0
November 15, 2021
Version: 2.1
DocuSign Envelope ID: E2200FFA-29A9-418F-8E01-8059345CCD21
Coronavirus State and Local Fiscal Recovery Funds
Compliance and Reporting Guidance
2
Coronavirus State and Local Fiscal Recovery Funds
Guidance on Recipient Compliance and Reporting
Responsibilities
On March 11, 2021, the American Rescue Plan Act was signed into law, and established the
Coronavirus State Fiscal Recovery Fund and Coronavirus Local Fiscal Recovery Fund, which
together make up the Coronavirus State and Local Fiscal Recovery Funds (“SLFRF”) program.
This program is intended to provide support to State, territorial, local, and Tribal governments
in responding to the economic and public health impacts of COVID-19 and in their efforts to
contain impacts on their communities, residents, and businesses.
This guidance provides additional detail and clarification for each recipient’s compliance and
reporting responsibilities under the SLFRF program, and should be read in concert with the
Award Terms and Conditions, the authorizing statute, the SLFRF implementing regulation,
and other regulatory and statutory requirements, including regulatory requirements under the
Uniform Guidance (2 CRF Part 200). Please see the Assistance Listing in SAM.gov under
assistance listing number (formerly known as CFDA number), 21.027 for more information.
Please Note: This guidance document applies to the SLFRF program only and does not
change nor impact reporting and compliance requirements for the Coronavirus Relief Fund
(“CRF”) established by the CARES Act.
This guidance includes two parts:
Part 1: General Guidance
This section provides an orientation to recipients’ compliance responsibilities and the U.S.
Department of the Treasury’s (“Treasury”) expectations, and recommends best practices
where appropriate under the SLFRF Program.
A. Key Principles……………………..……………………………………………………. P. 3
B. Statutory Eligible Uses…………………………………………………………………. P. 3
C. Treasury’s Rulemaking……………………………………………………….………… P. 4
D. Uniform Guidance (2 CFR Part 200)……………..…………………………………… P. 6
E. Award Terms and Conditions………………………………...………………………...
P. 10
Part 2: Reporting Requirements
This section provides information on the reporting requirements for the SLFRF program.
A. Interim Report…...…………………………………………………………………...…. P. 14
B. Project and Expenditure Report…………….…………………………………...……. P. 15
C. Recovery Plan Performance Report..………………..……………………….….…… P. 22
Appendix 1: Expenditure Categories…………………………………………………….…… P. 30
Appendix 2: Evidenced-Based Intervention Additional Information…………………….…. P. 32
DocuSign Envelope ID: E2200FFA-29A9-418F-8E01-8059345CCD21
Coronavirus State and Local Fiscal Recovery Funds
Compliance and Reporting Guidance
3
Part 1: General Guidance
This section provides an orientation on recipients’ compliance responsibilities and Treasury’s
expectations and recommended best practices where appropriate under the SLFRF program.
Recipients under the SLFRF program are the eligible entities identified in sections 602 and
603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of
2021 (the “SLFRF statute”) that receive a SLFRF award. Subrecipients under the SLFRF
program are entities that receive a subaward from a recipient to carry out the purposes
(program or project) of the SLFRF award on behalf of the recipient.
Recipients are accountable to Treasury for oversight of their subrecipients, including ensuring
their subrecipients comply with the SLFRF statute, SLFRF Award Terms and Conditions,
Treasury’s Interim Final Rule, and reporting requirements, as applicable.
A. Key Principles
There are several guiding principles for developing your own effective compliance regimes:
• Recipients and subrecipients are the first line of defense, and responsible for ensuring the
SLFRF award funds are not used for ineligible purposes, and there is no fraud, waste, or
abuse associated with their SLFRF award;
• Many SLFRF-funded projects respond to the COVID-19 public health emergency and
meet urgent community needs. Swift and effective implementation is vital, and recipients
must balance facilitating simple and rapid program access widely across the community
and maintaining a robust documentation and compliance regime;
• Treasury encourages recipients to use SLFRF-funded projects to advance shared
interests and promote equitable delivery of government benefits and opportunities to
underserved communities, as outlined in Executive Order 13985, On Advancing Racial
Equity and Support for Underserved Communities Through the Federal Government; and
• Transparency and public accountability for SLFRF award funds and use of such funds are
critical to upholding program integrity and trust in all levels of government, and SLFRF
award funds should be managed consistent with Administration guidance per
Memorandum M-21-20 and Memorandum M-20-21.
B. Statutory Eligible Uses
As a recipient of an SLFRF award, your organization has substantial discretion to use the
award funds in the ways that best suit the needs of your constituents – as long as such use
fits into one of the following four statutory categories:
1. To respond to the COVID-19 public health emergency or its negative economic impacts;
2. To respond to workers performing essential work during the COVID-19 public health
emergency by providing premium pay to such eligible workers of the recipient, or by
providing grants to eligible employers that have eligible workers who performed essential
work;
3. For the provision of government services, to the extent of the reduction in revenue of such
recipient due to the COVID–19 public health emergency, relative to revenues collected in
the most recent full fiscal year of the recipient prior to the emergency; and
4. To make necessary investments in water, sewer, or broadband infrastructure.
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Treasury adopted an Interim Final Rule to implement these eligible use categories and other
restrictions on the use of funds under the SLFRF program.1 It is the recipient’s responsibility
to ensure all SLFRF award funds are used in compliance with these requirements. In addition,
recipients should be mindful of any additional compliance obligations that may apply – for
example, additional restrictions imposed upon other sources of funds used in conjunction with
SLFRF award funds, or statutes and regulations that may independently apply to water,
broadband, and sewer infrastructure projects. Recipients should ensure they maintain proper
documentation supporting determinations of costs and applicable compliance requirements,
and how they have been satisfied as part of their award management, internal controls, and
subrecipient oversight and management.
C. Treasury’s Rule
Treasury’s Interim Final Rule details recipients’ compliance responsibilities and provides
additional information on eligible and restricted uses of SLFRF award funds and reporting
requirements. Your organization should review and comply with the information contained in
Treasury’s Interim Final Rule, and any subsequent final rule when building appropriate
controls for SLFRF award funds.
1. Eligible and Restricted Uses of SLFRF Funds. As described in the SLFRF statute and
summarized above, there are four enumerated eligible uses of SLFRF award funds. As a
recipient of an award under the SLFRF program, your organization is responsible for
complying with requirements for the use of funds. In addition to determining a given
project’s eligibility, recipients are also responsible for determining subrecipient’s or
beneficiaries’ eligibility and must monitor use of SLFRF award funds.
To help recipients build a greater understanding of eligible uses, Treasury’s Interim Final
Rule establishes a framework for determining whether a specific project would be eligible
under the SLFRF program, including some helpful definitions. For example, Treasury’s
Interim Final Rule establishes:
• A framework for determining whether a project “responds to” a “negative economic
impact” caused by the COVID-19 public health emergency;
• Definitions of “eligible employers”, “essential work,” “eligible workers”, and “premium
pay” for cases where premium pay is an eligible use;
• A definition of “general revenue” and a formula for calculating revenue lost due to the
COVID-19 public health emergency;
• A framework for eligible water and sewer infrastructure projects that aligns eligible uses
with projects that are eligible under the Environmental Protection Agency’s Drinking
Water and Clean Water State Revolving Funds; and
• A framework for eligible broadband projects designed to provide service to unserved
or underserved households, or businesses at speeds sufficient to enable users to
generally meet household needs, including the ability to support the simultaneous use
of work, education, and health applications, and also sufficiently robust to meet
increasing household demands for bandwidth.
Treasury’s Interim Final Rule also provides more information on four important restrictions
on use of SLFRF award funds: recipients may not deposit SLFRF funds into a pension
fund; recipients that are States or territories may not use SLFRF funds to offset a reduction
in net tax revenue caused by the recipient’s change in law, regulation, or administrative
interpretation; and recipients may not use SLFRF funds as non-Federal match where
1 Treasury’s Interim Final Rule is effective as of May 17, 2021, and public comments are due July 16,
2021. This guidance may be clarified consistent with the final rule.
https://www.govinfo.gov/content/pkg/FR-2021-05-17/pdf/2021-10283.pdf
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prohibited. In addition, the Interim Final Rule clarifies certain uses of SLFRF funds outside
the scope of eligible uses, including that recipients generally may not use SLFRF funds
directly to service debt, satisfy a judgment or settlement, or contribute to a “rainy day” fund.
Recipients should refer to Treasury’s Interim Final Rule for more information on these
restrictions.
2. Eligible Costs Timeframe. Your organization, as a recipient of an SLFRF award, may
use SLFRF funds to cover eligible costs that your organization incurred during the period
that begins on March 3, 2021 and ends on December 31, 2024, as long as the award funds
for the obligations incurred by December 31, 2024 are expended by December 31, 2026.
Costs for projects incurred by the recipient State, territorial, local, or Tribal government
prior to March 3, 2021 are not eligible, as provided for in Treasury’s Interim Final Rule.
Recipients may use SLFRF award funds to provide assistance to households,
businesses, nonprofits, and individuals within the eligible use categories described in
Treasury’s Interim Final Rule for costs that those households, businesses, nonprofits,
and individuals incurred prior to March 3, 2021. For example,
a. Public Health/Negative Economic Impacts: Recipients may use SLFRF award funds
to provide assistance to households, small businesses, and nonprofits – such as
rent, mortgage, or utility assistance – for costs incurred by the household prior to
March 3, 2021, provided that the recipient state, territorial, local or Tribal government
did not incur the cost of providing such assistance prior to March 3, 2021.
b. Premium Pay: Recipients may provide premium pay retrospectively for work
performed at any time since the start of the COVID-19 public health emergency.
Such premium pay must be “in addition to” wages and remuneration already received
and the obligation to provide such premium pay must not have been incurred by the
recipient prior to March 3, 2021.
c. Revenue Loss: Treasury’s Interim Final Rule gives recipients broad discretion to use
funds for the provision of government services to the extent of reduction in revenue.
While calculation of lost revenue begins with the recipient’s revenue in the last full
fiscal year prior to the COVID-19 public health emergency and includes the 12-month
period ending December 31, 2020, use of funds for government services must be
forward looking for costs incurred by the recipient after March 3, 2021.
d. Investments in Water, Sewer, and Broadband: Recipients may use SLFRF award
funds to make necessary investments in water, sewer, and broadband. Recipients
may use SLFRF award funds to cover costs incurred for eligible projects planned or
started prior to March 3, 2021, provided that the project costs covered by the SLFRF
award funds were incurred by the recipient after March 3, 2021.
Any funds not obligated or expended for eligible uses by the timelines above must be
returned to Treasury, including any unobligated or unexpended funds that have been
provided to subrecipients and contractors as part of the award closeout process
pursuant to 2 C.F.R. 200.344(d). For the purposes of determining expenditure
eligibility, Treasury’s Interim Final Rule provides that “incurred” has the same meaning
given to “financial obligation” in 2 CFR 200.1.
3. Reporting. Generally, recipients must submit one initial interim report, quarterly or annual
Project and Expenditure reports which include subaward reporting, and in some cases
annual Recovery Plan reports. Treasury’s Interim Final Rule and Part 2 of this guidance
provide more detail around SLFRF reporting requirements.
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D. Uniform Administrative Requirements
The SLFRF awards are generally subject to the requirements set forth in the Uniform
Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2
CFR Part 200 (the “Uniform Guidance”). In all instances, your organization should review the
Uniform Guidance requirements applicable to your organization’s use of SLFRF funds, and
SLFRF-funded projects. Recipients should consider how and whether certain aspects of the
Uniform Guidance apply.
The following sections provide a general summary of your organization’s compliance
responsibilities under applicable statutes and regulations, including the Uniform Guidance, as
described in the 2020 OMB Compliance Supplement Part 3. Compliance Requirements
(issued August 18, 2020). Note that the descriptions below are only general summaries and
all recipients and subrecipients are advised to carefully review the Uniform Guidance
requirements and any additional regulatory and statutory requirements applicable to the
program.
1. Allowable Activities. Each recipient should review program requirements, including
Treasury’s Interim Final Rule and the recipient’s Award Terms and Conditions, to
determine and record eligible uses of SLFRF funds. 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.
2. Allowable Costs/Cost Principles. As outlined in the Uniform Guidance at 2 CFR Part
200, Subpart E regarding Cost Principles, allowable costs are based on the premise that
a recipient is responsible for the effective administration of Federal awards, application of
sound management practices, and administration of Federal funds in a manner consistent
with the program objectives and terms and conditions of the award. Recipients must
implement robust internal controls and effective monitoring to ensure compliance with the
Cost Principles, which are important for building trust and accountability.
Assistance Listing
The Assistance Listing for the Coronavirus State and Local Fiscal Recovery Funds
(SLFRF) was published May 28, 2021 on SAM.gov under Assistance Listing Number
(“ALN”), formerly known as CFDA Number, 21.027.
The assistance listing includes helpful information including program purpose, statutory
authority, eligibility requirements, and compliance requirements for recipients. The ALN
is the unique 5-digit number assigned to identify a federal assistance listing, and can be
used to search for federal assistance program information, including funding
opportunities, spending on USASpending.gov, or audit results through the Federal Audit
Clearinghouse.
To expedite payments and meet statutory timelines Treasury issued initial payments
under an existing ALN, 21.019, assigned to the CRF. If you have already received funds
or captured the initial number in your records, please update your systems and reporting
to reflect the new ALN 21.027 for the SLFRF program. Recipients must use ALN
21.027 for all financial accounting, subawards, and associated program reporting
requirements for the SLFRF awards.
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SLFRF Funds may be, but are not required to be, used along with other funding sources
for a given project. Note that SLFRF Funds may not be used for a non-Federal cost share
or match where prohibited by other Federal programs, e.g., funds may not be used for the
State share for Medicaid.2
Treasury’s Interim Final Rule and guidance and the Uniform Guidance outline the types of
costs that are allowable, including certain audit costs. For example, per 2 CFR 200.425,
a reasonably proportionate share of the costs of audits required by the Single Audit Act
Amendments of 1996 are allowable; however, costs for audits that were not performed in
accordance with 2 CFR Part 200, Subpart F are not allowable. Please see 2 CFR Part
200, Subpart E regarding the Cost Principles for more information.
a. Administrative costs: Recipients may use funds for administering the SLFRF
program, including costs of consultants to support effective management and
oversight, including consultation for ensuring compliance with legal, regulatory, and
other requirements.3 Further, costs must be reasonable and allocable as outlined in 2
CFR 200.404 and 2 CFR 200.405. Pursuant to the SLFRF Award Terms and
Conditions, recipients are permitted to charge both direct and indirect costs to their
SLFRF award as administrative costs. Direct costs are those that are identified
specifically as costs of implementing the SLFRF program objectives, such as
contract support, materials, and supplies for a project. Indirect costs are general
overhead costs of an organization where a portion of such costs are allocable to the
SLFRF award such as the cost of facilities or administrative functions like a director’s
office.45 Each category of cost should be treated consistently in like circumstances as
direct or indirect, and recipients may not charge the same administrative costs to
both direct and indirect cost categories, or to other programs. If a recipient has a
current Negotiated Indirect Costs Rate Agreement (NICRA) established with a
Federal cognizant agency responsible for reviewing, negotiating, and approving cost
allocation plans or indirect cost proposals, then the recipient may use its current
NICRA. Alternatively, if the recipient does not have a NICRA, the recipient may elect
to use the de minimis rate of 10 percent of the modified total direct costs pursuant to
2 CFR 200.414(f).
b. Salaries and Expenses: In general, certain employees’ wages, salaries, and covered
benefits are an eligible use of SLFRF award funds. Please see Treasury’s Interim
Final Rule for details.
3. Cash Management. SLFRF payments made to recipients are not subject to the
requirements of the Cash Management Improvement Act and Treasury’s implementing
regulations at 31 CFR part 205 or 2 CFR 200.305(b)(8)-(9).
As such, recipients can place funds in interest-bearing accounts, do not need to remit
interest to Treasury, and are not limited to using that interest for eligible uses under the
SLFRF award.
4. Eligibility. Under this program, recipients are responsible for ensuring funds are used for
eligible purposes. Generally, recipients must develop and implement policies and
2 See 42 CFR 433.51 and 45 CFR 75.306.
3 Recipients also may use SLFRF funds directly for administrative costs to improve efficacy of
programs that respond to the COVID-19 public health emergency. 31 CFR 35.6(b)(10).
4 2 CFR 200.413 Direct Costs.
5 2 CFR 200.414 Indirect Costs.
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procedures, and record retention, to determine and monitor implementation of criteria for
determining the eligibility of beneficiaries and/or subrecipients. Your organization, and if
applicable, the subrecipient(s) administering a program on behalf of your organization, will
need to maintain procedures for obtaining information evidencing a given beneficiary,
subrecipient, or contractor’s eligibility including a valid SAM.gov registration. Implementing
risk-based due diligence for eligibility determinations is a best practice to augment your
organization’s existing controls.
5. Equipment and Real Property Management. Any purchase of equipment or real
property with SLFRF funds must be consistent with the Uniform Guidance at 2 CFR Part
200, Subpart D. Equipment and real property acquired under this program must be used
for the originally authorized purpose. Consistent with 2 CFR 200.311 and 2 CFR 200.313,
any equipment or real property acquired using SLFRF funds shall vest in the non-Federal
entity. Any acquisition and maintenance of equipment or real property must also be in
compliance with relevant laws and regulations.
6. Matching, Level of Effort, Earmarking. There are no matching, level of effort, or
earmarking compliance responsibilities associated with the SLFRF award. See Section
C.1 (Eligible and Restricted Uses of SLFRF Funds) for a discussion of restrictions on use
of SLFRF funds. SLFRF funds may only be used for non-Federal match in other programs
where costs are eligible under both SLFRF and the other program and use of such funds
is not prohibited by the other program.
7. Period of Performance. Your organization should also develop and implement internal
controls related to activities occurring outside the period of performance. For example,
each recipient should articulate each project’s policy on allowability of costs incurred prior
to award or start of the period of performance. All funds remain subject to statutory
requirements that they must be used for costs incurred by the recipient during the period
that begins on March 3, 2021, and ends on December 31, 2024, and that award funds for
the financial obligations incurred by December 31, 2024 must be expended by December
31, 2026. Any funds not used must be returned to Treasury as part of the award
closeout process pursuant to 2 C.F.R. 200.344(d).
8. Procurement, Suspension & Debarment. Recipients are responsible for ensuring that
any procurement using SLFRF funds, or payments under procurement contracts using
such funds are consistent with the procurement standards set forth in the Uniform
Guidance at 2 CFR 200.317 through 2 CFR 200.327, as applicable. The Uniform Guidance
establishes in 2 CFR 200.319 that all procurement transactions for property or services
must be conducted in a manner providing full and open competition, consistent with
standards outlined in 2 CFR 200.320, which allows for non-competitive procurements only
in circumstances where at least one of the conditions below is true: the item is below the
micro-purchase threshold; the item is only available from a single source; the public
exigency or emergency will not permit a delay from publicizing a competitive solicitation;
or after solicitation of a number of sources, competition is determined inadequate.6
Recipients must have and use documented procurement procedures that are consistent
with the standards outlined in 2 CFR 200.317 through 2 CFR 200.320. The Uniform
Guidance requires an infrastructure for competitive bidding and contractor oversight,
including maintaining written standards of conduct and prohibitions on dealing with
suspended or debarred parties. Your organization must ensure adherence to all applicable
local, State, and federal procurement laws and regulations.
9. Program Income. Generally, program income includes, but is not limited to, income from
fees for services performed, the use or rental of real or personal property acquired under
6 2 CFR 200.320(c)(1)-(3) and (5)
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Federal awards and principal and interest on loans made with Federal award funds.
Program income does not include interest earned on advances of Federal funds, rebates,
credits, discounts, or interest on rebates, credits, or discounts. Recipients of SLFRF funds
should calculate, document, and record the organization’s program income. Additional
controls that your organization should implement include written policies that explicitly
identify appropriate allocation methods, accounting standards and principles, compliance
monitoring checks for program income calculations, and records.
The Uniform Guidance outlines the requirements that pertain to program income at 2 CFR
200.307. Treasury intends to provide additional guidance regarding program income and
the application of 2 CFR 200.307(e)(1), including with respect to lending programs.
10. Reporting. All recipients of federal funds must complete financial, performance, and
compliance reporting as required and outlined in Part 2 of this guidance. Expenditures
may be reported on a cash or accrual basis, as long as the methodology is disclosed and
consistently applied. Reporting must be consistent with the definition of expenditures
pursuant to 2 CFR 200.1. Your organization should appropriately maintain accounting
records for compiling and reporting accurate, compliant financial data, in accordance with
appropriate accounting standards and principles.
In addition, where appropriate, your organization needs to establish controls to ensure
completion and timely submission of all mandatory performance and/or compliance
reporting. See Part 2 of this guidance for a full overview of recipient reporting
responsibilities.
11. Subrecipient Monitoring. SLFRF recipients that are pass-through entities as described
under 2 CFR 200.1 are required to manage and monitor their subrecipients to ensure
compliance with requirements of the SLFRF award pursuant to 2 CFR 200.332 regarding
requirements for pass-through entities.
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.
Next, your organization will need to evaluate each subrecipient’s risk of noncompliance
based on a set of common factors. These risk assessments may include factors such as
prior experience in managing Federal funds, previous audits, personnel, and policies or
procedures for award execution and oversight. Ongoing monitoring of any given
subrecipient should reflect its assessed risk and include monitoring, identification of
deficiencies, and follow-up to ensure appropriate remediation.
Accordingly, your organization should develop written policies and procedures for
subrecipient monitoring and risk assessment and maintain records of all award
agreements identifying or otherwise documenting subrecipients’ compliance obligations.
Recipients should note that non-entitlement units of local government (NEUs) are not
subrecipients under the SLFRF program. They are SLFRF recipients that will report
directly to Treasury.
Recipients should also note that subrecipients do not include individuals and organizations
that received SLFRF funds as end users to respond to the negative economic impacts of
COVID-19 on these organizations. Such individuals and organizations are beneficiaries
and not subject to audit pursuant to the Single Audit Act and 2 C.F.R. Part 200, Subpart
F.
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Separately or in addition, many recipients may choose to provide a subaward (e.g., via
contract or grant) to other entities to provide services to other end—users. For example,
a recipient may provide a grant to a nonprofit to provide homeless services to individuals
experiencing homelessness. In this case, the subaward to a nonprofit is based on the
services that the Recipient intends to provide, assistance to households experiencing
homelessness, and the nonprofit is serving as the subrecipient, providing services on
behalf of the recipient. Subrecipients are subject to audit pursuant to the Single Audit
Act and 2 CFR part 200, subpart F regarding audit requirements.
12. Special Tests and Provisions. Treasury has received comments on the Interim Final
Rule and will adopt a final rule after responding to these comments. In addition, Treasury
may add clarifications to the Final Rule and other subregulatory guidance as well as
frequently asked questions.
Across each of the compliance requirements above, Treasury described some best
practices for development of internal controls. The table below provides a brief description
and example of each best practice.
Table 1: Internal controls best practices
Best Practice Description Example
Written policies and
procedures
Formal documentation of
recipient policies and
procedures
Documented procedure for
determining worker eligibility
for premium pay
Written standards of conduct Formal statement of mission,
values, principles, and
professional standards
Documented code of conduct /
ethics for subcontractors
Risk-based due diligence Pre-payment validations
conducted according to an
assessed level of risk
Enhanced eligibility review of
subrecipient with imperfect
performance history
Risk-based compliance
monitoring
Ongoing validations conducted
according to an assessed level
of risk
Higher degree of monitoring for
projects that have a higher risk
of fraud, given program
characteristics
Record maintenance and
retention Creation and storage of
financial and non-financial
records.
Storage of all subrecipient
payment information.
E. Award Terms and Conditions
The Award Terms and Conditions of the SLFRF financial assistance agreement sets forth the
compliance obligations for recipients pursuant to the SLFRF statute, the Uniform Guidance,
and Treasury’s Interim Final Rule. Recipients should ensure they remain in compliance with
all Award Terms and Conditions. These obligations include the following items in addition to
those described above:
1. SAM.gov Requirements. All eligible recipients are also required to have an active
registration with the System for Award Management (SAM) (https://www.sam.gov). To
ensure timely receipt of funding, Treasury has stated that Non-entitlement Units of
Government (NEUs) who have not previously registered with SAM.gov may do so after
receipt of the award, but before the submission of mandatory reporting.7
2. Recordkeeping Requirements. Generally, your organization must maintain records and
financial documents for five years after all funds have been expended or returned to
Treasury, as outlined in paragraph 4.c. of the Award Terms and Conditions. Treasury may
7 See flexibility provided in https://www.whitehouse.gov/wp-content/uploads/2021/03/M_21_20.pdf.
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request transfer of records of long-term value at the end of such period. Wherever
practicable, such records should be collected, transmitted, and stored in open and
machine-readable formats.
Your organization must agree to provide or make available such records to Treasury upon
request, and to the Government Accountability Office (“GAO”), Treasury’s Office of
Inspector General (“OIG”), and their authorized representative in order to conduct audits
or other investigations.
3. Single Audit Requirements. Recipients and subrecipients that expend more than
$750,000 in Federal awards during their fiscal year will be subject to an audit under the
Single Audit Act and its implementing regulation at 2 CFR Part 200, Subpart F regarding
audit requirements.8 Recipients and subrecipients may also refer to the Office of
Management and Budget (OMB) Compliance Supplements for audits of federal funds and
related guidance and the Federal Audit Clearinghouse to see examples and single audit
submissions.
4. Civil Rights Compliance. Recipients of Federal financial assistance from the Treasury
are required to meet legal requirements relating to nondiscrimination and
nondiscriminatory use of Federal funds. Those requirements include ensuring that entities
receiving Federal financial assistance from the Treasury do not deny benefits or services,
or otherwise discriminate on the basis of race, color, national origin (including limited
English proficiency), disability, age, or sex (including sexual orientation and gender
identity), in accordance with the following authorities: Title VI of the Civil Rights Act of 1964
(Title VI) Public Law 88-352, 42 U.S.C. 2000d-1 et seq., and the Department's
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. 794; Title
IX of the Education Amendments of 1972 (Title IX), 20 U.S.C. 1681 et seq., and the
Department's implementing regulations, 31 CFR part 28; Age Discrimination Act of 1975,
Public Law 94-135, 42 U.S.C. 6101 et seq., and the Department implementing regulations
at 31 CFR part 23.
In order to carry out its enforcement responsibilities under Title VI of the Civil Rights Act,
Treasury will collect and review information from non-Tribal recipients to ascertain their
compliance with the applicable requirements before and after providing financial
assistance. Treasury’s implementing regulations, 31 CFR part 22, and the Department of
Justice (DOJ) regulations, Coordination of Non-discrimination in Federally Assisted
Programs, 28 CFR part 42, provide for the collection of data and information from
recipients (see 28 CFR 42.406). Treasury may request that recipients submit data for post-
award compliance reviews, including information such as a narrative describing their Title
VI compliance status. This collection does not apply to Tribal Governments.
8 For-profit entities that receive SLFRF subawards are not subject to Single Audit requirements.
However, they are subject to other audits as deemed necessary by authorized governmental entities,
including Treasury, the GAO, and Treasury’s OIG.
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Part 2: Reporting Guidance
There are three types of reporting requirements for the SLFRF program.
• Interim Report: Provide initial overview of status and uses of funding. This is a one-time
report. See Section A, page 14.
• Project and Expenditure Report: Report on projects funded, expenditures, and contracts
and subawards over $50,000, and other information. See Section B, page 15.
• Recovery Plan Performance Report: The Recovery Plan Performance Report (the
“Recovery Plan”) will provide information on the projects that large recipients are
undertaking with program funding and how they plan to ensure program outcomes are
achieved in an effective, efficient, and equitable manner. It will include key performance
indicators identified by the recipient and some mandatory indicators identified by
Treasury. The Recovery Plan will be posted on the website of the recipient as well as
provided to Treasury. See Section C, page 22.
The reporting threshold is based on the total award amount allocated by Treasury under the
SLFRF program, not the funds received by the recipient as of the time of reporting.
States and territories are also required to submit information on their distributions to NEUs.
Please refer to Section D for additional details.
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Table 2: Reporting requirements by recipient type
Tier Recipient Interim Report
Project and
Expenditure
Report
Recovery Plan
Performance
Report
1
States, U.S. territories,
metropolitan cities and
counties with a
population that exceeds
250,000 residents
By August 31,
2021 or 60
days after
receiving
funding if
funding was
received by
October 15,
with
expenditures by
category
By January 31,
2022, and then 30
days after the end
of each quarter
thereafter9
By August 31,
2021 or 60 days
after receiving
funding, and
annually
thereafter by
July 3110
2
Metropolitan cities and
counties with a
population below
250,000 residents which
received more than $10
million in SLFRF funding
Not required
3
Tribal Governments
which received more
than $30 million in
SLFRF funding
4
Tribal Governments
which received less than
$30 million in SLFRF
funding
By April 30, 2022,
and then annually
thereafter11
5
Metropolitan cities and
counties with a
population below
250,000 residents which
received less than $10
million in SLFRF funding
6
NEUs Not required
Note: Based on the period of performance, reports will be collected through April 30, 2027. See the
specific due dates listed in Sections B and C.
The remainder of this document describes these reporting requirements. User guides
describing how and where to submit required reports will be posted at
www.treasury.gov/SLFRPReporting and updated on a regular basis.
9 Interim Final Rule Page 111
10 Interim Final Rule page 112
11 Interim Final Rule Page 111
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14
A. Interim Report
States, U.S. territories, metropolitan cities, counties, and Tribal governments are required to
submit a one-time interim report with expenditures12 by Expenditure Category covering the
period from March 3rd to July 31, 2021, by August 31, 2021 or sixty (60) days after first
receiving funding if the recipient’s date of award is between July 15, 2021 and October 15,
2021. The recipient will be required to enter obligations13 and expenditures and, for each,
select the specific expenditure category from the available options. See Appendix 1 for
Expenditure Categories (EC).
1. Required Programmatic Data
Recipients will also be required to provide the following information if they have or plan to have
expenditures in the following Expenditure Categories.
a. Revenue replacement (EC 6.114): Key inputs into the revenue replacement formula in the
Interim Final Rule and estimated revenue loss due to the Covid-19 public health
emergency calculated using the formula in the Interim Final Rule as of December 31,
2020.
• Base year general revenue (e.g., revenue in the last full fiscal year prior to the public
health emergency)
• Fiscal year end date
• Growth adjustment used (either 4.1 percent or average annual general revenue growth
over 3 years prior to pandemic)
• Actual general revenue as of the twelve months ended December 31, 2020
12 For purposes of reporting in the SLFRF portal, an expenditure is the amount that has been incurred
as a liability of the entity (the service has been rendered or the good has been delivered to the entity).
13 For purposes of reporting in the SLFRF portal, an obligation is an order placed for property and
services, contracts and subawards made, and similar transactions that require payment.
14 See Appendix 1 for the full Expenditure Category (EC) list. References to Expenditure Categories
are identified by “EC” followed by numbers from the table in Appendix 1.
Comparison to reporting for the CRF
This guidance does not change the reporting or compliance requirements pertaining to
the CRF. Reporting and compliance requirements for the SLFRF are separate from
CRF reporting requirements. Changes from CRF to SLFRF include:
• Project, Expenditure, and Subaward Reporting: The SLFRF reporting
requirements leverage the existing reporting regime used for CRF to foster
continuity and provide many recipients with a familiar reporting mechanism. The
data elements for the Project and Expenditure Report will largely mirror those used
for CRF, with some minor exceptions noted in this guidance. The users’ guide will
describe how reporting for CRF funds will relate to reporting for the SLFRF.
• Timing of Reports: CRF reports were due within 10 days of each calendar quarter
end. For quarterly reporters, SLFRF reporting will be due 30 days from quarter end.
For annual reporters, SLFRF reporting will be due on an annual schedule (see table
below).
• Program and Performance Reporting: The CRF reporting did not include any
program or performance reporting. To build public awareness and accountability
and allow Treasury to monitor compliance with eligible uses, some program and
performance reporting is required for SLFRF.
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Compliance and Reporting Guidance
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• Estimated revenue loss due to the Covid-19 public health emergency as of December
31, 2020
• An explanation of how revenue replacement funds were allocated to government
services (Note: additional instructions and/or template to be provided in users’ guide)
In calculating general revenue and the other items discussed above, recipients should
use audited data if it is available. When audited data is not available, recipients are not
required to obtain audited data if substantially accurate figures can be produced on an
unaudited basis. Recipients should use their own data sources to calculate general
revenue, and do not need to rely on revenue data published by the Census Bureau.
Treasury acknowledges that due to differences in timing, data sources, and definitions,
recipients’ self-reported general revenue figures may differ from those published by the
Census Bureau. Recipients may provide data on a cash, accrual, or modified accrual
basis, provided that recipients are consistent in their choice of methodology throughout
the covered period and until reporting is no longer required. Recipients’ reporting should
align with their own financial reporting.
In calculating general revenue, recipients should exclude all intergovernmental transfers
from the federal government. This includes, but is not limited to, federal transfers made
via a State to a locality pursuant to the CRF or SLFRF. To the extent federal funds are
passed through States or other entities or intermingled with other funds, recipients
should attempt to identify and exclude the federal portion of those funds from the
calculation of general revenue on a best-efforts basis.
Consistent with the broad latitude provided to recipients to use funds for government
services to the extent of reduction in revenue, recipients will be required to submit a
description of services provided. This description may be in narrative or in another form,
and recipients are encouraged to report based on their existing budget processes and to
minimize administrative burden. For example, a recipient with $100 in revenue
replacement funds available could indicate that $50 were used for law enforcement
operating expenses and $50 were used for pay-go building of sidewalk infrastructure. As
discussed in the Interim Final Rule, these services can include a broad range of services
but may not be used directly for pension deposits or debt service.
Reporting requirements will not require tracking the indirect effects of Fiscal Recovery
Funds, apart from the restrictions on use of Fiscal Recovery Funds to offset a reduction
in net tax revenue. In addition, recipients must indicate that Fiscal Recovery Funds were
not used to make a deposit in a pension fund.
B. Project and Expenditure Report
All recipients are required to submit Project and Expenditure Reports.
1. Quarterly Reporting
The following recipients are required to submit quarterly Project and Expenditure Reports:
• States and U.S. territories
• Tribal governments that received more than $30 million in SLFRF funding
• Metropolitan cities and counties with a population that exceeds 250,000 residents
• Metropolitan cities and counties with a population below 250,000 residents that are
allocated more than $10 million in SLFRF funding
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For these recipients, the initial quarterly Project and Expenditure Report will cover three
calendar quarters from March 3, 2021 to December 31, 2021 and must be submitted to
Treasury by January 31, 2022. The subsequent quarterly reports will cover one calendar
quarter and must be submitted to Treasury within 30 calendar days after the end of each
calendar quarter. Quarterly reports are not due concurrently with applicable annual reports.
The table below summarizes the quarterly report timelines:
Report Year Quarter Period Covered Due Date
1 2021 2 - 4 March 3 – December 31 January 31, 2022
2 2022 1 January 1 – March 31 April 30, 2022
3 2022 2 April 1 – June 30 July 31, 2022
4 2022 3 July 1 – September 30 October 31, 2022
5 2022 4 October 1 – December 31 January 31, 2023
6 2023 1 January 1 – March 31 April 30, 2023
7 2023 2 April 1 – June 30 July 31, 2023
8 2023 3 July 1 – September 30 October 31, 2023
9 2023 4 October 1 – December 31 January 31, 2024
10 2024 1 January 1 – March 31 April 30, 2024
11 2024 2 April 1 – June 30 July 31, 2024
12 2024 3 July 1 – September 30 October 31, 2024
13 2024 4 October 1 – December 31 January 31, 2025
14 2025 1 January 1 – March 31 April 30, 2025
15 2025 2 April 1 – June 30 July 31, 2025
16 2025 3 July 1 – September 30 October 31, 2025
17 2025 4 October 1 – December 31 January 31, 2026
18 2026 1 January 1 – March 31 April 30, 2026
19 2026 2 April 1 – June 30 July 31, 2026
20 2026 3 July 1 – September 30 October 31, 2026
21 2026 4 October 1 – December 31 March 31, 2027
2. Annual Reporting
The following recipients are required to submit annual Project and Expenditure Reports:
• Tribal governments that received less than $30 million in SLFRF funding
• Metropolitan cities and counties with a population below 250,000 residents that are
allocated less than $10 million in SLFRF funding
• NEUs. To facilitate reporting, each NEU will need a NEU Recipient Number. This is a
unique identification code for each NEU assigned by the State or territory to the NEU as
part of its request for funding.
For these recipients, the initial Project and Expenditure Report will cover from March 3, 2021
to March 31, 2022 and must be submitted to Treasury by April 30, 2022. The subsequent
annual reports will cover one calendar year and must be submitted to Treasury by April 30.
The table below summarizes the report timelines:
Report Period Covered Due Date
1 March 3, 2021 – March 31, 2022 April 30, 2022
2 April 1, 2022 – March 31, 2023 April 30, 2023
3 April 1, 2023 – March 31, 2024 April 30, 2024
4 April 1, 2024 – March 31, 2025 April 30, 2025
5 April 1, 2025 – March 31, 2026 April 30, 2026
6 April 1, 2026 – December 31, 2026 April 30, 2027
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3. Required Information
The following information will be required in Project and Expenditure Reports for both quarterly
and annual reporting:
a. Projects: Provide information on all SLFRF funded projects. Projects are new or existing
eligible government services or investments funded in whole or in part by SLFRF funding.
For each project, the recipient will be required to enter the project name, identification
number (created by the recipient), project expenditure category (see Appendix 1),
description, and status of completion. Project descriptions must describe the project in
sufficient detail to provide understanding of the major activities that will occur, and will be
required to be between 50 and 250 words. Projects should be defined to include only
closely related activities directed toward a common purpose. Recipients should review the
Required Programmatic Data described in 3.g. below and define their projects at a sufficient
level of granularity.
Note: For each project, the recipient will be asked to select the appropriate Expenditure
Category based on the scope of the project (see Appendix 1). Projects should be scoped
to align to a single Expenditure Category. For select Expenditure Categories, the recipient
will also be asked to provide additional programmatic data (described further below).
b. Expenditures: Once a project is entered the recipient will be able to report on the project’s
obligations and expenditures. Recipients will be asked to report:
• Current period obligation
• Cumulative obligation
• Current period expenditure
• Cumulative expenditure
c. Project Status: Once a project is entered the recipient will be asked to report on project
status each reporting period, in four categories:
• Not Started
• Completed less than 50 percent
• Completed 50 percent or more
• Completed
d. Adopted Budget (States, U.S. territories, metropolitan cities and counties with a population
that exceeds 250,000 residents only): Each state, territory and metropolitan city and county
with a population that exceeds 250,000 residents will provide the budget adopted for each
project by its jurisdiction associated with SLFRF funds. Treasury will use this information to
better understand the intended impact, identify opportunities for technical assistance, and
understand the recipient’s progress in program implementation. Treasury is not approving
or pre-approving projects or budgets.
• Recipients will enter the Adopted Budget based on information that exists currently in
the recipient’s financial systems and the recipient’s established budget process.
Treasury understands that recipients may use different budget processes. For
example, a recipient may consider a project budgeted once a legislature has
appropriated funds; whereas another recipient may consider a project budgeted at the
moment when the funds have been obligated.
• Additional information will be provided on the differences between Adopted Budget,
Obligations, and Expenditures as part of the forthcoming User Guide.
e. Project Demographic Distribution – Collection of this data will be phased in; no data will be
collected in this area before April 2022: Recognizing the disproportionate impact of the
pandemic-related recession on low-income and economically disadvantaged communities,
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the Interim Final Rule encourages recipients to direct Fiscal Recovery Funds toward
disproportionately impacted communities. Recipients are encouraged to design projects
that prioritize economic and racial equity and promote equitable outcomes. Treasury is
committed to supporting recipients in executing and reporting on projects that promote
equity. In a subsequent version of the Reporting Guidance and User Guide, which will be
released after the issuance of the Fiscal Recovery Fund Final Rule, Treasury will issue
detailed requirements for reporting the project demographic distribution of Fiscal Recovery
Fund projects.
f. Subawards: Each recipient shall also provide detailed obligation and expenditure
information for any contracts and grants awarded, loans issued, transfers made to other
government entities, and direct payments made by the recipient that are greater than
$50,000.
Recipients do not also need to submit separate monthly subaward reports to FSRS.gov as
required pursuant to the 2 CFR Part 170, Appendix A award term regarding reporting
subaward and executive compensation, which is included in the SLFRF Award Terms and
Conditions. Treasury will submit this reporting on behalf of recipients using the $50,000
reporting threshold, timing, and data elements discussed in this guidance. If recipients
choose to continue reporting to FSRS.gov in addition to reporting directly to Treasury on
these funds, they may do so and will be asked to notify Treasury as part of their quarterly
submission.
In general, recipients will be asked to provide the following information for each Contract,
Grant, Loan, Transfer, or Direct Payment greater than $50,000:
• Subrecipient identifying and demographic information (e.g., DUNS number and
location)
• Award number (e.g., Award number, Contract number, Loan number)
• Award date, type, amount, and description
• Award payment method (reimbursable or lump sum payment(s))
• For loans, expiration date (date when loan expected to be paid in full)
• Primary place of performance
• Related project name(s)
• Related project identification number(s) (created by the recipient)
• Period of performance start date
• Period of performance end date
• Quarterly obligation amount
• Quarterly expenditure amount
• Project(s)
• Additional programmatic performance indicators for select Expenditure Categories (see
below)
Aggregate reporting is required for contracts, grants, transfers made to other government
entities, loans, direct payments, and payments to individuals that are below $50,000. This
information will be accounted for by expenditure category at the project level.
As required by the 2 CFR Part 170, Appendix A award term regarding reporting subaward
and executive compensation, recipients must also report the names and total compensation
of their five most highly compensated executives and their subrecipients’ executives for the
preceding completed fiscal year if (1) the recipient received 80 percent or more of its annual
gross revenues from Federal procurement contracts (and subcontracts) and Federal
financial assistance subject to the Transparency Act, as provided by 2 CFR 170.320 (and
subawards), and received $25,000,000 or more in annual gross revenues from Federal
procurement contracts (and subcontracts) and Federal financial assistance subject to the
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Transparency Act (and subawards), and (2) if the information is not otherwise public. In
general, most SLFRF Recipients are governmental entities with executive salaries that are
already disclosed, so no additional information must be reported. The recipient is
responsible for the subrecipients’ compliance with registering and maintaining an updated
profile on SAM.gov.
g. Civil Rights Compliance: Treasury will request information on recipients’ compliance with
Title VI of the Civil Rights Act of 1964, as applicable, on an annual basis. This information
may include a narrative describing the recipient’s compliance with Title VI, along with other
questions and assurances. This collection does not apply to Tribal Governments.
h. Ineligible Activities: Tax Offset Provision (States and territories only): Treasury may collect
additional information related to the Tax Offset Provision as described in section 602(c)(2)
of the Social Security Act and implemented under 31 CFR 35.8 as part of the Project and
Expenditure Report, such as but not limited to revenue reducing covered changes. Please
see Section C.11 (Recovery Plan, Ineligible Activities: Tax Offset Provision) for more
information.
i. Required Programmatic Data (other than infrastructure projects): For all projects listed
under the following Expenditure Categories (see Appendix 1), the information listed must
be provided in each report.
1. Payroll for Public Health and Safety Employees (EC 1.9) – Collection to begin in
January 2022:
• Number of government FTEs responding to COVID-19 supported under this
authority
2. Household Assistance (EC 2.1-2.5) – Collection to begin January 2022:
• Brief description of structure and objectives of assistance program(s) (e.g., nutrition
assistance for low-income households)
• Number of households served (by program if recipient establishes multiple
separate household assistance programs)
• Brief description of recipient’s approach to ensuring that aid to households
responds to a negative economic impact of Covid-19, as described in the Interim
Final Rule
3. Small Business Economic Assistance (EC 2.9) – Collection of this data will be phased
in; no data will be collected in this area before April 2022:
• Brief description of the structure and objectives of assistance program(s) (e.g.,
grants for additional costs related to Covid-19 mitigation)
• Number of small businesses served (by program if recipient establishes multiple
separate small businesses assistance programs)
• Brief description of recipient’s approach to ensuring that aid to small businesses
responds to a negative economic impact of COVID-19, as described in the Interim
Final Rule
4. Aid to Travel, Tourism, and Hospitality or Other Impacted Industries (EC 2.11-2.12) –
Collection of this data will be phased in; no data will be collected in this area before
April 2022:
• If aid is provided to industries other than travel, tourism, and hospitality (EC 2.12),
a description of pandemic impact on the industry and rationale for providing aid to
the industry
• Brief narrative description of how the assistance provided responds to negative
economic impacts of the COVID-19 pandemic
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• For each subaward:
o Sector of employer (Note: additional detail, including list of sectors to be
provided in a users’ guide)
o Purpose of funds (e.g., payroll support, safety measure implementation)
5. Rehiring Public Sector Staff (EC 2.14) – Collection to begin in January 2022:
• Number of FTEs rehired by governments under this authority
6. Education Assistance (EC 3.1-3.5) – Collection to begin in January 2022:
• The National Center for Education Statistics (“NCES”) School ID or NCES District
ID. List the School District if all schools within the school district received some
funds. If not all schools within the school district received funds, list the School ID
of the schools that received funds. These can allow evaluators to link data from the
NCES to look at school-level demographics and, eventually, student
performance.15
7. Premium Pay (both Public Sector EC 4.1 and Private Sector EC 4.2) – Collection to
begin in January 2022:
• List of sectors designated as critical to the health and well-being of residents by
the chief executive of the jurisdiction, if beyond those included in the Interim Final
Rule (Note: a list of sectors will be provided in the forthcoming users’ guide).
• Number of workers to be served
• Employer sector for all subawards to third-party employers (i.e., employers other
than the State, local, or Tribal government) (Note: a list of sectors will be provided
in the forthcoming users’ guide).
• For groups of workers (e.g., an operating unit, a classification of worker, etc.) or,
to the extent applicable, individual workers, for whom premium pay would
increase total pay above 150 percent of their residing State’s average annual
wage, or their residing county’s16 average annual wage, whichever is higher, on
an annual basis:
o A brief written narrative justification of how the premium pay or grant is
responsive to workers performing essential work during the public health
emergency. This could include a description of the essential workers’ duties,
health or financial risks faced due to COVID-19, and why the recipient
government determined that the premium pay was responsive to workers
performing essential work during the pandemic. This description should not
include personally identifiable information; when addressing individual
workers, recipients should be careful not to include this information.
Recipients may consider describing the workers’ occupations and duties in a
general manner as necessary to protect privacy.
8. Revenue replacement (EC 6.1) – Collection began in August 2021:
Under the Interim Final Rule, recipients calculate revenue loss using data as of four
discrete points during the program: December 31, 2020, December 31, 2021,
December 31, 2022, and December 31, 2023. Revenue loss calculated as of
December 31, 2020 will be reported in the Interim Report, as described above. For
future calculation dates, revenue loss will be reported only in the Quarter 4 reports
15 For more information on NCES identification numbers see https://nces.ed.gov/ccd/districtsearch/
(districts) and https://nces.ed.gov/ccd/schoolsearch/ (schools).
16 County means a county, parish, or other equivalent county division (as defined by the Census
Bureau). See 31 CFR 35.3.
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due January 31, 2022, January 31, 2023, and January 31, 2024. Reporting on
revenue loss should include:
• General revenue collected over the past 12 months as of the most recent
calculation date, as outlined in the Interim Final Rule (for example, for the
January 31, 2022 report, recipients should provide 12 month general revenue as
of December 31, 2021).
• Calculated revenue loss due to the Covid-19 public health emergency; and
• An explanation of how the revenue replacement funds were allocated to
government services (note: additional instructions and/or template to be provided
in user guide).
In calculating general revenue and the revenue loss due to the COVID-19 public
health emergency, recipients should follow the same guidance as described above
for the Interim Report.
j. Required Programmatic Data for Infrastructure Projects (EC 5): For all projects listed under
the Water, Sewer, and Broadband Expenditure Categories (see Appendix 1), more detailed
project-level information is required. Each project will be required to report expenditure
data as described above, but will also report the following information:
1. All infrastructure projects (EC 5) – Collection to begin in January 2022:
• Projected/actual construction start date (month/year)
• Projected/actual initiation of operations date (month/year)
• Location (for broadband, geospatial location data)
• For projects over $10 million (based on expected total cost):
a. A recipient may provide a certification that, for the relevant project, all laborers
and mechanics employed by contractors and subcontractors in the
performance of such project are paid wages at rates not less than those
prevailing, as determined by the U.S. Secretary of Labor in accordance with
subchapter IV of chapter 31 of title 40, United States Code (commonly known
as the “Davis-Bacon Act”), for the corresponding classes of laborers and
mechanics employed on projects of a character similar to the contract work in
the civil subdivision of the State (or the District of Columbia) in which the work
is to be performed, or by the appropriate State entity pursuant to a corollary
State prevailing-wage-in-construction law (commonly known as “baby Davis-
Bacon Acts”). If such certification is not provided, a recipient must provide a
project employment and local impact report detailing:
▪ The number of employees of contractors and sub-contractors working on
the project;
▪ The number of employees on the project hired directly and hired through a
third party;
▪ The wages and benefits of workers on the project by classification; and
▪ Whether those wages are at rates less than those prevailing.17
Recipients must maintain sufficient records to substantiate this information
upon request.
b. A recipient may provide a certification that a project includes a project labor
agreement, meaning a pre-hire collective bargaining agreement consistent with
section 8(f) of the National Labor Relations Act (29 U.S.C. 158(f)). If the
recipient does not provide such certification, the recipient must provide a
project workforce continuity plan, detailing:
17 As determined by the U.S. Secretary of Labor in accordance with subchapter IV of chapter 31 of
title 40, United States Code (commonly known as the “Davis-Bacon Act”), for the corresponding
classes of laborers and mechanics employed on projects of a character similar to the contract work in
the civil subdivision of the State (or the District of Columbia) in which the work is to be performed.
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▪ How the recipient will ensure the project has ready access to a sufficient
supply of appropriately skilled and unskilled labor to ensure high-quality
construction throughout the life of the project;
▪ How the recipient will minimize risks of labor disputes and disruptions that
would jeopardize timeliness and cost-effectiveness of the project;
▪ How the recipient will provide a safe and healthy workplace that avoids
delays and costs associated with workplace illnesses, injuries, and
fatalities;
▪ Whether workers on the project will receive wages and benefits that will
secure an appropriately skilled workforce in the context of the local or
regional labor market; and
▪ Whether the project has completed a project labor agreement.
c. Whether the project prioritizes local hires.
d. Whether the project has a Community Benefit Agreement, with a description of
any such agreement.
2. Water and sewer projects (EC 5.1-5.15) Collection to begin in January 2022 and
required once the project starts:
• National Pollutant Discharge Elimination System (NPDES) Permit Number (if
applicable; for projects aligned with the Clean Water State Revolving Fund)
• Public Water System (PWS) ID number (if applicable; for projects aligned with the
Drinking Water State Revolving Fund)
3. Broadband projects (EC 5.16-5.17) Collection to begin in January 2022:
• Confirm that the project is designed to, upon completion, reliably meet or exceed
symmetrical 100 Mbps download and upload speeds.
o If the project is not designed to reliably meet or exceed symmetrical 100
Mbps download and upload speeds, explain why not, and
o Confirm that the project is designed to, upon completion, meet or exceed
symmetrical 100 Mbps download speed and between at least 20 Mbps and
100 Mbps upload speed, and be scalable to a minimum of 100 Mbps
download speed and 100 Mbps upload speed.
• Please note: additional programmatic data will be required for broadband projects
beginning in July 2022 and will be defined in a subsequent version of the Reporting
Guidance.
k. NEU Documentation (NEUs only): Each NEU will also be asked to provide the following
information once their accounts are established in Treasury’s Reporting Portal and prior to
the due date for their first annual Project and Expenditure Report (due April 30, 2022):
• Copy of the signed award terms and conditions agreement (which was signed and
submitted to the State as part of the request for funding)
• Copy of the signed assurances of compliance with Title VI of the Civil Rights Act of
1964 (which was signed and submitted to the State as part of the request for funding)
• Copy of actual budget documents validating the top-line budget total provided to the
State as part of the request for funding
NEU accounts will be established in Treasury’s Portal based on information provided by
the States or territories, as further described in Section Part 2 D below.
C. Recovery Plan Performance Report
States, territories, metropolitan cities, and counties with a population that exceeds 250,000
residents will also be required to publish and submit to Treasury a Recovery Plan performance
report (“Recovery Plan”). Each Recovery Plan must be posted on the public-facing website of
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the recipient by the same date the recipient submits the report to Treasury. This reporting
requirement includes uploading a link to the publicly available document report along with
providing data in the Treasury reporting portal.
The Recovery Plan will provide the public and Treasury information on the projects recipients
are undertaking with program funding and how they are planning to ensure program outcomes
are achieved in an effective, efficient, and equitable manner. While this guidance outlines
some minimum requirements for the Recovery Plan, each recipient is encouraged to add
information to the plan they feel is appropriate to provide information to their constituents on
efforts they are taking to respond to the pandemic and promote economic recovery. Each
jurisdiction may determine the general form and content of the Recovery Plan, as long as it
includes the minimum information determined by Treasury. Treasury will provide a
recommended template but recipients may modify this template as appropriate for their
jurisdiction. The Recovery Plan will include key performance indicators identified by the
recipient and some mandatory indicators identified by Treasury.
The initial Recovery Plan will cover the period from the date of award to July 31, 2021 and
must be submitted to Treasury by August 31, 2021, or 60 days after receiving funding.
Thereafter, the Recovery Plan will cover a 12-month period and recipients will be required to
submit the report to Treasury within 30 days after the end of the 12-month period (by July 31).
The table below summarizes the report timelines:
Annual
Report
Period Covered Due Date
1 Award Date – July 31, 2021 August 31, 2021
2 July 1, 2021 – June 30, 2022 July 31, 2022
3 July 1, 2022 – June 30, 2023 July 31, 2023
4 July 1, 2023 – June 30, 2024 July 31, 2024
5 July 1, 2024 – June 30, 2025 July 31, 2025
6 July 1, 2025 – June 30, 2026 July 31, 2026
7 July 1, 2026 – December 31, 2026 March 31, 2027
The Recovery Plan will include, at a minimum, the following information:
1. Executive Summary
Provide a high-level overview of the jurisdiction’s intended and actual uses of funding
including, but not limited to: the jurisdiction’s plan for use of funds to promote a response to
the pandemic and economic recovery, key outcome goals, progress to date on those
outcomes, and any noteworthy challenges or opportunities identified during the reporting
period.
2. Uses of Funds
Describe in further detail your jurisdiction’s intended and actual uses of the funds, such as
how your jurisdiction’s approach would help support a strong and equitable recovery from the
COVID-19 pandemic and economic downturn. Describe any strategies employed to maximize
programmatic impact and effective, efficient, and equitable outcomes. Given the broad eligible
uses of funds and the specific needs of the jurisdiction, please also explain how the funds
would support the communities, populations, or individuals in your jurisdiction. Your
description should address how you are promoting each of the following, to the extent they
apply:
a. Public Health (EC 1): As relevant, describe how funds are being used to respond to
COVID-19 and the broader health impacts of COVID-19 and the COVID-19 public health
emergency.
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b. Negative Economic Impacts (EC 2): As relevant, describe how funds are being used to
respond to negative economic impacts of the COVID-19 public health emergency,
including to households and small businesses.
c. Services to Disproportionately Impacted Communities (EC 3): As relevant, describe how
funds are being used to provide services to communities disproportionately impacted by
the COVID-19 public health emergency.
d. Premium Pay (EC 4): As relevant, describe the approach, goals, and sectors or
occupations served in any premium pay program. Describe how your approach prioritizes
low-income workers.
e. Water, sewer, and broadband infrastructure (EC 5): Describe the approach, goals, and
types of projects being pursued, if pursuing.
f. Revenue Replacement (EC 6): Describe the loss in revenue due to the COVID-19 public
health emergency and how funds have been used to provide government services.
Where appropriate, recipients should also include information on your jurisdiction’s use (or
planned use) of other federal recovery funds including other programs under the American
Rescue Plan such as Emergency Rental Assistance, Housing Assistance, and so forth, to
provide broader context on the overall approach for pandemic recovery.
3. Promoting equitable outcomes
Describe efforts to promote equitable outcomes, including how programs were designed with
equity in mind. Please include in your description how your jurisdiction will consider and
measure equity at the various stages of the program, including:
a. Goals: Are there particular historically underserved, marginalized, or adversely affected
groups that you intend to serve within your jurisdiction?
b. Awareness: How equal and practical is the ability for residents or businesses to become
aware of the services funded by the SLFRF?
c. Access and Distribution: Are there differences in levels of access to benefits and services
across groups? Are there administrative requirements that result in disparities in ability to
complete applications or meet eligibility criteria?
d. Outcomes: Are intended outcomes focused on closing gaps, reaching universal levels of
service, or disaggregating progress by race, ethnicity, and other equity dimensions
where relevant for the policy objective?
Treasury encourages uses of funds that promote strong, equitable growth, including racial
equity. Please describe how your jurisdiction’s planned or current use of funds prioritizes
economic and racial equity as a goal, names specific targets intended to produce meaningful
equity results at scale, and articulates the strategies to achieve those targets. In addition,
please explain how your jurisdiction’s overall equity strategy translates into the specific
services or programs offered by your jurisdiction in the following Expenditure Categories:
a. Negative Economic Impacts (EC 2): assistance to households, small businesses, and
non-profits to address impacts of the pandemic, which have been most severe among
low-income populations. This includes assistance with food, housing, and other needs;
employment programs for people with barriers to employment who faced negative
economic impacts from the pandemic (such as residents of low-income neighborhoods,
minorities, disconnected youth, the unemployed, formerly incarcerated people, veterans,
and people with disabilities); and other strategies that provide disadvantaged groups with
access to education, jobs, and opportunity.
b. Services to Disproportionately Impacted Communities (EC 3): services to address health
disparities and the social determinants of health, build stronger neighborhoods and
communities (e.g., affordable housing), address educational disparities (e.g., evidence-
based tutoring, community schools, and academic, social-emotional, and mental health
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supports for high poverty schools), and promote healthy childhood environments (e.g.,
home visiting, child care).
The initial report must describe efforts to date and intended outcomes to promote equity.
Each annual report thereafter must provide an update, using qualitative and quantitative
data, on how the recipients’ approach achieved or promoted equitable outcomes or
progressed against equity goals during the performance period. Please also describe any
constraints or challenges that impacted project success in terms of increasing equity. In
particular, this section must describe the geographic and demographic distribution of
funding, including whether it is targeted toward traditionally marginalized communities.
For the purposes of the SLFRF, equity is described in the Executive Order 13985 On
Advancing Racial Equity and Support for Underserved Communities Through the Federal
Government, as issued on January 20, 2021.
4. Community Engagement
Please describe how your jurisdiction’s planned or current use of funds incorporates written,
oral, and other forms of input that capture diverse feedback from constituents, community-
based organizations, and the communities themselves. Where relevant, this description must
include how funds will build the capacity of community organizations to serve people with
significant barriers to services, including people of color, people with low incomes, limited
English proficient populations, and other traditionally underserved groups.
5. Labor Practices
Describe workforce practices on any infrastructure projects being pursued (EC 5). How are
projects using strong labor standards to promote effective and efficient delivery of high-quality
infrastructure projects while also supporting the economic recovery through strong
employment opportunities for workers? For example, report whether any of the following
practices are being utilized: project labor agreements, community benefits agreements,
prevailing wage requirements, and local hiring.
6. Use of Evidence
The Recovery Plan should identify whether SLFRF funds are being used for evidence-based
interventions18 and/or if projects are being evaluated through rigorous program evaluations
that are designed to build evidence. Recipients must briefly describe the goals of the project,
and the evidence base for the interventions funded by the project. Recipients must specifically
identify the dollar amount of the total project spending that is allocated towards evidence-
based interventions for each project in the Public Health (EC 1), Negative Economic Impacts
(EC 2), and Services to Disproportionately Impacted Communities (EC 3) Expenditure
Categories.19
Recipients are exempt from reporting on evidence-based interventions in cases where a
program evaluation is being conducted. Recipients are encouraged to use relevant evidence
Clearinghouses, among other sources, to assess the level of evidence for their interventions
and identify evidence-based models that could be applied in their jurisdiction; such evidence
clearinghouses include the U.S. Department of Education’s What Works Clearinghouse, the
U.S. Department of Labor’s CLEAR, and the Childcare & Early Education Research
Connections and the Home Visiting Evidence of Effectiveness clearinghouses from
18As noted in Appendix 2, evidence-based refers to interventions with strong or moderate levels of
evidence.
19 Of note, recipients are only required to report the amount of the total funds that are allocated to
evidence-based interventions in the areas of Public Health, Negative Economic Impacts, and Services
to Disproportionately Impacted Communities that are marked by an asterisk in Appendix 1:
Expenditure Categories.
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Administration for Children and Families, as well as other clearinghouses relevant to particular
projects conducted by the recipient. In such cases where a recipient is conducting a program
evaluation in lieu of reporting the amount of spending on evidence-based interventions, they
must describe the evaluation design including whether it is a randomized or quasi-
experimental design; the key research questions being evaluated; whether the study has
sufficient statistical power to disaggregate outcomes by demographics; and the timeframe for
the completion of the evaluation (including a link to completed evaluation if relevant).20 Once
the evaluation has been completed, recipients must post the evaluation publicly and link to the
completed evaluation in the Recovery Plan. Once an evaluation has been completed (or has
sufficient interim findings to determine the efficacy of the intervention), recipients should
determine whether the spending for the evaluated interventions should be counted towards
the dollar amount categorized as evidence-based for the relevant project.
For all projects, recipients may be selected to participate in a national evaluation, which would
study their project along with similar projects in other jurisdictions that are focused on the same
set of outcomes. In such cases, recipients may be asked to share information and data that is
needed for the national evaluation.
Recipients are encouraged to consider how a Learning Agenda, either narrowly focused on
SLFRF or broadly focused on the recipient’s broader policy agenda, could support their
overarching evaluation efforts in order to create an evidence-building strategy for their
jurisdiction.21
Appendix 2 contains additional information on evidence-based interventions for the purposes
of the Recovery Plan.
7. Table of Expenses by Expenditure Category
Please include a table listing the amount of funds used in each Expenditure Category (See
Appendix 1). The table should include cumulative expenses to date within each category, and
the additional amount spent within each category since the last annual Recovery Plan.
8. Project Inventory
List the name and provide a brief description of all SLFRF funded projects. Projects are new
or existing eligible government services or investments funded in whole or in part by SLFRF
funding. For each project, include the project name, funding amount, identification number
(created by the recipient and used thereafter in the quarterly Program and Expenditure
Report), project Expenditure Category (see Appendix 1), and a description of the project which
includes an overview of the main activities of the project, the approximate timeline, primary
delivery mechanisms and partners, if applicable, and intended outcomes. Include a link to the
website of the project if available. This information will provide context and additional detail
for the information reported quarterly in the Project and Expenditure Report.
For infrastructure investment projects (EC 5), project-level reporting will be more detailed, as
described for the Project and Expenditure Report above. Projects in this area may be grouped
by Expenditure Category if needed, with further detail (such as the specific project name and
identification number) provided in the Project and Expenditure Report. For infrastructure
projects, descriptions should note how the project contributes to addressing climate change.
9. Performance Report
The Recovery Plan must include key performance indicators for the major SLFRF funded
projects undertaken by the recipient. The recipient has flexibility in terms of how this
information is presented in the Recovery Plan, and may report key performance indicators for
20 For more information on the required standards for program evaluation, see OMB M-20-12.
21 For more information on learning agendas, please see OMB M-19-23
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each project, or may group projects with substantially similar goals and the same outcome
measures. In some cases, the recipient may choose to include some indicators for each
individual project as well as crosscutting indicators.
Performance indicators should include both output and outcome measures. Output measures,
such as number of students enrolled in an early learning program, provide valuable information
about the early implementation stages of a project. Outcome measures, such as the percent
of students reading on grade level, provide information about whether a project is achieving
its overall goals. Recipients are encouraged to use logic models22 to identify their output and
outcome measures. While the initial report will focus heavily on early output goals, recipients
must include the related outcome goal for each project and provide updated information on
achieving these outcome goals in annual reports. In cases where recipients are conducting a
program evaluation for a project (as described above), the outcome measures in the
performance report should be aligned with those being evaluated in the program. To support
their performance measurement and program improvement efforts, recipients are permitted to
use funds to make improvements to data or technology infrastructure and data analytics, as
well as program evaluations.
10. Required Performance Indicators and Programmatic Data
While recipients have discretion on the full suite of performance indicators to include, a number
of mandatory performance indicators and programmatic data must be included. These are
necessary to allow Treasury to conduct oversight as well as understand and aggregate
program outcomes across recipients. This section provides an overview of the mandatory
performance indicators and programmatic data. This information may be included in each
recipient’s Recovery Plan as they determine most appropriate, including combining with the
section above, but this data will also need to be entered directly into the Treasury reporting
portal. Below is a list of required data for each Expenditure Category:
a. Household Assistance (EC 2.2 & 2.5) and Housing Support (EC 3.10-3.12):
• Number of people or households receiving eviction prevention services (including legal
representation)
• Number of affordable housing units preserved or developed
b. Negative Economic Impacts (EC 2):
• Number of workers enrolled in sectoral job training programs
• Number of workers completing sectoral job training programs
• Number of people participating in summer youth employment programs
c. Education Assistance (EC 3.1-3.5):
• Number of students participating in evidence-based tutoring programs23
d. Healthy Childhood Environments (EC 3.6-3.9):
• Number of children served by childcare and early learning (pre-school/pre-K/ages 3-
5)
• Number of families served by home visiting
The initial report should include the key indicators above. Each annual report thereafter should
include updated data for the performance period as well as prior period data, and a brief
22 A logic model is a tool that depicts the intended links between program investments and outcomes,
specifically the relationships among the resources, activities, outputs, outcomes, and impact of a
program.
23 For more information on evidence-based tutoring programs, refer to the U.S. Department of
Education’s 2021 ED COVID-19 Handbook (Volume 2), which summarizes research on evidence-
based tutoring programs (see the bottom of page 20.
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narrative adding any additional context to help the reader interpret the results and understand
the any changes in performance indicators over time. To the extent possible, Treasury also
encourages recipients to provide data disaggregated by race, ethnicity, gender, income, and
other relevant factors.
11. Ineligible Activities: Tax Offset Provision (States and territories only)
The following information is required for Treasury to ensure SLFRF funding is not used for
ineligible activities.
In each reporting year, States and territories will report certain items related to the Tax Offset
Provision as described in section 602(c)(2) of the Social Security Act and implemented by 31
CFR 35.8. Additional guidance will be forthcoming for reporting requirements regarding the
tax offset provision and additional information that Recipients will report once the Final Rule
goes into effect.
a. Revenue-reducing Covered Changes: Collection began August 2021:
For each reporting year, a recipient must report the value of covered changes that the
recipient predicts will have the effect of reducing tax revenue in a given reporting year
(revenue-reducing covered changes), similar to the way it would in the ordinary course of
its budgeting process. The value of these covered changes may be reported based on
estimated values produced by a budget model, incorporating reasonable assumptions,
that aligns with the recipient government’s existing approach for measuring the effects of
fiscal policies, and that measures relative to a current law baseline. The covered changes
may also be reported based on actual values using a statistical methodology to isolate the
change in year-over-year revenue attributable to the covered change(s), relative to the
current law baseline prior to the change(s). Estimation approaches should not use
dynamic methodologies that incorporate the projected effects of the policies on
macroeconomic growth. In general, and where possible, reported values should be
produced by the agency of the recipient government responsible for estimating the costs
and effects of fiscal policy changes. Recipients must maintain records regarding the
identification and predicted effects of revenue-reducing covered changes. The term
“covered change,”” and “tax revenue” are described in the Interim Final Rule, 31 CFR 35.3.
For additional information, see 602(c)(2) of the Social Security Act, the Interim Final Rule,
and 31 CFR 35.8.
D. Distributions to NEUs
Each State and territory is asked to provide regular updates on their NEU distribution as well
as their distributions to units of general local government within counties that are not units of
general local government (Non-UGLG). The distribution template generally requests
information on whether the local government has (1) received funding; (2) declined funding
and requested a transfer to the State under Section 603(c)(4) of the Act; or (3) not taken
action on its funding or declined funding.
For NEUs, states and territories should be prepared to report on their information, including
the following:
• NEU name
• NEU DUNS number
• NEU Taxpayer Identification Number (TIN)
• NEU Recipient Number (a unique identification code for each NEU assigned by the
State or territory to the NEU as part of the request for funding)
• NEU contact information (e.g., address, point of contact name, point of contact email
address, and point of contact phone number)
• NEU authorized representative name and email address
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• Initial allocation and, if applicable, subsequent allocation to the NEU (before
application of the 75 percent cap)
• Total NEU reference budget (as submitted by the NEU to the State or territory as part
of the request for funding)
• Amount of the initial and, if applicable, subsequent allocation above 75 percent of the
NEU’s reference budget which will be returned to Treasury
• Payment amount(s)
• Payment date(s)
States with “weak” minor civil divisions (i.e., Illinois, Indiana, Kansas, Missouri, Nebraska,
North Dakota, Ohio, and South Dakota) should also list any minor civil divisions that the
State deemed ineligible.
For each eligible NEU that declined funding and requested a transfer to the State under
Section 603(c)(4), the State or territory must also attach a form signed by the NEU, as
detailed in the Guidance on Distributions of Funds to Non-Entitlement Units of Local
Government.
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Appendix 1: Expenditure Categories
The Expenditure Categories (EC) listed below must be used to categorize each project as
noted in Part 2 above. The term “Expenditure Category” refers to the detailed level (e.g., 1.1
COVID-10 Vaccination). When referred to as a category (e.g., EC 1) it includes all Expenditure
Categories within that level.
1: Public Health
1.1 COVID-19 Vaccination ^
1.2 COVID-19 Testing ^
1.3 COVID-19 Contact Tracing
1.4 Prevention in Congregate Settings (Nursing Homes, Prisons/Jails, Dense Work Sites,
Schools, etc.)*
1.5 Personal Protective Equipment
1.6 Medical Expenses (including Alternative Care Facilities)
1.7 Capital Investments or Physical Plant Changes to Public Facilities that respond to the
COVID-19 public health emergency
1.8 Other COVID-19 Public Health Expenses (including Communications, Enforcement,
Isolation/Quarantine)
1.9 Payroll Costs for Public Health, Safety, and Other Public Sector Staff Responding to
COVID-19
1.10 Mental Health Services*
1.11 Substance Use Services*
1.12 Other Public Health Services
2: Negative Economic Impacts
2.1 Household Assistance: Food Programs* ^
2.2 Household Assistance: Rent, Mortgage, and Utility Aid* ^
2.3 Household Assistance: Cash Transfers* ^
2.4 Household Assistance: Internet Access Programs* ^
2.5 Household Assistance: Eviction Prevention* ^
2.6 Unemployment Benefits or Cash Assistance to Unemployed Workers*
2.7 Job Training Assistance (e.g., Sectoral job-training, Subsidized Employment,
Employment Supports or Incentives)* ^
2.8 Contributions to UI Trust Funds
2.9 Small Business Economic Assistance (General)* ^
2.10 Aid to Nonprofit Organizations*
2.11 Aid to Tourism, Travel, or Hospitality
2.12 Aid to Other Impacted Industries
2.13 Other Economic Support* ^
2.14 Rehiring Public Sector Staff
3: Services to Disproportionately Impacted Communities
3.1 Education Assistance: Early Learning* ^
3.2 Education Assistance: Aid to High-Poverty Districts ^
3.3 Education Assistance: Academic Services* ^
3.4 Education Assistance: Social, Emotional, and Mental Health Services* ^
3.5 Education Assistance: Other* ^
3.6 Healthy Childhood Environments: Child Care* ^
3.7 Healthy Childhood Environments: Home Visiting* ^
3.8 Healthy Childhood Environments: Services to Foster Youth or Families Involved in
Child Welfare System* ^
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3.9 Healthy Childhood Environments: Other* ^
3.10 Housing Support: Affordable Housing* ^
3.11 Housing Support: Services for Unhoused Persons* ^
3.12 Housing Support: Other Housing Assistance* ^
3.13 Social Determinants of Health: Other* ^
3.14 Social Determinants of Health: Community Health Workers or Benefits Navigators* ^
3.15 Social Determinants of Health: Lead Remediation ^
3.16 Social Determinants of Health: Community Violence Interventions* ^
4: Premium Pay
4.1 Public Sector Employees
4.2 Private Sector: Grants to Other Employers
5: Infrastructure24
5.1 Clean Water: Centralized Wastewater Treatment
5.2 Clean Water: Centralized Wastewater Collection and Conveyance
5.3 Clean Water: Decentralized Wastewater
5.4 Clean Water: Combined Sewer Overflows
5.5 Clean Water: Other Sewer Infrastructure
5.6 Clean Water: Stormwater
5.7 Clean Water: Energy Conservation
5.8 Clean Water: Water Conservation
5.9 Clean Water: Nonpoint Source
5.10 Drinking water: Treatment
5.11 Drinking water: Transmission & Distribution
5.12 Drinking water: Transmission & Distribution: Lead Remediation
5.13 Drinking water: Source
5.14 Drinking water: Storage
5.15 Drinking water: Other water infrastructure
5.16 Broadband: “Last Mile” projects
5.17 Broadband: Other projects
6: Revenue Replacement
6.1 Provision of Government Services
7: Administrative
7.1 Administrative Expenses
7.2 Evaluation and Data Analysis
7.3 Transfers to Other Units of Government
7.4 Transfers to Non-entitlement Units (States and territories only)
*Denotes areas where recipients must identify the amount of the total funds that are allocated
to evidence-based interventions (see Use of Evidence section above for details)
^Denotes areas where recipients must report on whether projects are primarily serving
disadvantaged communities (see Project Demographic Distribution section above for details)
24 Definitions for water and sewer Expenditure Categories can be found in the EPA’s handbooks. For
“clean water” expenditure category definitions, please see:
https://www.epa.gov/sites/production/files/2018-03/documents/cwdefinitions.pdf. For “drinking water”
expenditure category definitions, please see: https://www.epa.gov/dwsrf/drinking-water-state-
revolving-fund-national-information-management-system-reports.
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Appendix 2: Evidenced-Based Intervention Additional Information
What is evidence-based?
For the purposes of the SLFRF, evidence-based refers to interventions with strong or
moderate evidence as defined below:
Strong evidence means that the evidence base can support causal conclusions for the specific
program proposed by the applicant with the highest level of confidence. This consists of one
or more well-designed and well-implemented experimental studies conducted on the proposed
program with positive findings on one or more intended outcomes.
Moderate evidence means that there is a reasonably developed evidence base that can
support causal conclusions. The evidence base consists of one or more quasi-experimental
studies with positive findings on one or more intended outcomes OR two or more non-
experimental studies with positive findings on one or more intended outcomes. Examples of
research that meet the standards include: well-designed and well-implemented quasi-
experimental studies that compare outcomes between the group receiving the intervention
and a matched comparison group (i.e., a similar population that does not receive the
intervention).
Preliminary evidence means that the evidence base can support conclusions about the
program’s contribution to observed outcomes. The evidence base consists of at least one non-
experimental study. A study that demonstrates improvement in program beneficiaries over
time on one or more intended outcomes OR an implementation (process evaluation) study
used to learn and improve program operations would constitute preliminary evidence.
Examples of research that meet the standards include: (1) outcome studies that track program
beneficiaries through a service pipeline and measure beneficiaries’ responses at the end of
the program; and (2) pre- and post-test research that determines whether beneficiaries have
improved on an intended outcome.
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Revision Log
Version Date Published Summary of changes
1.0 June 17, 2021 Initial publication
1.1 June 24, 2021 • Pg. 12, removed references to “summary” level with
respect to reporting by Expenditure Categories in
the Interim Report to avoid confusion.
• Pg. 13, revised the coverage period end date for the
Interim Report from June 30, 2021 to July 31, 2021
to align with the IFR.
• Pg. 13, removed references to “summary” level with
respect to reporting by Expenditure Categories in
the Interim Report to avoid confusion.
• Pg. 31, removed references to “summary level” with
respect to Expenditure Categories in Appendix 1 to
avoid confusion.
1.1 September 30, 2021
• Announced the extension in the Project and
Expenditure Report submission date, originally due
on October 31, 2021.
2.0 November 5, 2021 • Updated Subrecipient Monitoring section to clarify
beneficiaries and recipients.
• Updated references to Interim Final Rule comment
period as comment period is closed.
• Updated reporting tiers, thresholds and timelines in
Part 2 Table 2, Reporting Requirements by recipient
type, as well as Part 2 A and Part 2 B.
• Updated reporting periods for Interim Report and
Project and Expenditure reports.
• Added concept of Adopted Budget to Project and
Expenditure Report data fields.
• Noted phase in of Required Programmatic Data in
the Project and Expenditure Report.
• Removed certain data fields from the Ineligible
Activities: Tax Offset Provision under the Recovery
Plan.
• Separated reporting of NEU Distributions (for States
and territories) from the Interim Report and Project
and Expenditure Reports as information will be
provided on an ongoing basis.
2.1 November 15, 2021 • Updated pages 9 and 11 to note that civil rights
certification is not applicable to Tribal Governments.
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