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American REscue Plan Act (ARPA) Resources

Federal funding from the American Rescue Plan Act will be coming to the State of Oklahoma. We are gathering information and resources for your city or town to understand the process and make plans for the funding. We will continue to update here regularly.

It is recommended that cities and towns in Oklahoma begin to consider the use of funding that will be available shortly as a result of the stimulus legislation passed by Congress.

Receiving a payment from funds made available this relevant section of the ARA shall only use such amounts to—

“(A) respond to or mitigate the public health emergency with respect to the Coronavirus Disease 2019 (COVID-19) or its NEGATIVE ECONOMIC IMPACTS;

“(B) cover costs incurred as a result of such emergency;

“(C) REPLACE REVENUE THAT WAS LOST, DELAYED, OR DECREASED (as determined based on revenue projections…as of January 27, 2020) as a result of such emergency; or

“(D) ADDRESS THE NEGATIVE ECONOMIC IMPACTS of such emergency.

While it is speculative at this point to interpret definitive allowable use of ARPA funds, come potential interpretive examples MIGHT be (caution:  if NOT previously claimed under the CARES Act):

Using the 2019 Calendar Budget (which crosses by month two of most cities and towns Fiscal Years) as the basis:

  • Budget cuts that might have been made or not realized to be done because of the Revenue side of the 2019 calendar year budget had a shortfall from the projected Revenue budget.

  • Reimbursement for any direct Covid related expenses not budgeted but that were made in order to meet the demands of the pandemic (and not previously reimbursed)

  • Because of negative economic impacts to city and town economies, to structure incentives, infrastructure improvements, marketing, etc. related to recruiting, expanding, and maintaining the local economy.

  • Rehire furloughed personnel.

These are just some examples that MIGHT qualify.  We will be looking to provide you with further guidance on the use of the ARPA as more definitive information is forthcoming.

Treasury just released its guidance on pre-award requirements that outline immediate steps recipients need to take in order to receive Recovery Funds. This information may be especially important to smaller governments or government that have not received federal funding, so please distribute to your networks.

Submission instructions to the US Treasury will very likely follow soon, but as of now those instructions are not yet available. We would suggest, though, that as a part of this preparation process, your executive or authorized officer is prepared to certify the submission.

As outlined in Treasury’s guidance, eligible recipients should take the below steps as soon as possible:

  1. Ensure the entity has a valid DUNS number. A DUNS number is a unique nine-character number used to identify an organization and is issued by Dun & Bradstreet. The federal government uses the DUNS number to track how federal money is allocated. A DUNS number is required prior to registering with the SAM database, which is outlined below. Registering for a DUNS number is free of charge.
    If an entity does not have a valid DUNS number, please visit https://fedgov.dnb.com/webform/ or call 1-866-705-5711 to begin the registration process.

  2. Ensure the entity has an active SAM registration. SAM is the official government-wide database to register with in order to do business with the U.S. government. All Federal financial assistance recipients must register on SAM.gov and renew their SAM registration annually to maintain an active status to be eligible to receive Federal financial assistance. There is no charge to register or maintain your entity SAM registration.
    If an entity does not have an active SAM registration, please visit, SAM.gov to begin the entity registration or renewal process. Please note that SAM registration can take up to three weeks; delay in registering in SAM could impact timely payment of funds.
    Click here for a quick overview for SAM registration

  3. Gather the entity’s payment information, including:

    • Entity Identification Number (EIN), name, and contact information

    • Name and title of an authorized representative of the entity

    • Financial institution information (e.g., routing and account number, financial institution name and contact information)

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

https://home.treasury.gov/policy-issues/coronavirus/assistance-for-state-local-and-tribal-governments/state-and-local-fiscal-recovery-fund

External Resources

US Treasury’s NEU Guidance

US Treasury’s SLFRF Compliance and Reporting Guidance

US Treasury’s SLFRP FAQ

Executive Order 2021-11 (Oklahoma)

National League of Cities FAQ

National League of Cities PowerPoint

US Treasury

ICMA

GFOA Guiding Principles

Centers for Medicare & Medicaid Services

COVID Relief for Airports

A Breakdown of the American Rescue Plan

How Should Local Leaders Use Their ARPA Funding

Accounting for Funds

NACO

NACO - Treasury Guidelines

NACO - The Act Text 2021

Treasury Rules

State and Local Recovery Funds for Non-Entitlement Units