Now you know the high-level requirements, the funding purposes and the keys to helping the decision-makers fund your project/programs with ARPA funds.
The money is here now, and more is coming with most local governments having received half of their funds in June 2021 and the second half expected in May 2022 and the clock to distribute these funds is ticking. Local governments fund expenditures must be justified according to US Treasury Guidance’s and incurred by December 31, 2024. The timeframe for the project work must be performed and completed with the funds fully expended by December 31, 2026. If the ARPA spending dollars are not expensed or in-appropriately expensed by the deadline then those funds must be returned to the US Treasury. When it comes to how the ARPA funds must be expensed, there are two general purposes, firstly to Rescue and secondly to Rebuild Better. When it comes to appropriate ways in which the funding can be used, there are five primary ways. 1- Replacement of lost revenues to local governments. 2- Fund Public Health responses. 3- Address negative economic impacts for businesses, workers in impacted industries. 4- Provide premium funding for essential workers retroactively back to January 27, 2020. 5- Invest into water, sewer, and broadband infrastructure. There are also NO-NO’s with the ARPA funding and those include; reducing unfunded pension liabilities, funding general infrastructure, and economic development projects un-related to COVID-19, for use as a non-Federal match amount for Federal grant applications, to make debt servicing payments, pay legal settlements or deposits into Rainy Day Funds. Now that the high-level requirements are outlined, we will explore more of the funding purposes as they apply to certain program/projects for which you may be seeking funding.
When it comes to programs/projects that Support Public Health Responses it is necessary to fulfill one or more of the funding purposes listed below:
- Activities that prevent and mitigate COVID-19
- Providing COVID-19 treatment and medical services
- Enhancing mental and behavioral health services which were negatively impacted by the pandemic
- Supporting local workforce providing health and safety services
- Improving public health programs
- Reducing disparities in public health outcomes
If your project/program Address Negative Economic Impacts, then it must fulfill one or more of the funding purposes, with a preference for serving the most disproportionately impacted groups:
- Providing assistance to households
- Supporting non-profits and small businesses
- Providing aid to those industries impacted by the pandemic
- Rehiring laid-off local government staff
- Providing training to unemployed workers
- Improving the performance of economic relief programs
- Proving services for residents living in Qualified Census Tracts (QCT) and other disproportionately impacted communities
Third-party employers that are seeking premium pay for essential workers must have employees performing contracted work to local governments in the following roles:
- Social and human services staff.
- Childcare workers and educators.
- Public health and safety staff.
- Truck drivers, transit and warehouse staff.
- Janitors and sanitation staff.
- Food production, grocery and restaurant staff.
- Nursing home, hospital and home-care staff.
Water, Sewer, and Broadband Infrastructure projects related to COVID-19 must fulfill one or more of the following funding purposes:
- Provide or improve clean drinking water.
- Create green infrastructure.
- Project water from pollution.
- Improve infrastructure resilience.
- Build, improve, or repair wastewater treatment plants.
- Flood Control or manage stormwater runoff.
- Provide internet to unserved and underserved households.
Every Leader in Coconino County, both those elected and employed, has the responsibility to steward the ARPA funding and publicly expense it or invest it into programs and projects that meet the eligibility requirements. The leaders must also face the scrutiny of the public as expenses and investment (both amounts and purposes) are published, these decisions and their impacts will be very transparent, thus reinforcing the importance of your program/project’s justifications. Demonstrating the need is often generalized but when it comes to ARPA funded activities, the general and biggest need is not enough. It is clear from the US Treasury Guidance that specifically targeting a disproportionately impacted demographic will be preferable to identify a general population need. Use the Qualifying Census Tracts and other economic data sets to focus on those populations most negatively impacted and be prepared to report on your outcomes. Reporting on your project/program outcomes on a quarterly basis should be expected as Local Governments must report on outcomes and expenses for any ARPA-subrecipient who received more than $50,000. These ARPA funds while great and unprecedented are not without strings attached. In order to make sure your project/program request for ARPA funding is thoughtfully considered by leaders, make sure your purposes are clear, your justification detailed, and your outcomes specific and regularly reportable. Now you know the high-level requirements, the funding purposes and the keys to helping the decision-makers fund your project/programs with ARPA funds. If you want to discuss your project in more detail or want assistance with justifications, please contact me. FBN
By Chris Pasterz
Chris Pasterz is the economic development manager for Coconino County. He can be reached at cpasterz@cococino.az.gov or 928-679-7134.