Toolkit
BASIC COMPLIANCE | Sample policies that must be adopted by all counties and municipalities, regardless of how much funding they received or how they expend their ARP/CSLFRF funds.
ARP/CSLFRF Sample Eligible Use Policy
Per 2 CFR Part 200.303, a local government must develop and implement effective internal controls to ensure that funding decisions under the SLFRF award constitute eligible uses of funds, and document determinations. The eligible use policy provides details allowable and prohibited expenditures and prescribes a process for approving and documenting ARP/CSLFRF-eligible projects.
part of Basic Compliance
Download Sample Eligible Use Policy as a Word document
ARP/CSLFRF Sample Allowable Cost Policy
The expenditures for each eligible ARP/CSLFRF project are comprised of cost items. Typical cost items include compensation and fringe benefits, materials and supplies, equipment and other capital, consultants/professional services, audits, communications, insurance, maintenance and repair, and rental costs. To ensure that the cost items within an eligible project are proper, a local government must adopt and implement an allowable costs and cost principles policy. That policy will accomplish three different goals: (1) General review that a cost item is reasonable, allowable, allocable, consistently treated, and properly documented; (2) Identification of direct or indirect cost allocation for administrative expenses; and (3) Specific review of certain identified cost items, for special treatment, justification, and/or documentation. (Note that some aspects of this policy will not apply to Revenue Replacement expenditures.) Learn more about the sample allowable cost policy in this explanatory blog post >> Blog Post
part of Basic Compliance
Download Sample Allowable Cost Policy as a Word document
ARP/CSLFRF Sample Nondiscrimination (Civil Rights Compliance) Policy
Local government-recipients of ARP/CSLFRF funds are required to meet legal requirements relating to nondiscrimination and nondiscriminatory use of the Federal funds. A local government may 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 federal law. A local government must adopt and implement a written nondiscrimination policy to ensure compliance with these requirements.
part of Basic Compliance
Download Sample Civil Rights Compliance Policy as a Word document
ARP/CSLFRF Sample Conflicts of Interest Policy
A local government must comply with both state and federal conflict of interest laws and regulations in expending ARP/CSLFRF funds for contracts and subaward agreements. This conflict of interest template guides a local government in drafting and implementing a sufficient conflict of interest policy.
part of Basic Compliance
Download Sample Conflicts of Interest Policy as a Word document
ARP/CSLFRF Sample Records Retention Policy Addendum
part of Basic Compliance
Download Sample Records Retention Policy Addendum as a Word document
ARP/CLSFRF Sample Grant Project Ordinance
A local government must budget all funds, including grant funds, before obligating and expending them. The grant project ordinance, authorized by G.S. 159-13.2, is the best budgeting vehicle for grant funds. This sample grant project ordinance provides a template for budgeting ARP/CSLFRF funds. For more grant project ordinance examples, see this blog post.
part of Basic Compliance
Download Sample Grant Project Ordinance as a Word document
BASIC COMPLIANCE IMPLEMENTATION TOOLS | Tools we’ve created to help local governments navigate basic requirements, document compliance with eligible use and allowable cost policies for revenue replacement expenditures, and track obligations and expenditures. See this blog post for all compliance requirements for revenue replacement.
Start with the roadmap for revenue replacement!
Revenue Replacement Roadmap
Start Here For all Counties and Municipalities
part of Basic Compliance Implementation Tools
See this blog post for all compliance requirements for revenue replacement
Template | Revenue Replacement: Eligible Use and Allowable Cost Documentation Template
part of Basic Compliance Implementation Tools
Download Word Template
Template | Revenue Replacement: Tracking Obligations and Expenditures by Project Template
part of Basic Compliance Implementation Tools | This template provides a tool to track all obligations and expenditures for all projects funded using Revenue Replacement as required by the P&E report, and includes reporting periods mapped out until the final December 2026 spending deadline.
Download Excel Template
Model ARPA Internal Control Policy
part of Basic Compliance Implementation Tools
Download Word Template
ADVANCED COMPLIANCE | Additional compliance policies that counties and municipalities receiving over $10 million in ARP/CSLFRF funds may need to adopt and implement, depending on their specific expenditures.
ARP/CSLFRF Sample Subaward Policy and Risk Assessment, Subaward Agreement, and Subrecipient Monitoring Templates
part of Advanced Compliance | See this explanatory blog post for more on using ARP/CSLFRF funds to contract with other governments, nonprofits, or other private entities with subawards.
ARP/CSLFRF Premium Pay
part of Advanced Compliance
For more guidance on premium pay, see this explanatory blog post on how to use ARP-CSLFRF funds to "pay... eligible workers performing essential work during the COVID-19 public health emergency" which lasted until April 10, 2023.
ADVANCED COMPLIANCE IMPLEMENTATION TOOLS | Tools we’ve created to help local governments receiving over $10 million in ARP/CSLFRF funds to comply with applicable policies.
Sample Contract Terms Compliant with Uniform Guidance Procurement Requirements
part of Advanced Compliance Implementation Tools
Employee Personnel Activity Report Form
part of Advanced Compliance Implementation Tools
Use this form to record time spent working on grant-funded project(s)).
ARP Program Income | PowerPoint Presentation
Program Income for Water & Wastewater Projects | Because some water and wastewater projects are funded in whole or in part with ARP/CSLFRF will cause new fee for service income to be generated during the grant term, Uniform Guidance program income requirements may apply. | This presentation provides guidance on what constitutes program income, when program income applies, and how to manage, obligate, and expend it during the grant term.
ARP/CSLFRF: The Basics | PowerPoint Presentation
ARP/CSLFRF Property Management | PowerPoint Presentation
ARP/CSLFRF Davis Bacon Wages | PowerPoint Presentation
ARP/CSLFRF 2024 Deadlines | PowerPoint Presentation
Statutes
Blog Posts
American Rescue Plan Act Coronavirus State and Local Fiscal Recovery Fund: Reimbursements
As detailed in previous posts, North Carolina counties and municipalities received funding from the American Rescue Plan Act of 2021 Coronavirus State and Local Fiscal Recovery Fund (ARP/CSLFRF). This federal grant funding has afforded local governments opportunities to make transformational investm …
American Rescue Plan Act Coronavirus State and Local Fiscal Recovery Fund: Preparing for the Audit
As detailed in previous posts, all NC counties and municipalities received federal grant funding from the American Rescue Plan Act of 2021 Coronavirus State and Local Fiscal Recover Fund (ARP/CSLFRF). There are detailed expenditure guidelines, and compliance and reporting requirements for these gran …
Expending ARP/CSLFRF Funds for Local Government Employee Salary, Benefit, and Other Payroll Costs OUTSIDE of Revenue Replacement (For Local Governments with OVER $10 Million Allocation Only)
The American Rescue Plan Act of 2021 Coronavirus State and Local Fiscal Recovery Fund (ARP/CSLFRF) program provides significant funding to all North Carolina counties and municipalities. As detailed in previous posts, this federal grant program groups allowable expenditures of these funds in four ma …
American Rescue Plan Act of 2021: New (Fewer) Compliance Requirements for Revenue Replacement Expenditures
As detailed in previous posts, the American Rescue Plan Act of 2021 Coronavirus State and Local Fiscal Recovery Funds (ARP/CSLFRF) allows local governments to spend their allocations on eligible projects within four major expenditure groupings:
Using American Rescue Plan Coronavirus State and Local Fiscal Recovery Funds to Contract with Other Governments, Nonprofits, or Other Private Entities: Subawards
As detailed in previous posts, NC local governments are receiving significant funding from the federal American Rescue Plan Act Coronavirus State and Local Fiscal Recovery Funds program (ARP/CSLFRF). The availability of these funds presents many opportunities but also poses challenges for local gove …
American Rescue Plan Act of 2021: Spending Revenue Replacement Funds on Salaries and Benefits
UPDATED August 2022: On July 27, 2022, US Treasury amended its Final Rule FAQs to exempt expenditures in the Revenue Replacement category from some Uniform Guidance provisions. Those changes are reflected in the updated post below.
Design-Build Contracting in North Carolina Using Coronavirus State and Local Fiscal Recovery Funds
The U.S.
American Rescue Plan Act of 2021: Reporting “Program Income” (Including Sample Policy)
Update: We finally have sample UG policies and other implementation tools ready to share. Kara Millonzi’s blog post contains links to, and brief explanations of, the different policies and tools. We may update these policies or draft additional guidance as Treasury releases new information.
Procuring Single Audit Services under the Uniform Guidance (2 C.F.R. Part 200)
With the passage of the American Rescue Plan Act of 2021 (“ARPA”), almost all cities and counties in North Carolina received distributions of Coronavirus State and Local Fiscal Recovery Funds (“CSLFRF”) from the U.S. Department of the Treasury (“Treasury”) to assist with pandemic recovery efforts.
American Rescue Plan Act: Aid for Small Businesses and Nonprofits with ARP/CLFRF
The American Rescue Plan Act of 2021 (ARPA) is a wide-ranging law that provides federal funding in areas ranging from child care to higher education to community service to relief for shuttered venues to a restaurant revitalization fund.
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Finance in Five
ARP Basics | Comprehensive Overview Session
This video provides a comprehensive overview of the American Rescue Plan Act Coronavirus State and Local Fiscal Recovery Fund. It provides a framework for the grant program, introduces eligible expenditure categories, and details basic and more advance compliance requirements. All local governments must follow basic compliance. Local governments who received over $10 million in their own ARP/CSLFRF monies and expending funds outside the revenue replacement category and many local governments receiving grants of State ARP/CSLFRF funds must also adhere to advance compliance requirements. (Note that the run time on this video is approximately 2 hours.)