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 of 2021 (ARP): State Law Authority To Expend ARP Funds
Update: On January 6, 2022, the U.S. Department of the Treasury issued the Final Rule, which governs the eligible uses of Coronavirus State and Local Fiscal Recovery Funds (“SLFRF”) under the American Rescue Plan Act (“ARPA”). The Final Rule makes several key changes to the Interim Final Rule, inclu …
Budgeting for American Rescue Plan Act Funds
As detailed here and here, the federal American Rescue Plan Act (ARP) provides si
Raising the Federal Micro-Purchase Threshold: Self-Certification for Units of Local Government in North Carolina
On August 13, 2020, the Office of Management and Budget (“OMB”) published revisions to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 C.F.R.
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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.)