On April 1, 2022, the U.S. Treasury released an update to its Project and Expenditure Report User Guide for the American Rescue Plan Act (ARPA) and State and Local Fiscal Recovery Funds (SLFRF). This version of the guide is applicable only to the Project and Expenditure Report (P&E) due by April 30, 2022. It is anticipated that the guide will be revised again for P&Es due in July 2022.
All recipients of SLFRF are required to submit a P&E by the end of April 2022. For some recipients, this will be the second quarterly report. For others, this will be their first annual P&E.
The prior version of the guide was published prior to the release of the ARPA Final Rule. Version two of the guide primarily details the changes which were made to the P&E Reporting Portal in order to implement the Final Rule, which became effective on April 1, 2022.
The portal continues to be organized around “modules,” which are intended to be completed in sequential order. The seven modules used previously are retained, one new module has been added and one has been re-named. These modules are:
The new Introduction/Bulk Templates module includes helpful links. In addition to a link to the guide, users can download the bulk upload templates, either as a group or individually for projects, subrecipients, subawards or expenditures.
Within the Recipient Profile module, the only significant change is the addition of the SAM.gov Unique Entity Identifier number (UEI). As of April 2022, the Treasury is requiring all SLSRF recipients to have a SAM.gov registration. Once a SAM.gov registration has been established, the recipient’s UEI will be viewable on the SAM.gov website.
The Project Overview module is where most of the Portal changes occurred.
For subrecipients identified in the Subrecipients/Beneficiaries/Contractors module, use of a DUNS number is no longer permitted to identify a subrecipient entity. Instead, a SAM.gov Unique Entity Identifier (UEI) or Tax Identification Number (TIN) must be used.
Expenditure Category 6.2, Non-federal Match for Other Federal Programs has been added to categories not required in the Subawards/Direct Payments module.
Within the Expenditures module, expenditures to individuals – regardless of amount – are now reported in aggregate by project. Projects entered under expenditure categories 6.1, Provision of Government Services and 6.2, Non-federal Match for Other Federal Programs do not require entry of Subrecipient, Subaward or Expenditure (for a subaward) information for the April 2022 reporting cycle.
There were no changes to the Recipient Specific module, which continues to be applicable only to states and U.S. territories.
The Certification module adds a "Review" table which indicates whether the Project, Subaward and Expenditure modules are complete or incomplete and provides instruction on correcting errors.
Recognizing the importance of the ARPA to local governments, Baker Tilly continues to focus on helping organizations get the most out of their award, while complying with applicable regulations. Contact us today to learn how we can help you navigate the ARPA journey and the recently updated Project and Expenditure Report User Guide.
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