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AMERICAN RESCUE PLAN ACT (ARPA)

National emergencies and catastrophes often trigger federal relief and grant funding assistance available to state and local governments, schools and universities, public utilities, other eligible non-government organizations, and even businesses and residents impacted by the event. Every year, the federal government administers billions of dollars through federal agencies that share a responsibility in administering the programs established by Congress. COVID-19 is not different.

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    American Rescue Plan Act Overview

    The American Rescue Plan Act (ARPA) (Public Law 117-2) is the latest in a series of Coronavirus Disease 2019 (COVID-19)-related relief and economic stimulus legislation. Signed into law on March 11, 2021, the ARPA includes approximately $350 billion in direct aid to state and local governments.

    • States and The District of Columbia —— $195.3 Billion
    • Country Governments —— $65.1 Billion
    • Metropolitan Governments —— $45.6 Billion
    • Non- Entitlement Units of Local Government —— $19.6 Billion
    • Tribal Governments —— $20 Billion
    • Territory Governments —— $4.5 Billion

    State and local governments cannot use funds towards pensions or to offset revenue resulting from a tax cut enacted since March 3, 2021.

    ARPA provides an exceptional opportunity for governments and community leaders to not only recover from the impacts of COVID-19, but to provide their communities on a path for sustained growth, revitalization, and resiliency. Administering ARPA funds, however, will be a challenge even for the most sophisticated state, county, metropolitan, tribal, territorial, and non-entitlement government agencies. COVID-19 recovery success is dependent upon a strategy that instills integrity, transparency, and accountability while also meeting the expectations of the community and taxpayers, and at ISC we are well prepared to meet these needs.

    ARPA Funds can be Used in the Following Categories :

    Respond to the COVID-19 emergency and address its economic efforts, including aid to households, small businesses, nonprofits, and industries such as tourism and hospitality.

    Provide premium pay to essential employees or grants to their employers. Premium pay couldn't exceed $13 per hour or $25,000 per worker.

    Provide goverment services affected by a revenue reduction resulting from COVID-19.

    Make investment in water, sewer and broadband infrastructure.

    State & local governments could transfer funds to private nonprofit groups, public benefit corporations involved in passenger or cargo transportation, and special-purpose units of state or local government.

    ARPA Quarterly Reporting Requirements

    ARPA Full Life Cycle Grant Management for ARPA

    ISC’s 4 Phased Approach

    Phase I

    Define the needs & governance

    Phase II

    Establish the plan & controls

    Phase III

    Report & performance

    Phase IV

    Monitor, reconcile & audit

    ISC’s ARPA Approach

    ISC’s community recovery strategy has been time-tested and proven in past catastrophic disasters, terrorist attacks, epidemics, and national crises. Our experience and expertise in past national catastrophes and disasters have taught us that securing every eligible dollar of disaster assistance is very important, however, it is vital for communities to initiate COVID-19 recovery activities as expeditiously as possible and take proactive measures to manage its success. We know this at ISC because we understand that:

    • Community recovery operations are complex. They involve a multitude of stakeholders that must make informed decisions that serve in the best interest of the community and its people.
    • Community recovery does not happen overnight. Not properly managing one stage to the next will jeopardize federal relief funding, cause unnecessary delays with important community recovery projects, and create frustration and discontent with constituents.

    To accommodate communities in their ARPA activities, ISC has prepared a Four Phased Approach, as described in further detail below, to guide our clients through the ARPA process, aid in any challenges they may face, and to ensure COVID-19 recovery success. Within the Four Phased Approach, we have broken down our action items throughout the phases into 12 Essential Actions. These action items can be seen numbered (1 – 12) in each phase in the following sections.

    ISC’s Four-Phased Approach & Twelve Actions
    will ensure COVID-19 recovery success for your community!

    American Rescue Plan Act - Our Approach

    12 Essential Actions for ARPA

    Administering ARPA funds will be a challenge even for the most sophisticated state, county, metropolitan, tribal, territorial, and non-entitlement government agencies. COVID-19 recovery success is dependent upon a strategy that instills integrity, transparency, and accountability while also meeting the expectations of the community and taxpayers. Our community recovery strategy has been time-tested and proven in past catastrophic disasters, terrorist attacks, epidemics, and national crises.

    Define the needs & governance

    In Phase I, ISC assists the client in defining a strategy to address the needs of their community and an ARPA governance structure that defines the process of making informed decisions and adhering to programmatic and administrative requirements. In this phase, steps focus on connecting the client to their public and stakeholders in the community, building trust and ARPA awareness, establishing an ARPA governance structure to guide decision making, and mapping the 180+ funding ARPA programs to the needs of the client.

    At ISC we believe establishing a defined strategy that addresses the needs of the community and creating an ARPA governance structure is vital to successfully meeting the specific milestones of the ARPA and expending ARPA funding by the December 31st, 2024, ARPA deadline. We understand that with the ARPA containing more than 180+ funding programs, being able to expend ARPA funding by the deadline requires the support, understanding, and collaboration of a wide diversity of community stakeholders. The ISC team will work with the client to establish and institute a governance structure to guide decision-making and promote collaboration with community stakeholders on important ARPA matters and will provide the client with an outreach strategy to engage community stakeholders and the public on important ARPA program topics. Finally, we will help to identify local champions for the ARPA program who will help to build unity and strengthen partnerships between the client and its community.

    Establish the plan & controls

    In Phase II, ISC helps the client establish an ARPA COVID-19 Recovery Strategy and process controls. Like any other grant program, it is important to have a well-defined implementation strategy that helps guide decision-making practice and defines processes to drive compliance. By aligning ARPA funds with existing programmatic and administrative processes, communities can help to reduce unnecessary burdens of administering the ARPA program and focus on establishing process controls to ensure compliance and that program eligibility requirements are met.

    ISC will first prepare an ARPA COVID-19 Recovery Strategy that maps ARPA funding opportunities to community needs. Next, our team focuses on finding ways to make an impact in the community through ARPA funding, focusing on finding opportunities to advance equity, build prosperity, and make an impact. ISC will then assist our client in establishing guidelines to administer the ARPA funds and establish internal control measures to reduce the risk of fraud, waste, abuse of funds, and other activities that may jeopardize federal funding. Finally, the ISC team will work with the client and its partners to design and identify programs that will help stimulate community resiliency, economic growth, and sustainability.

    Reporting & performance

    In Phase III, ISC assists the client with defining a systematic process to track ARPA funds and ensure compliance, and to prepare quarterly ARPA reports. Throughout the APRA implementation process it is important for communities to be able to pivot quickly from establishing an ARPA strategy to taking action. While communities must move quickly, it is vitally important that they establish a process to continually monitor performance, adhere to Department of Treasury reporting requirements, track their ARPA performance, and make necessary adjustments to improve community ARPA outcomes.

    ISC will assist the client in defining a systematic process to track ARPA funds and ensure compliance, and the preparation of quarterly reports. Whether it’s COVID-19 relief or disaster assistance funding, ISC understands how overwhelming administrative, reporting, and compliance requirements can be for communities. For this reason, ISC has developed a web-based tool to manage data and track the comprehensive ARPA grant management process. ISC’s ARPA Grant Management Tool can be integrated into current client processes and systems to help drive workload, track performance, monitor funding queues, create reports, monitor compliance, and audit requirements. This tool provides a centralized location to collaborate on projects and automates workflow to increase efficiency. Personalized dashboards highlight pending tasks and can help gauge the overall progress of the expenditure of ARPA funds. Finally, ISC will assist the county in preparing quarterly reports for the Department of Treasury on behalf of the client. Our Team will monitor and ensure compliance with all programmatic deadlines and assist in the development of time extension requests, as necessary.

    Tier 1
    • State, U.S. territories, metropolitan cities, and counties with a population that exceeds 250,000 residents
    Tier 2
    • Metropolitan cities and counties with a population below 250,000 residents are allocated more than $10 million in SLFRF funding, and NEUs that are allocated more than $10 million in SLFRF funding.
    Tier 3
    • Tribal Governments that are allocated more than $30 million in SLFRF funding
    Tier 4
    • Tribal Governments that are allocated less than $30 million in SLFRF funding
    Tier 5
    • Metropolitan cities and counties with a population below 250,000 residents are allocated less than $10 million in SLFRF funding, and NEUs that are allocated less than $10 million in SLFRF funding.
    Tier 1 – 5

    By August 31, 2021 or 60 days after receiving funding if funding was received by October 15, with expenditures by category

     

    Note : NEUs were not required to submit on Interim Report

    Tier 1 – 3

    By August 31, 2022, and then 30 days after the end of each quarter thereafter

     

    Note : NEUs were not required to submit a Project and Expenditure Report on January 31, 2022. The first report date for NEUs will be April 30, 2022.

     

    Tier 4 – 5

    By April 30, 2022, and then manually thereafter

    Tier 1

    By August 31, 2021, or 60 days after receiving funding, and manually thereafter by July 31.

    ARPA Project & Expenditure Reporting Requirements

    Must be Submitted :

    • Quarterly for Tier 1-3
    • Annually for Tier 4-5

    Report Must Include :

    • General Project Information
      • Project Name
      • Identification Number
      • Project Expenditure Category
      • Description
      • Major Project Activities
      • Status of Completion
    • Program income
    • Adopted Budget (Tier 1 Only)
    • Civil Rights Compliance
    • Ineligible Activities
    • Project Obligations & Expenditures
      • Current Period Obligations
      • Cumulative Obligations
      • Current Period Expenditure
      • Cumulative Expenditure
    • Project Demographics Distribution
      • Only Public Health and Negative Economic Impact ECs
    • Subawards, Contracts, Grants, Loans, etc.
    • Required Programmatic Data
      • Details Information for all projects on the ARPA Expenditure Category

    ARPA Recovery Plan Reporting Requirements

    Must be Submitted :

    • Annually for Tier 1 only

    Report Must Include :

    • Executive Summary
    • Use of Funds
      • Public Health (EC 1)
      • Negative Economic Impacts (EC 2)
      • Services to Disproportionately Impacted Communities (EC 3)
      • Premium Pay (EC 4)
      • Water, Sewer, and Broadband Infrastructure (EC 5)
      • Revenue Replacements (EC 6)
    • Promoting Equitable Outcomes
      • Goals, Awareness, Access, and Distribution, Outcomes
    • Community Engagement
    • Labor Practices
    • Use of Evidence
    • Table of Expenses by Expenditure Category
    • Project Inventory
    • Performance Report
    • Required Performance Indicators & Programmatic Data
      • Household Assistance
      • Negative Economic Impacts
      • Education Assistance
      • Health Childhood Assistance
    • Ineligible Activities: Tax Offset Provision (States & Territories Only)

    Monitor, reconcile & audit

    In Phase IV, ISC will assist the client with compliance of ARPA expenditures and perform periodic audits to prevent de-obligation or return of funds and perform closeout and reconciliation of ARPA expenditures.

    ISC will work with the client to establish audit and financial controls that will reduce the burden of potential audits. Additionally, ISC will maintain file records for each project to account for all associated documentation and accounting records, ensuring costs are consistent with policies and procedures, and that all costs are necessary and reasonable. Finally, ISC’s closeout specialists will review all ARPA project and program funding, reconcile the actual costs and expenditures, and, when applicable, identify any outstanding funds that are owed to the client. In addition, ISC will work with the client to obtain documentation to support all eligible costs and approved scope of work per the ARPA grant funds.

    DISASTER GRANT MANAGEMENT TOOL

    Track, Manage, and Administer Disaster Grant Funding and Compliance

    The Odysseus™ | GMT provides users with a ready-to-use or customized disaster grant management system to allow your organization to track, administer, and report grant funding and comply to regulatory requirements.

    Recent ARPA Projects