U.S. Treasury releases additional American Rescue Plan guidance for non-entitlement municipalities

With the U.S. Treasury recently issuing additional American Rescue Plan (ARP)

Act guidance for the Coronavirus State and Local Fiscal Recovery Funds (CSLFR) program, a clearer picture exists for both "metropolitan cities" that are receiving a direct allocation from Treasury, as well as non-entitlement units of local government (NEUs), which are local governments typically serving a population under 50,000. Combined with previous guidance and the interim final rule, guidance will assist states with their distribution of funds to NEUs and give more details to all municipalities on allowed use of funds. 

In Colorado, the following municipalities are "metropolitan cities" receiving ARP funds directly from Treasury – Arvada, Aurora, Broomfield, Boulder, Centennial, Colorado Springs, Commerce City, Denver, Fort Collins, Grand Junction, Greeley, Lakewood, Longmont, Loveland, Parker, Pueblo, Thornton, and Westminster. The remaining 254 municipalities in Colorado are the only local governments classified as NEUs and will receive their funds from the state.

While those receiving direct allocations will receive the first half of their funds shortly after requesting them, the wait will be a little longer for NEUs. The guidance sets forth a process for states to verify NEUs and stepby-step guidance for Colorado to calculate and distribute the $265 million in funds for NEUs. This will be done by the Department of Local Affairs (DOLA). 

In order to receive their allocations, NEU municipalities will be required to request them from DOLA, along with required information. The League anticipates that DOLA will handle the requests and distribution, and more information will be available soon at bit.ly/34yoFmU.

CML advises members to review Treasury’s pre-submission checklist for NEU municipalities in preparation for requesting payment from DOLA. It can be found at bit.ly/3c4iL1b. Ensuring all the checklist items are completed will prevent delays in receipt of local funding allocations.

As a reminder, municipalities will receive half of their allocation this year and the second half approximately one year later. While the municipalities above that are direct recipients will have to file quarterly reports with Treasury, non-entitlement municipalities will only be required to file an annual report that will also be directly with Treasury. All funds must be encumbered by the end of 2024 and exhausted by the end of 2026.

All of the information and guidance on the CSLFR for all municipalities, including allocation information and guidance on use of funds, can be found on Treasury’s website at bit.ly/3wJDsYe. You may also contact Kevin Bommer, CML executive director, with questions at kbommer@cml.org.