The American Rescue Plan Act (ARPA) local relief funds that will go to cities should be released no later than May 10, 2021, creating a short amount of time for smaller cities to get ready to receive the funds.
Cities, towns and villages with fewer than 50,000 residents, referred to in the law as nonentitlement units of local government, will receive their money as a pass through from the state. States will receive their money no later than May 10, and then states have 30 days to pass the money through cities, towns and villages with fewer than 50,000 residents. The law contains strong language that should prevent states from withholding funds to cities, towns and villages with less than 50,000 residents.
Municipalities with fewer than 50,000 residents will need to obtain a DUNS number to meet the reporting requirements of the law. A DUNS number is a unique nine-character number used to identify an organization and is issued by Dun & Bradstreet. The federal government uses the DUNS number to track how federal money is allocated. Registering for a DUNS number is free of charge. If an entity does not have a valid DUNS number, please visit https://fedgov.dnb.com/webform/ or call 1-866-705-5711 to begin the registration process.
It is also advised that municipalities with fewer than 50,000 residents gather their financial information to share with the state to ensure a timely transfer of funds. This would include:
- Entity Identification Number (EIN), name, and contact information
- Name and title of an authorized representative of the entity
- Financial institution information (e.g., routing and account number, financial institution name and contact information)
For additional information on DUNS, visit NLC’s ARPA Local Relief Frequently Asked Questions.
The Single Audit Act
The Single Audit Act requires that all non-federal entities that expend more than $750,000 in federal awards in a year are required to obtain an audit in accordance with the Single Audit Act Amendments of 1996, the U.S. Government’s Office of Management and Budget’s Circular A-133, the U.S. Government’s Office of Management and Budget’s Circular Compliance Supplement and Government Auditing Standards. A single audit is intended to provide a cost-effective audit for non-federal entities, so one audit would be conducted in lieu of multiple audits of individual programs.
NLC suggests that municipalities begin budgeting to hire an auditing firm for a single audit if they believe they will expend more than $750,000 in federal awards in a year.
At this moment, it is unclear whether the funds from the American Rescue Plan Act can be used to pay auditors. In a call with Treasury and White House officials, NLC pushed hard for this to be an allowable use of funds under the American Rescue Plan Act.