American Rescue Plan December 2021 Updates: for Non-Entitlement Units (NEU)
December 14, 2021 by Justin McGraw
When will Non-Entitlement Units (NEUs) receive a second disbursement?
  • NEU’s had until October 11, 2021 to request funds from the State of Minnesota. The deadline has passed to request these funds.
  • The second disbursement, to NEU’s that requested these funds, will be available starting May 10, 2022.
What are the current reporting requirements for NEUs?
  • NEUs must submit the Project and Expenditure Report to the U.S. Treasury by April 30, 2022 (previously October 31, 2021).
  • NEUs will be asked to provide: NEU recipient number (assigned by the state), copy of the signed award terms and conditions, copy of signed assurances of compliance with Title VI, and copy of the actual budget documents validating the budget used to request funding.
How long must records be kept?
  • Financial records and supporting documents related to the award must be retained for a period of five years after all funds have been expended or returned to Treasury, whichever is later.
What are some important dates?
  • The covered period for using ARP funding begins March 3, 2021 and costs must be incurred by December 31, 2024.
    • Funds must be expended with all work performed by December 31, 2026.
  • Jurisdictions may provide premium pay retroactively, dating back to the start of the public health emergency on January 27, 2020.
What are proper uses of ARP funding?
  • Support public health expenditures
    • Fund COVID-19 mitigation efforts, medical expenses, behavioral health care and certain public health, public safety, human services, and other related staff.
  • Address the negative economic impacts caused by the public health emergency
    • Respond to economic harms to workers, families, small businesses, impacted industries, and rehiring of public sector workers.
  • Replace lost public sector revenue
    • Use funds to provide government services to the extent of the reduction in revenue experienced during the pandemic.
  • Provide premium pay for essential workers
    • Offer additional compensation, up to $13 per hour in additional wages, to those – both city employees and other workers in the community – who have faced and continue to face the greatest health risks due to their service during the COVID-19 public health emergency. NEU’s should prioritize low-income persons. Premium pay amount should not exceed $25,000 per eligible worker.
  • Invest in water, sewer, and broadband infrastructure
    • Make necessary investments to improve access to drinking water, invest in wastewater and storm water infrastructure and provide unserved or underserved locations with new or expanded broadband access.
What are restricted uses of ARP funding?
  • Pension funds (extraordinary deposits)
  • Net reduction in tax revenue
  • Funding debt services (including tax anticipation notes or issuing short-term revenue)
  • Legal settlements or judgements
  • Deposits to rainy day funds or financial reserves

 

The examples listed in this document are non-exhaustive, do not describe all terms and conditions associated with the use of ARP funding, and do not describe all the restrictions that may apply. Please see your expert CDS auditor for more information.

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