The U.S. Department of Treasury (Treasury) recognizes that due to the receipt of a State and Local Fiscal Recovery Funds (SLFRF)/ARPA award, many recipients may expend $750,000 or more in federal awards during their fiscal year and newly be required to complete a Single Audit or a Program-Specific Audit. Section IV of the SLFRF/ARPA Compliance Supplement describes an alternative approach for SLFRF/ARPA recipients that are required to undergo an audit pursuant to 2 CFR Part 200, Subpart F solely for the expenditures of SLFRF funds directly awarded by Treasury. An SLFRF/ARPA recipient may still elect to undergo a Single Audit or a Program-Specific Audit under 2 CFR Part 200, Subpart F.
Eligibility Criteria
SLFRF/ARPA recipients that expend $750,000 or more in federal awards during the recipient’s fiscal year and that meet both criteria listed below have the option to follow the Alternative Compliance Examination Engagement (ACEE) Report:
- The recipient’s total SLFRF/ARPA award received directly from Treasury or received (through states) as a non-entitlement unit (NEU) of local government is at or below $10 million; and
- Other federal award funds the recipient expended (not including their SLFRF/ARPA award funds) are less than $750,000 during the recipient’s fiscal year.
Further details are included in:
- 21 SLFRF Compliance Supplement – Technical Update (see content beginning on page 9)
- 2022 SLFRF Compliance Supplement (see content beginning on page 10)
- 2023 SLFRF Compliance Supplement ( see content beginning on page 11)
Examination Guidance
The alternative approach to a Single Audit or Program-Specific Audit under 2 CFR Part 200, Subpart F permits eligible recipients to engage a practitioner (professional auditor) to perform a compliance examination engagement in accordance with the Government Accountability Office (GAO) Government Auditing Standards. These standards direct practitioners to conduct these engagements in accordance with the American Institute of Certified Public Accountants (AICPA) Statements on Standards for Attestation Engagements. The AICPA attestation standards are codified in the AT-C section of the AICPA’s Professional Standards and AT-C Section 315, Compliance Attestation, which is the standard to be followed.
Some Additional Details to Remember about Local SLFRF/ARPA Awards
- Notice the name of the SLFRF/ARPA funding: STATE and LOCAL Fiscal Recovery Funds. The State of Vermont received state ARPA (~$1 billion) and municipalities received local ARPA (~$200 million).
- The amount of your total local SLFRF/ARPA award is HERE.
- All recipients of local SLFRF/ARPA funds are direct recipients (not beneficiaries or subrecipients).
- All recipients of local SLFRF/ARPA funds have a grant agreement (HERE and HERE) directly with the U.S. Department of Treasury.
- If a municipality receives state SLFRF/ARPA from the State of Vermont, then the municipality is most likely considered a subrecipient of these funds. If you are unsure, look at the first section of the first page of your grant agreement. It should look like THIS.
- Expenditures of local SLFRF/ARPA funds should be included on a municipality's Schedule of Expenditures of Federal Awards (SEFA).
Other Supporting Documents
- Alternative Compliance Examination Engagement (ACEE) Report User Guide
- National League of Cities: What You Need to Know About ARPA and the Single Audit Alternative