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About ARPA

The American Rescue Plan Act (ARPA) included $350 billion in pandemic-related aid for state and local governments. Vermont will receive more than $1.25 billion of Coronavirus State and Local Fiscal Recovery Funding from ARPA. While the legislature and the governor will determine how more than $1 billion of that funding will be spent, Congress directed nearly $200 million of that funding directly to Vermont’s cities, towns, and villages. City councils and selectboards will have discretion over how to spend their allocations. The State of Vermont will not be allowed to add any additional rules to the roughly $200 million distributed directly to municipalities.  

VLCT and its members appreciate that Vermont’s Congressional Delegation fought for this local assistance. This is the first time since the early nineteen eighties that the federal government has provided direct, unrestricted financial assistance to local units of government.

Thanks to support from the Vermont Legislature and Governor Phil Scott, VLCT established a new ARPA Coordination and Assistance Program. This page contains information about the services and tools available to help municipalities spend and track the Coronavirus Local Fiscal Recovery Funding (CLFRF). We regularly update it to help cities, towns, and villages understand how they can use the money, when to expect the money, and how to report on the money. Municipalities may submit questions about ARPA to ARPA@vlct.org.

Please note: This page is currently being revised to reflect issuance of the Final Rule on January 6, 2022.  

FAQs

Can I view all these FAQs in a single, searchable PDF?

Yes! Click on the blue words "PDF version" to the right of "About ARPA" on this page.

How much funding will my town/city/village receive?

The Vermont Agency of Administration issued an allocation table on June 8. Click here to access the allocation table. The calculation was based on population. Funding will be distributed in two (2) roughly equal tranches, as shown in the allocation table.  The first payment arrived August 2021; the second will arrive around the same time in 2022.  Most Vermont towns (except Burlington and South Burlington) are referred to as “non-entitlement units of government” (NEUs) in ARPA. The State of Vermont will receive $58,788,245 in NEU ARPA funding that it will disburse to those towns, cities and villages that certified to accept it. 

On July 30, 2021. Treasury issued updated guidance to correct the designation of Vermont's 14 counties to reflect they are not "units of general local government."  This cleared the way for the $121,202,550 in county ARPA funding to be distributed to Vermont’s towns, cities and villages, including the two metropolitan cities of Burlington and South Burlington.  VLCT worked with Vermont’s Congressional Delegation, the Governor's office and his Administration, and others to ensure this funding reaches local governments. 

Like the NEU money, the county ARPA money will be distributed in two (2) roughly equal tranches.  The first arrived  early September 2021; the second will arrive around the same time in 2022. 

 

When will my town/city/village receive the funding?

Vermont's NEUs that certified to accept their funding will receive it from the U.S. Department of the Treasury through State of Vermont. The funding will arrive in two (2) roughly equal payments ("tranches"). The first payment was made in August of 2021 and the second payment will be made about the same in 2022. Per ARPA, the State has 30 days from when they receive the funding to distribute the funding to municipalities.

The City of Burlington and the City of South Burlington were designated as "metropolitan cities" and therefore requested and received their ARPA funding directly from the Treasury.

The county ARPA funding will also arrive in two (2) roughly equal payments ("tranches"). The first payment in was in September 2021 and the second payment will arrive about the same time 2022.  It will be distributed through the State of Vermont to all NEUs that certified to accept their ARPA funds, as well as the cities of Burlington and South Burlington.  There is no additional certification process required to receive these funds.  

 

How will my town's/city's/village's money arrive?

When your town/city/village completed its Coronavirus Local Fiscal Recovery Fund Certification process through the portal, you would have selected one of the three possible options for how your town/city/village would like to receive its money:

  1. We are a vendor in the State's financial system and would like payment to be made according to our current supplier preferences.
  2. We are a vendor in the State's financial system and would like payment to be made differently.
  3. We are NOT a vendor in the State's financial system and need to set up an account.

If your town/city/village chose option 2 or 3, then you were contacted by email or phone to provide additional information.  

If your town/city/village selected option 1, then your ARPA funding will be ACH'ed into the same bank account that you receive other state revenue. 

How may my town/city/village spend the funding?

ARPA includes four broad criteria outlining eligible uses:

  • To respond to the public health emergency or its negative economic impacts, including assistance to households, small businesses, and nonprofits, or aid to impacted industries such as tourism, travel, and hospitality;

  • To respond to workers performing essential work during the COVID-19 public health emergency by providing premium pay to eligible workers;

  • For the provision of government services to the extent of the reduction in revenue due to the COVID–19 public health emergency relative to revenues collected in the most recent full fiscal year prior to the emergency; and

  • To make necessary investments in water, sewer, or broadband infrastructure.

On January 6, 2022, the U.S. Department of the Treasury issued the Final Rule that further explains eligible and ineligible uses.          

The National League of Cities has provided some additional FAQs about how the funding can be used.  Treasury has also issued easy to read and understand FAQs about the Interim Final Rule.  Treasury anticipates issuing FAQs for the Final Rule at a later date. Recipients may find helpful the Overview of the Final Rule, which provides a summary of major provision of the Final Rule for informational purposes.

What infrastructure projects may ARPA funds be used on?

General infrastructure spending is not covered as an eligible use outside of water, sewer, and broadband investments or above the amount allocated under the revenue loss provision. 

May a town/city/village transfer its ARPA funds to another entity?

The federal statute provides four (4) categories of entities to which a town/city/village may transfer funds: 

  1. A private nonprofit organization 
  2. A public benefit corporation involved in the transportation of passengers or cargo 
  3. A special-purpose unit of state or local government*
  4. A state government

* Special-purpose districts perform specific functions in the community, such as fire, water, sewer or mosquito abatement districts.

A municipality may transfer its ARPA funds to another municipality.  Section 603(c)(3) of the Social Security Act authorizes a local government to transfer funds to the same entities (other than Tribal organizations). Final Rule clarifies that the lists of transferees in sections 602(c)(3) and 603(c)(3) are not exclusive, and recipients may transfer funds to constituent units of government or private entities beyond those specified in the statute.

A municipality may transfer provided that the project is itself an eligible use of funds and that recipients can track the use of funds in line with the reporting and compliance requirements of the CSFRF/CLFRF. In general, when pooling funds for regional projects, recipients may expend funds directly on the project or transfer funds to another government that is undertaking the project on behalf of multiple recipients. To the extent recipients undertake regional projects via transfer to another government, recipients would need to comply with the rules on transfers specified in the Final Rule, "recipient may transfer funds to a government outside its boundaries (e.g., county transfers to a neighboring county), provided that the recipient can document that its jurisdiction receives a benefit proportionate to the amount contributed."

A transferee receiving a transfer from a recipient under sections 602(c)(3) and 603(c)(3) of the Social Security Act will be considered to be a "subrecipient" and will be expected to comply with all subrecipient reporting requirements (Treasury FAQ 1.8).                                

What should my town/city/village do with their signed Terms and Conditions and Assurances of Compliance with Civil Rights Requirements?

File them for now (you do not need to send them anywhere yet).  These two documents (fully completed) will be included in your town's first report to the U.S. Treasury.

 

Where can I learn more about the ARPA award reporting requirements for my town/city/village?

The U.S. Department of the Treasury issued the Compliance and Reporting Guidance document (the link for this document is in the "Resources and Information" section).  This guidance provides additional detail and clarification for each recipient’s compliance and reporting responsibilities under the CLFRF program, and should be read in concert with the Award Terms and Conditions, the authorizing statute, the Final Rule and other regulatory and statutory requirements.

You can always find all newly released information and updates to Treasury's documents on VLCT's ARPA webpage.

 

Tracking all of this will take a lot of time. May ARPA funds be used on administrative costs?

In the context of using funds for administrative purposes, Treasury's FAQ 10.2 states:

“Recipients may use funds to cover the portion of payroll and benefits of employees corresponding to time spent on administrative work necessary due to the COVID–19 public health emergency and its negative economic impacts. This includes, but is not limited to, costs related to disbursing payments of Fiscal Recovery Funds and managing new grant programs established using Fiscal Recovery Funds”.

 

More information on how to handle administrative costs is included in Treasury's Compliance and Reporting Guidance, in Section D. Uniform Administrative Requirements, item 2. a., on page 7.

 

May ARPA funds be used for stormwater projects and expenses?

Recipients may also use this funding to invest in wastewater infrastructure projects, including constructing publicly-owned treatment infrastructure, managing and treating stormwater or subsurface drainage water, facilitating water reuse, and securing publicly-owned treatment works.  

To help jurisdictions expedite their execution of these essential investments, Treasury’s Interim Final Rule aligns types of eligible projects with the wide range of projects that can be supported by the Environmental Protection Agency’s Clean Water State Revolving Fund and Drinking Water State Revolving Fund. Recipients retain substantial flexibility to identify those water and sewer infrastructure investments that are of the highest priority for their own communities. 

EPA's Drinking Water State Revolving Fund Eligibility Handbook (2017)

EPA's Overview of Clean Water State Revolving Fund Eligibilities (May 2016)

May funds be used to invest in infrastructure OTHER THAN water, sewer, and broadband projects such as roads and public facilities?

Recipients may use funds for maintenance of infrastructure or pay-go* spending for building of new infrastructure as part of the general provision of government services, to the extent of the estimated reduction in revenue due to the public health emergency. A general infrastructure project typically would not be considered a response to the public health emergency and its negative economic impacts unless the project responds to a specific pandemic-related public health need (e.g., investments in facilities for the delivery of vaccines) or a specific negative economic impact of the pandemic (e.g., affordable housing for those impacted by the pandemic).

*Pay-go infrastructure funding refers to the practice of funding capital projects with cash on hand from taxes, fees, grants, and other sources rather than borrowed sums.

 

Would investments in improving outdoor spaces (e.g. parks) be an eligible use of funds as a response to the public health emergency and/or its negative economic impacts?

There are multiple ways that investments in improving outdoor spaces could qualify as eligible uses; several are highlighted below, though there may be other ways that a specific investment in outdoor spaces would meet eligible use criteria.

First, in recognition of the disproportionate negative economic impacts on certain communities and populations, the Interim Final Rule identifies certain types of services that are eligible uses when provided in a Qualified Census Tract (QCT), to families and individuals living in QCTs, or when these services are provided by Tribal governments. Recipients may also provide these services to other populations, households, or geographic areas disproportionately impacted by the pandemic.

These programs and services include services designed to build stronger neighborhoods and communities and to address health disparities and the social determinants of health. The Interim Final Rule provides a non-exhaustive list of eligible services to respond to the needs of communities disproportionately impacted by the pandemic, and recipients may identify other uses of funds that do so, consistent with the Rule’s framework. For example, investments in parks, public plazas, and other public outdoor recreation spaces may be responsive to the needs of disproportionately impacted communities by promoting healthier living environments and outdoor recreation and socialization to mitigate the spread of COVID-19.

Second, recipients may provide assistance to small businesses in all communities. Assistance to small businesses could include support to enhance outdoor spaces for COVID-19 mitigation (e.g., restaurant patios) or to improve the built environment of the neighborhood (e.g., façade improvements).

Third, many governments saw significantly increased use of parks during the pandemic that resulted in damage or increased maintenance needs. The Interim Final Rule recognizes that “decrease[s to] a state or local government’s ability to effectively administer services” can constitute a negative economic impact of the pandemic.

What is the formula for calculating the reduction in revenue?

ARPA Revenue Loss Calculator [Link]- VLCT has produced a revenue loss calculator that uses the U.S. Department of the Treasury’s specific formula in the Interim Final Rule.  It is designed to help communities determine if they may use a portion of their ARPA funding to replace lost revenue.

Formula

A reduction in a recipient’s General Revenue equals:Max {[Base Year Revenue* (1+Growth Adjustment) (nt/12)] - Actual General Revenuet ; 0}
Where:

  • Base Year Revenue is General Revenue collected in the most recent full fiscal year prior to the COVD-19 public health emergency.
  • Growth Adjustment is equal to the greater of 4.1 percent (or 0.041) and the recipient’s average annual revenue growth over the three full fiscal years prior to the COVID-19 public health emergency.
  • "n" equals the number of months elapsed from the end of the base year to the calculation date.
  • Actual General Revenue is a recipient’s actual general revenue collected during 12-month period ending on each calculation date.
  • Subscript "t" denotes the calculation date.

May ARPA funds be used to replenish a budget stabilization fund, rainy day fund, or similar reserve account?

No. Funds made available to respond to the public health emergency and its negative economic impacts are intended to help meet pandemic response needs and provide immediate stabilization for households and businesses. Contributions to rainy day funds and similar reserves funds would not address these needs or respond to the COVID-19 public health emergency, but would rather be savings for future spending needs. Similarly, funds made available for the provision of governmental services (to the extent of reduction in revenue) are intended to support direct provision of services to citizens. Contributions to rainy day funds are not considered provision of government services, since such expenses do not directly relate to the provision of government services.

May ARPA funds be pooled for regional projects?

Yes, provided that the project is itself an eligible use of funds and that the award recipients can track the use of funds in line with the reporting and compliance requirements of the Coronavirus Local Fiscal Recovery Funds/ARPA. In general, when pooling funds for regional projects, recipients may expend funds directly on the project or transfer* funds to another government that is undertaking the project on behalf of multiple recipients. To the extent recipients undertake regional projects via transfer to another government, recipients would need to comply with the rules on transfers specified in the Interim Final Rule, Section V. A recipient may transfer funds to a government outside its boundaries (e.g., county transfers to a neighboring county), provided that the recipient can document that its jurisdiction receives a benefit proportionate to the amount contributed.

 

* See FAQ above on "May a town/city/village transfer its ARPA funds to another entity?  

For broadband investments, may recipients use funds for related programs such as cybersecurity or digital literacy training?

Yes. Recipients may use funds to provide assistance to households facing negative economic impacts due to Covid-19, including digital literacy training and other programs that promote access to the Internet. Recipients may also use funds for modernization of cybersecurity, including hardware, software, and protection of critical infrastructure, as part of provision of government services up to the amount of revenue lost due to the public health emergency.

Does ARPA money have to be kept in a separate, non-interest bearing cash account?

No, ARPA money does not need to be in a separate cash (bank) account.  Best practice is to create a separate fund in the general ledger to more easily account for and report on these funds.   

Also, any interest earned on this money may be kept by the municipality.  

May ARPA funds be used for road repairs and upgrades that occur in connection with an eligible water or sewer project?

Yes, ARPA funds may be used for road repairs and upgrades directly related to an eligible water or sewer project. For example, a recipient could use ARPA funds to repair or re-pave a road following eligible sewer repair work beneath it. However, use of ARPA funds for general infrastructure projects is subject to the limitations described in Treasury's FAQ 4.2. Water and sewer infrastructure projects are often a single component of a broader transportation infrastructure project, for example, the implementation of stormwater infrastructure to meet Clean Water Act established water quality standards. In this example, the components of the infrastructure project that interact directly with the stormwater infrastructure project may be funded by ARPA funds.  

Recipients may use funds up to the amount of revenue loss for government services, which road repairs and maintenance would be.  

How should I assess whether a stormwater management project, such as a culvert replacement, is an eligible use of ARPA funds?

Treasury's FAQ 6.7 describes the overall approach that recipients may take to evaluate the eligibility of water or sewer projects. For stormwater management projects specifically, as noted in the EPA’s Overview of Clean Water State Revolving Fund Eligibilities, “Stormwater projects must have a water quality benefit.” Thus, to be eligible under CSFRF/CLFRF, stormwater management projects should be designed to incorporate water quality benefits consistent with the goals of the Clean Water Act. 

Summary of Clean Water Act

May ARPA funds be used to make loans or other extensions of credit, including loans to small businesses and loans necessary to finance necessary investments in water, sewer and broadband infrastructure?

Yes, provided that the loan is an eligible use and the cost of the loan is tracked and reported in accordance with the points that follow. See 31 CFR 35.6. For example, a recipient may use ARPA funds to make loans to small businesses. See 31 CFR 35.6(b)(6). In addition, a recipient may use ARPA funds to finance a necessary investment in water, sewer or broadband, as described in the Interim Final Rule. See 31 CFR 35.6(e). Funds must be used to cover “costs incurred” by the recipient between March 3, 2021, and December 31, 2024, and Funds must be expended by December 31, 2026. See Section III.D of the Interim Final Rule; 31 CFR 35.5. Accordingly, recipients must be able to determine the amount of Funds used to make a loan.(See Treasury's FAQ for more details relative to length of loans.)

What are considered eligible ARPA expenditures in regard to containing/mitigating the spread of COVID-19?

Services and programs to contain and mitigate the spread of COVID-19 include: vaccination program, medical expenses, testing, contact tracing, isolation for quarantine, PPE purchases, support for vulnerable populations to access medical or public health services, public health surveillence (ex. monitoring for variants), enforcement of public health orders, public communications efforts, enhancement of healthcare capacity inlcuding alternative care facilities, support for prevention, mitigaiton, or other service in congregate living facilities and schools, enhancement of public health data systems, capital investments in public facilities to meet pandemic operational needs, ventialtion improvements in key settings like healthcare facilities.

May ARPA funds be used for mental health services?

Yes. Services to address behavioral healthcare needs exacerbated by the pandemic include: mental health treatment, substance misuse treatment, other behavioral services, hotlines or warmlines, crisis intervention, services or outreach to promoe access to health and social services.

For what community programs may ARPA funds be used?

Assistance to households or populations facing negative economic impacts due to COVID-19 is also an eligible use. This includes: food assistance; rent, mortgage, or utility assistance; counseling and legal aid to prevent eviction or homelessness; cash assistance; emergency assistance for burials, home repairs, weatherization, or other needs; internet access or digital literacy assistance; or job training to address negative economic or public health impacts experienced due to a worker’s occupation or level of training.

May ARPA funds be used to deposit into a housing fund?

Investing in Housing and Neighborhoods to build stronger communities as an eligible use of the funds under Section. A. This is in the context of addressing those disproportionately impacted by the pandemic. It is not clear if storing funds in a housing fund is eligible, however, funds may be used on services to address homelessness, affordable housing development, housing vouchers, residential counseling, or housing navigation assistance. (Interim Final Rule, p. 10-11)

May ARPA funds be used for ventilation for a public building?

Ventilation improvements in congregate settings is an eligible use under Section A.  (Treasury FAQ, 2.1)

Under mitigating COVID-19, would building an EOC or updating tech in an existing EOC be eligible?

 In the context of responding to the public health emergency, an emergency operations center would be an eligible use under Section A.

 

Is the $25,000 cap on Premium Pay under Section B on a yearly basis or for the entire time of 3/3/21 to 12/31/24?

The cap is for the whole covered period. 

 

Is $13/hr the cap for premium pay? We were thinking of paying a lower amount.

 Premium pay is stated to mean “an amount of up to $13 per hour that is paid to an eligible worker.”  Therefore, $13 would be the cap.

Could premium pay be given as a bonus to public safety/public health employees versus an increase in the hourly wage?

  The bill text states Premium Pay would be "in addition to wages or remuneration the eligible worker otherwise receives, for all work performed by the eligible worker during the COVID–19 public health emergency," (American Rescue Plan, Subtitle M, Section 602 and 603).

May ARPA funding be used for software that reduces forms and documentation that are in paper form?

Modernization of cybersecurity, including hardware, software, and protection of critical infrastructure, is listed as an eligible use of funds for government services.

May ARPA funds be used to digitize land records?

Yes.

Where can I learn more about Uniform Guidance (2 CFR Part 200)?

Visit the Code of Federal Regulations website here: https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200

What is the timeline for obligating and expending my ARPA funds?

ARPA funds must be obligated by December 31, 2024.  Any funds not obligated by this date must be returned to Treasury.

ARPA funds must be expended by December 31, 2026.  Any funds not expended by this date must be returned to Treasury.

What is the definition of "obligate"?

Obligation means an order placed for property and services and entering into contracts, subawards, and similar transactions that require payment.

Once my town/city/village has identified a reduction in revenue, are there any restrictions on how we may use funds up to the amount of the reduction?

The Final Rule gives recipients broad latitude to use funds for the provision of government services to the extent of reduction in revenue. Government services can include, but are not limited to, maintenance of infrastructure or pay-go spending for building new infrastructure, including roads; modernization of cybersecurity, including hardware, software, and protection of critical infrastructure; health services; environmental remediation; school or educational services; and the provision of police, fire, and other public safety services.

However, paying interest or principal on outstanding debt, replenishing rainy day or other reserve funds, or paying settlements or judgments would not be considered provision of a government service, since these uses of funds do not entail direct provision of services to citizens. This restriction on paying interest or principal on any outstanding debt instrument, includes, for example, short-term revenue or tax anticipation notes, or paying fees or issuance costs associated with the issuance of new debt. In addition, the overarching restrictions on all program funds (e.g., restriction on pension deposits, restriction on using funds for non-federal match where barred by regulation or statute) would apply.

Treasury FAQ 3.8

Must my town/city/village demonstrate that reduction in revenue is due to the COVID-19 public health emergency?

In the Final Rule, any diminution in actual revenue calculated using the formula above would be presumed to have been “due to” the COVID-19 public health emergency. This presumption is made for administrative ease and in recognition of the broad-based economic damage that the pandemic has wrought. 

Treasury FAQ 3.6

What does "pay-go" infrastructure funding mean?

Pay-go infrastructure funding refers to the practice of funding capital projects with cash-onhand from taxes, fees, grants, and other sources, rather than with borrowed sums.

What provisions of the Uniform Guidance for grants apply to these funds? Will the Single Audit requirements apply?

Most of the provisions of the Uniform Guidance (2 CFR Part 200) apply to this program, including the Cost Principles and Single Audit Act requirements. Recipients should refer to the Assistance Listing for detail on the specific provisions of the Uniform Guidance that do not apply to this program. The Assistance Listing will be available on beta.SAM.gov.

Treasury FAQ 9.3

For broadband investments, may my town/city/village use funds for related programs such as cybersecurity or digital literacy training?

Yes. Cities may use funds to provide assistance to households facing negative economic impacts due to COVID-19, including digital literacy training and other programs that promote access to the internet. Cities may also use funds for modernization of cybersecurity, including hardware, software, and protection of critical infrastructure, as part of provision of government services up to the amount of revenue lost due to the public health emergency.

Treasury FAQ 6.6

What is the definition of "Authorized Representative"?

An Authorized Representative is an individual with legal authority to bind the government entity (e.g., the Chief Executive Officer of the government entity). An Authorized Representative must sign the Acceptance of Award terms for it to be valid.

Treasury FAQ 11.7

When you completed your certification to receive ARPA funds through the State of Vermont's online certification portal, you would have entered the name and contact information for your Authorized Representative as a required field.  

Who has oversight of the NEUs, the State/U.S. Territory or Treasury?

NEUs are considered prime recipients of Treasury and States are not responsible for monitoring NEUs for compliance with use of funds.

My town/city/village would like to help local businesses with our ARPA funds. Do we need to document their need for aid?

Yes. Towns/cities/villages should maintain records to support their assessment of how businesses or business districts receiving assistance were affected by the negative economic impacts of the pandemic and how the aid provided responds to these impacts. (Refer to Treasury's Compliance and Reporting Guidance)

Is public/community engagement a requirement of my ARPA award?

No, however public engagement is implicit throughout the language in the Interim Final Rule (IFR):

"Implementation of the Fiscal Recovery Funds also reflects the importance of public input, transparency and accountability."  In addtion, the IFR establishes certain regular reporting requirements, including requiring local governments to publish information regarding uses of Fiscal Recovery Funds (ARPA) payments in their local jurisdiciton.  This means your reporting  on use of funds will be open for public viewing, perhaps posted on Treasury's website and others, easily found through search engines.  "These reporting requirements reflect the need for transparency and accountability."  Treasury urges State and local governments "to engage their constituents and communities in developing plans to use these payments, given the scale of funding and potential to catalyze broader economic recovery and rebuilding."

What is the "period of performance" for my ARPA award?

From the award Terms and Conditions, item 2. "The period of performance for this award begins on the date hereof and ends on December 31, 2026."  The "date hereof" is the date your Authorized Representative signed the cover page of the Terms and Conditions document.  

For my town/village/city to use our local ARPA funds for water/wastewater, does our project have to be included on the State of Vermont's Intended Use Plan?

No.  The only requirement on local ARPA funds for a water/wastewater project is that the project must follow EPA's DWSRF Eligibility Handbook (2017) or EPA's Overview of CWSRF Eligibilities (2016), depending upon the type of project.  If a town uses its local ARPA funds alongside the State's/ANR's ARPA funds or other state or federal program funds in a project, then the rules of the other funds will prevail.  

My town/city/village is under a consent decree for Clean Water Act violations. Can we use these funds toward activities under our consent decree? 

Yes. If you’re using your local ARPA funds pursuant to the “infrastructure provision” to meet requirements of a Clean Water Act consent decree, that is an eligible use as long as the project aligns with one or more of the Clean Water SRF categories.  

If you’re using your local APRA funds pursuant to the “Responding to COVID-19/Responding to Negative Economic Impacts” provision to meet requirements of a Clean Water Act consent decree, that is an eligible use as long as the project required by the consent decree responds to the public health or negative economic impacts of COVID 19 and is a “pay-go” project.  

If you’re using your local ARPA funds pursuant to the “Revenue Loss” provision to meet requirements of a Clean Water Act consent decree, that is an eligible use as long as the project required by the consent decree provides a government service and is a “pay-go” project.  

Pay-go infrastructure funding refers to the practice of funding capital projects with cash-on-hand from taxes, fees, grants, and other sources, rather than with borrowed sums. 

Local ARPA funds cannot be used to pay off fines or any other settlement costs, including those associated with a consent decree. (source:  NLC)

Does the National Environmental Policy Act (NEPA) apply to infrastructure projects?  

NEPA does not apply to Treasury’s administration of ARPA funds. Projects supported with payments from ARPA funds may still be subject to NEPA review if they are also funded by other federal financial assistance programs.

What is considered Personal Protective Equipment (PPE) in the context of COVID-19?

Surgical masks, non-surgical masks, gloves, goggles, face shields, gowns and N95 masks

Can ARPA funds be used to pay for the extra costs of a Single Audit, if one is needed?

Certain federal regulations are applicable to your ARPA award, such as Uniform Guidance (2 CFR Part 200).  Section 200.425 discusses audit services and states: “A reasonably proportionate share of the costs of audits required by, and performed in accordance with, the Single Audit Act Amendments of 1996 (31 U.S.C. 7501-7507), as implemented by requirements of this part, are allowable.”  If you expended funds from multiple federal grant programs in a fiscal year, each program would pay a proportionate share of the cost of the Single Audit. 

Are payments to individuals for Premium Pay considered wages?

Yes.  Premium pay amounts paid to employees are considered wages. Employers generally must withhold federal income tax as well as social security tax and Medicare tax from employees' wages. (Employers also may have to pay federal unemployment tax on the wages.) Any payment from SLFRF/ARPA that is in the nature of compensation for services, even a one-time payment (such as a hiring "bonus"), is considered wages. More information can be found on the IRS CSLFRF (ARPA) FAQ.

Are payments to individuals for utilities (or arrearages of utilities) using ARPA funds considered income?

No, these payments are not considered income and therefore a Form 1099-MISC is not required.

Are other cash transfers to individuals using ARPA funds considered income?

No, cash transfers are not considered income and therefore no Form 1099-MISC or other information return is required to be filed with the IRS or furnished to the town/city/village (Recipient).

RESOURCES AND INFORMATION

 

   U.S. Department of the Treasury   

Grant/Award "Agreement" Documents:

Compliance and Reporting Documents & User Guides:

 

   State of Vermont   

 

   National League of Cities   

  • Local Fiscal Recovery Funds Playbook  This guide centralizes all the information and recommendations NLC has released on SLFRF grants over the last several months and organizes them by the program's eligible expenditure categories. It also organizes the Treasury's key guidance resources by format. It's a user-friendly, curated guide that includes hyperlinks to all the resources.

 

   Other FAQs   

 

 

   Other ARPA Resources   

 

   Other Funding Sources   

  • Agency of Commerce and Community Development -  ACCD Grant Opportunities Inventory Dec 2021 - Grant opportunities for businesses, and municipalities, both COVID specific as well as existing programs.  
  • Agency of Natural Resources (ANR) ARPA Funding Opportunities:
    • Combined Sewer Overflow (CSO) Elimination and Abatement The Vermont Department of Environmental Conservation will issue grants to municipalities to accelerate CSO elimination projects, allowing these projects to progress on a faster schedule and with more affordability to the ratepayers.
    • Mobile Home Park Solutions - Many manufactured housing communities (also known as mobile home parks) in Vermont struggle to provide clean and adequate drinking water, wastewater, stormwater and drainage systems. This funding will provide grants to improve living conditions for people in manufactured housing communities and help residents follow Vermont’s environmental regulations.  Grants can be used to complete a needs assessment, receive technical assistance, and cover construction costs necessary to implement water infrastructure solutions. 
    • Individual Drinking Water and Wastewater Systems - This program will provide financial assistance to residential property owners, including owner-occupied multi-family properties with up to four units, to install or repairs systems. The Agency of Natural Resources will provide ARPA funding to owner/applicant-occupied single and multi-unit residential properties that have failing or inadequate on-site water and/or wastewater systems. 
    • 3-Acre Stormwater  - This program will help Vermont citizens and businesses follow new rules for properties with three or more acres of impervious surfaces (e.g. rooftops, paved or gravel areas) that require pollution-reducing stormwater treatment. 
    • Pretreatment Capacity - Funding will be available to invest in wastewater pretreatment systems that reduce high strength or incompatible waste at municipal wastewater treatment facilities.
    • Village Drinking and Wastewater Initiative - This funding is now available to help municipalities develop or expand public drinking water systems and community wastewater disposal systems where this critical infrastructure is lacking. This grant funding will bridge the affordability gap, protect public health, increase affordable housing, support economic development and incentivize compact growth in Vermont’s designated villages and neighborhoods.  These ARPA funds will be used in a “co-funding” model with the State Revolving Loan Funds, USDA -Rural Development support, or locally available funding. Co-funding means that ARPA funding will be used to complement other funding sources to achieve affordability. The assistance will be primarily in the form of grants, but pending eligibility determination, may include refinancing for planning, design, land purchase, or construction of active as-of-yet completed projects.
       

 

   ARPA Across the Country   

  • ICMA ARPA Local Fiscal Recovery Fund Spending Priorities Survey ICMA surveyed local government chief administrative officers (CAOs) in September 2021 about their priorities for utilizing the American Rescue Plan Act (ARPA)’s Local Fiscal Recovery Funds (FRF). Nearly 600 town, city, and county managers responded. Responses include local governments with populations ranging from less than 2,500 to over one million; two thirds came from communities of 25,000 or fewer residents, which fall under the U.S. Treasury definition of “Non-entitlement Units” (NEUs, i.e., local governments typically serving a population of under 50,000). Direct FRF recipients include counties and metropolitan citie
  • U.S. Department of the Treasury - Early Reporting Highlights – Coronavirus State and Local Fiscal Recovery Funds (October 14, 2021) - Treasury started disbursing State and Local Fiscal Recovery Funds to state, local, territorial, and Tribal government recipients on May 10, 2021. A subset of these recipients were required to submit initial reports on August 31, 2021 ("Interim Reports"). Treasury is processing these reports and will make them publicly available soon. In the meantime, this document includes some highlights from the Recovery Plan Performance Reports submitted by recipients, which include both immediate and long-term plans across eligible use categories.

 

   Community Engagement Resources   

 

   Sources of Data  

Vermont Agency of Education, Annual Statistical Report, Percent of Students Approved for Free and Reduced-Price School Meals, School Year 2020 - 2021 (published September 22, 2021)

 

   Resources for Your Residents