American Rescue Plan


The US Treasury just released further guidance on the American Rescue Plan (ARP) as it relates to the Coronavirus State and Local Fiscal Recovery Funds.

Today they adopted the Interim Final Rule which specifies the requirements for Coronavirus State and Local Fiscal Recovery Fund expenditures. The Treasury has submitted this document to the Office of the Federal Register (OFR) for publication and is currently pending placement on public display at the OFR and publication in the Federal Register, at which point it will become the official document.

Treasury has also published detailed allocation information for the Coronavirus State and Local Fiscal Recovery Funds.  For municipalities considered “Metropolitan Cities” of which Maryland has nine, the allocations are listed by state in this Treasury document.  For municipalities considered “Non-Entitlement Units,” which includes the other 148 municipalities in Maryland, the Treasury presently only has aggregate numbers at the state level.  However, the state aggregate for Maryland for non-entitlement units went from a first draft of $448 Million to $528 Million. Treasury expects to provide further guidance on distributions to non-entitlement units in the coming days.


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.

IMPORTANT UPDATE - April 16, 2021:

DUNS Number - In order to receive ARP Funds, all municipalities must ensure they have a valid DUNS number. 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. A DUNS number is required prior to registering with the SAM database, which is outlined below. Registering for a DUNS number is free of charge.
If an entity does not have a valid DUNS number, please visit or call 1-866-705-5711 to begin the registration process.

Please see our US Treasury Guidance page for more details.

Informational Webinar Series

MML is hosting a three-part webinar series to help Maryland's municipalities through the ARP implementation. 

Part One - April 28, 2021

Mike Wallace, NLC's Legislative Director for Housing, Community and Economic Development pays a special visit to the Maryland Municipal League to discuss the latest on U.S. Treasury Department guidance as well as best practices for using ARP funds. ARP Funding Info Session - Part 1 Recording

Part Two - Week of May 24th

Will discuss implementation and clarifying how funding can and can't be spent, based on the newly released Interim Final Rule.

Part Three - Date TBD

Will discuss the reporting process

NLC Opens in new windowNLC has identified municipal officials frequently asked questions about Coronavirus Local Fiscal Recovery Fund grants, and have provided answers based on available information to help you prepare while we all wait for official guidance. These answers will be updated when additional information becomes available.  ARP Local Relief Frequently Asked Questions

Guiding Research

American Rescue Plan Spending: Recommended Guiding Principles

For many jurisdictions, the funding provided under ARPA is substantial and could be transformational for states and local governments in their pandemic rescue and recovery efforts. Elected leaders will need to decide how to best use the additional funding consistent with the ARPA requirements, which are very broad.
Resource Guide from the Government Finance Officers Association (GFOA)

What Every Local and Tribal Government Needs to Know About the Federal Stimulus

The role local and tribal governments play in supporting their communities has been newly acknowledged with another tranche of COVID-19 relief funding and additional emergency responsibilities to match. Employees might be rehired, deferred maintenance projects may resume, services previously cut could return.
Resource Guide from eCivis &