2024-2026: ARPA compliance activities
Some activities need attention throughout the entire funding process. Following are details on Treasury reporting, program closeout, and program assessment.
Treasury reporting
State and local governments are required to report to Treasury on their ARPA SLFRF spending. The reporting frequency depends on the government’s size. For example, states provide a highly detailed financial and programmatic data report quarterly and a higher level report for non-entitlement units annually.
Reporting can be tedious, complex, and require significant employee time if the right practices and technology are not in place – especially if an organization is required to report every quarter.
Program closeout
SLFRF-funded projects must be formally closed at the conclusion of the project life cycle. Program closeout includes:
- Expenditure of all SLFRF funds for agency projects
- Completion of financial and programmatic reporting for all projects
- Collection of all project documentation and data for retention
Generally, closeout procedures allow agencies and compliance review teams to:
- Complete final financial and programmatic data reviews
- Reconcile the Treasury submission portal with known information
- Gather and maintain supporting documentation
- Review 2 CRF 200 for compliance and establish continuing compliance procedures
Treasury likely will issue closeout guidance toward the end of the SLFRF spending window. However, as some subrecipients will wrap up their spending before Dec. 31, 2026, governments need to establish closeout processes and procedures in advance.
Program assessment
As ARPA SLFRF spending winds down in 2026, governments need to review which programs (if any) should stay and identify how they are going to fund these programs moving forward. Program assessments can help leaders understand which programs are working based on performance against recognized standards and best practices, benchmarks from comparable organizations, and an evaluation of outcomes against goals and objectives.