This article provides critical information on the obligation deadline for your American Rescue Plan Act (ARPA) State and Local Fiscal Recovery Funds (SLFRF) award, along with details about reporting requirements and helpful resources.
Obligation Deadline
The obligation deadline for your entire ARPA SLFRF award is December 31, 2024. Obligations must be reported to the U.S. Treasury during your next reporting period.
Reporting Deadline
- Non-entitlement Units (NEUs): Report annually. The next reporting period ends April 30, 2025.
- All counties and large municipalities (recipients of direct allocations from the U.S. Treasury): Report quarterly. The next reporting period ends January 31, 2025.
Colorado Non Entitlement Units
Obligation Requirements
Local Governments should ensure their ARPA SLFRF funds are obligated by December 31, 2024, through contracts, subawards, interagency agreements and other transactions that require payment.
The U.S. Treasury encourages NEUs that have $10M or less in ARPA SLFRF funds to take advantage of a simplified reporting (webinar) option to categorize all funds as 6.1 Revenue Replacement. This approach satisfies the obligation requirement by ensuring that:
- Revenue loss funds are used for purchase orders, contracts, and similar transactions or eligible incurred costs requiring payment entered into by December 31, 2024.
- Personnel costs are included if positions were filled before December 31, 2024.
All obligations and related expenses should be documented in internal records and reported during your next reporting period.
Additional Resources
- Webinar recording covering the above information
- An 11 minute video: How to Obligate Revenue Replacement as demonstrated by the US Treasury.
- FAQs on Obligation: Section 17 of Treasury’s SLFRF Final Rule FAQ document.
- Treasury’s Amended Definition of Obligation Reference Guide
- SLFRF Compliance and Reporting Guidance
- Non-entitlement Units of Government Quick Reference Guide
Need Additional Assistance?
- Please email Alyssa Dinberg if you have additional questions or need 1:1 assistance.