Internal ARPA Handbook - Lewis County FINAL
Lewis County, WA
Internal ARPA Projects Handbook
American Rescue Plan Act (ARPA) State and Local Fiscal
Recovery Funds (SLFRF)
Version 1.0
Submitted by:
BerryDunn
2211 Congress Street
Portland, ME 04102-1955
207.541.2200
Bill Brown, Principal
BBrown@berrydunn.com
Steven Whitney, Senior Project Manager
swhitney@berrydunn.com
Submitted On:
November 2, 2022
Internal ARPA Projects Handbook i
Table of Contents
1.0 Purpose ............................................................................................................................... 1
2.0 ARPA Overview ................................................................................................................... 2
3.0 Roles and Responsibilities ................................................................................................... 3
3.1 Auditor’s Office: Financial Services ................................................................................... 3
3.2 Budget Department........................................................................................................... 3
3.3 Departments of the County ............................................................................................... 3
4.0 Uniform Administrative Requirements .................................................................................. 5
4.1 Allowable Activities (A) ..................................................................................................... 6
4.2 Allowable Costs/Cost Principles (B) .................................................................................. 6
4.3 Cash Management (C) ..................................................................................................... 7
4.4 Eligibility (E) ...................................................................................................................... 7
4.5 Equipment and Real Property Management (F) ................................................................ 7
4.6 Matching, Level of Effort, Earmarking (G) ......................................................................... 8
4.7 Period of Performance (H) ................................................................................................ 8
4.8 Procurement, Suspension, and Debarment (I) .................................................................. 9
4.8.1 Procurement............................................................................................................... 9
4.8.2 Suspension and Debarment ....................................................................................... 9
4.9 Program Income (J) .........................................................................................................10
4.10 Reporting (L) ..................................................................................................................11
4.10.1 Types of Required Reports ......................................................................................11
4.10.2 Submission of Required Reporting ..........................................................................12
4.11 Subrecipient Monitoring (M) ...........................................................................................12
4.11.1 Risk Assessment .....................................................................................................12
4.11.2 Monitoring ...............................................................................................................13
4.12 Special Tests and Provisions (N) ...................................................................................14
5.0 Other Grant Requirements ..................................................................................................15
Internal ARPA Projects Handbook ii
5.1 Maintenance of Records ..................................................................................................15
5.2 Single Audit .....................................................................................................................16
5.3 Lobbying ..........................................................................................................................16
6.0 Closeout Phase ...................................................................................................................17
Internal ARPA Projects Handbook 1
1.0 Purpose
The Coronavirus State and Local Fiscal Recovery Funds (SLFRF) program—a part of the
American Rescue Plan Act (ARPA)—delivered $350 billion to state, local, and Tribal
governments across Lewis County (the County) to support its response to and recovery from
the COVID-19 public health emergency.
The County received approximately $15.7 million in two tranches of funding in 2021 and 2022 to
support its response to and recovery from the COVID-19 public health emergency.
The County is considered a Prime Recipient of SLFRF funding. As a department of the
County receiving this funding, you will be required to follow the guidelines of a Prime Recipient.
As a County, numerous compliance and reporting requirements need to be adhered to in order
to successfully administer this program.
This handbook provides an orientation on recipients’ compliance responsibilities and the U.S.
Department of the Treasury’s (U.S. Treasury’s) expectations and recommended best practices,
where appropriate, under the SLFRF program. The U.S. Treasury developed several guiding
principles:
• Recipients and subrecipients are the first line of defense and are responsible for
working to ensure SLFRF is not used for ineligible purposes, and there is no fraud,
waste, or abuse associated with the SLFRF award.
• Many SLFRF-funded projects respond to the COVID-19 public health emergency
and meet urgent community needs. Swift and effective implementation is vital, and
recipients must balance facilitating simple and rapid program access widely across
the community and maintaining a robust documentation and compliance regime.
• The U.S. Treasury encourages recipients to use SLFRF-funded projects to advance
shared interests and promote equitable delivery of government benefits and
opportunities to underserved communities.
• Transparency and public accountability for SLFRF and use of such funds are critical
to upholding program integrity and trust in all levels of government.
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2.0 ARPA Overview
Congratulations on receiving a portion of the County’s ARPA allocation under the SLFRF
program. This program helps ensure governments have the resources needed to conduct the
following:
• Fight the pandemic and support families and businesses struggling with COVID-19-
related public health and economic impacts
• Maintain vital public services even amid declines in revenues
• Build a strong, resilient, and equitable recovery by making investments that support
long-term growth and opportunity
The U.S. Treasury released the Final Rule for the program, which took effect on April 1, 2022.
We encourage you to visit the U.S. Treasury’s website for SLFRF, which can be found at the
URL below to learn more about this funding.
https://home.treasury.gov/policy-issues/coronavirus/assistance-for-state-local-and-tribal-
governments/state-and-local-fiscal-recovery-funds.
Additionally, the U.S. Treasury periodically updates its Frequently Asked Questions (FAQs).
Please monitor and read these FAQs at the below URL.
https://home.treasury.gov/system/files/136/SLFRF-Final-Rule-FAQ.pdf
Figure 1 below illustrates the four key aspects to the life cycle for SLFRF and all other federal
grants.
Figure 1: SLFRF Grant Life Cycle
Planning and Pre-Award
•Conduct
planning and
development
•Conduct
accounting
activities and
review
applications
•Identify risks
•Identify
projects
Award
•Subrecipient
agreements
•Review for
suspension
and
debarment
•Risk
assessment
•Obligate
funds
•Develop time
frames
Manage
•Subrecipient
monitoring
•Drawdown
funds
•Reporting
•Prepare for
Uniform
Guidance
Audits
•Provide
oversight
Closeout
•Final
drawdowns
•Final reports
•Return
unused funds
•Retain
records
•Final
closeout
procedures
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3.0 Roles and Responsibilities
3.1 Auditor’s Office: Financial Services
The Auditor’s Office will be responsible for coordinating and overseeing the following:
• Accounts Payable
• Payroll expenditures
• Managing the General Ledger
• Monitoring
• Procurement review and compliance
• Providing guidance on how best to comply with the Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 Code of
Federal Regulations (CFR) Part 200 (the Uniform Guidance)
3.2 Budget Department
The Budget Department will be responsible for coordinating and overseeing the departments as
it relates to the following:
• Reporting
• Reviewing Request for Proposals (RFPs), bids, and contracts related to SLFRF
• Reviewing and approving project eligibility
• Other administrative services, as needed
3.3 Departments of the County
Departments under the SLFRF program are considered Prime Recipients of SLFRF financial
assistance. Departments’ compliance responsibilities will generally be subject to the
requirements of the Uniform Guidance, and will include:
• Administering projects
• Adhering to the Uniform Guidance
• Developing and maintaining sound internal controls related to financial reporting and
compliance
• Confirming and documenting verification of Unique Entity Identifier (UEI) for any
contractor/vendor via the System for Award Management (SAM) website,
http://www.SAM.gov
• Submitting vendor/contractor suspension and debarment certification to the Auditor’s
Office
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• Timely submission of Project Budget sheet
• Timely submission of monthly reimbursement requests (if applicable)
• Timely submission of all required grant reporting and reconciliation to the Auditor’s Office
• Adhering to data requests, reviews, and audits; working to ensure proper records
management of all records related to these funds in accordance with grant requirements
(e.g., emails, eligibility documents)
• Adhering to all requirements in the Grant Agreements and Grant Terms and Conditions
• Complying with SLFRF statute, SLFRF Award Terms and Conditions, the U.S.
Treasury’s interim final rule and final rule, applicable federal statutes, regulations, and
reporting requirements
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4.0 Uniform Administrative Requirements
The SLFRF are federal funds received through the U.S. Treasury’s Assistance Listing
Number (ALN) 21.027 Coronavirus SLFRF. Federal funds are subject to the requirements
identified under the Uniform Guidance. The summaries below are only general summaries, and
all departments are advised to carefully review the Uniform Guidance requirements and any
additional regulatory and statutory requirements applicable to the program.
Figure 2: Uniform Guidance – Matrix of Compliance Requirements
Uniform Guidance
Matrix of Compliance Requirments
Allowable Activities
(A)Allowable Costs/Cost Principles
(B)
Cash Management
(C)
Eligibility
(E)
Equipment and Real Property Management
(F)
Matching, Level of Effort, Earmarking
(G)Period of Performance
(H)
Procurement, Suspension & Debarment
(I)
Program
Income
(J)
Reporting
(L)
Subrecipient Monitoring
(M)
Special Tests
and Provisions
(N)
Internal ARPA Projects Handbook 6
4.1 Allowable Activities (A)
Under the Final Rule issued by the U.S. Treasury on January 6, 2021, recipients may use the
federal awards to do the following:
• Support public health expenditures by funding COVID-19 mitigation efforts, medical
expenses, behavioral healthcare, and certain public health and safety staff
• Address negative economic impacts caused by the public health emergency, including
economic harms to workers, households, small businesses, impacted nonprofits, and the
public sector
• Provide premium pay for essential workers, offering additional support to those who
have borne and will bear the greatest health risks because of their service in critical
infrastructure sectors
• Invest in water, sewer, and broadband infrastructure, making necessary investments to
improve access to clean drinking water, support vital wastewater and stormwater
infrastructure, and expand access to broadband internet
The Final Rule also states the following activities are specifically not permitted:
• A recipient may not use funds for deposits into any pension fund
• A recipient may not use funds to contribute to rainy day funds, financial reserves, or
similar funds
• A recipient may not use funds to either directly or indirectly offset a reduction in the net
tax revenue of the entity resulting from a coverage change during the covered period
Increased federal funding has escalated the risk of entities “double dipping” (i.e., using federal
funds for the same expense twice). The County and its departments should have policies and
procedures in place to avoid any “double dipping” of federal awards.
The County and its departments must develop and implement effective internal controls to help
ensure funding decisions under the SLFRF award constitute eligible uses of funds and to
document determinations.
4.2 Allowable Costs/Cost Principles (B)
As outlined in the Uniform Guidance in 2 CFR Part 200, Subpart E regarding Cost Principles,
allowable costs are based on the premise that sound management practices and administration
The County Commissioners approved each project based on the applicant’s
proposed project outline. Each project was deemed allowable under the Final Rule.
All expenditures should be used specifically for the approved project. If a department
has excess funds, it must communicate this immediately to the County.
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of federal funds should be in a manner consistent with the project objectives and terms and
conditions of the award.
Consistent with the Final Rule, administrative costs are allowable for projects funded with
SLFRF, including costs of consultants to support effective management and oversight, such as
consultation to help ensure compliance with legal, regulatory, and other requirements. Further,
costs must be reasonable and allocable, as outlined in 2 CFR § 200.404 and 2 CFR § 200.405.
Pursuant to the Final Rule, recipients are permitted to charge both direct and indirect
administrative costs to their award.
Direct administrative costs are those identified specifically as the costs of implementing the
SLFRF program objectives, such as contract support, materials, and supplies for a project.
Indirect administrative costs are an organization’s general overhead costs, where a portion of
such costs is allocable to the SLFRF award (e.g., the cost of facilities or administrative
functions, such as a director’s office). Each category of cost should be treated consistently in
like circumstances as direct or indirect, and recipients may not charge the same administrative
costs to both direct and indirect cost categories or to other programs.
4.3 Cash Management (C)
SLFRF payments made to recipients are not subject to the requirements of the Cash
Management Improvement Act nor the U.S. Treasury’s implementing regulations at 31 CFR
Part 205 or 2 CFR § 200.305(b)(8) – (9).
As such, recipients can place funds in interest-bearing accounts, do not need to remit interest to
the U.S. Treasury, and are not limited to using that interest for eligible uses under the SLFRF
award.
The County will keep funds in a separate special revenue fund and will use pooled cash across
the funds.
4.4 Eligibility (E)
Each department is responsible for adhering to the eligibility requirements of the specific project
the department was awarded under. The department must develop and implement policies and
procedures to help ensure it follows the eligibility requirements outlined in its specific grant
award and terms and conditions.
4.5 Equipment and Real Property Management (F)
Any purchases of equipment or real property with SLFRF must be consistent with 2 CFR Part
200, Subpart D of the Uniform Guidance. Any equipment and real property acquired with SLFRF
must be used for the originally authorized purpose. Consistent with 2 CFR § 200.311 and 2 CFR
§ 200.313, any equipment or real property acquired using SLFRF shall vest in the non-federal
entity. Any acquisition and maintenance of equipment or real property must also comply with
relevant laws and regulations. Any equipment purchases in excess of $1 million require
Internal ARPA Projects Handbook 8
preapproval from the U.S. Treasury; therefore, departments must obtain prior approval from the
County before spending $1 million.
Exhibit A outlines use requirements by category from the U.S. Treasury.1
Exhibit A: U.S. Treasury Use Requirements
4.6 Matching, Level of Effort, Earmarking (G)
No matching, level of effort, or earmarking compliance responsibilities are associated with the
SLFRF award.
4.7 Period of Performance (H)
SLFRF may only be used for costs incurred within a specific period, beginning March 3, 2021,
with all funds obligated by December 31, 2024, and all funds spent by December 31, 2026. This
is known as the Period of Performance, and all departments must adhere to this requirement.
1 The U.S. Department of the Treasury. Coronavirus State and Local Fiscal Recovery Funds Final Rule: Frequently
Asked Questions. Treasury.gov, July 27, 2022. Accessed October 3, 2022.
https://home.treasury.gov/system/files/136/SLFRF-Final-Rule-FAQ.pdf
Internal ARPA Projects Handbook 9
4.8 Procurement, Suspension & Debarment (I)
4.8.1 Procurement
Recipients are responsible for helping to ensure that any procurement using SLFRF, or
payments under procurement contracts using such funds, are consistent with the procurement
standards set forth in the Uniform Guidance at 2 CFR § 200.317 through 2 CFR § 200.327, as
applicable. The Uniform Guidance establishes in 2 CFR § 200.319 that all procurement
transactions for property or services must be conducted in a manner providing full and open
competition, consistent with standards outlined in 2 CFR § 200.320, which allows for non-
competitive procurements only in circumstances where at least one of the conditions below is
true:
• The item is below the micro-purchase threshold
• The item is only available from a single source
• The public exigency or emergency will not permit a delay from publicizing a competitive
solicitation
• After solicitation of several sources, competition is determined inadequate
Recipients must have and use documented procurement procedures consistent with the
standards outlined in 2 CFR § 200.317 through 2 CFR § 200.320. The Uniform Guidance
requires an infrastructure for competitive bidding and contractor oversight, including maintaining
written standards of conduct and prohibitions on dealing with suspended or debarred parties.
Departments must help ensure adherence to all applicable local, state, and federal procurement
laws and regulations.
The Davis-Bacon Act requirements (prevailing wage rate) do not apply to projects funded solely
with award funds from the SLFRF program. If the project is funded with other sources of federal
funding, the Davis-Bacon Act might apply. The project may be subject to Washington State
prevailing wage law as defined in RCW 39.04. Recipients must review these requirements and
determine if state prevailing wage law applies.
The departments must also follow all local policies established under Resolution No. 16-344. –
Establishing Procedures for the Procurement of Goods and Services – “Procurement Procedure
Manual.” The departments are responsible for following all statutory requirements related to
purchasing, bidding, and contracting.
The County has developed an RFP Checklist for SLFRF-related bids. Please reach out to the
Budget Department for a copy.
4.8.2 Suspension and Debarment
All subrecipients, beneficiaries, and contractors receiving SLFRF are required to be registered
with the System for Award Management (SAM) and obtain a UEI number.
• Requirement for SAM: Unless the subrecipient is exempt from this requirement under 2
CFR 25.110, the subrecipient must enroll in SAM and help ensure the information in the
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system is up to date and accurate until the subrecipient submits the final financial report
required under this grant or receives the final payment, whichever is later. This requires
the subrecipient to review and update the information at least annually after the initial
registration, and more frequently if required by changes in information or another award
term. Additional information about registration procedures may be found at the SAM
website (http://www.sam.gov).
• Requirement for UEI: The entity must provide its UEI number as part of accepting the
grant. If the subrecipient does not have a UEI number, the subrecipient must apply for
one. A UEI number may be obtained at the SAM website (http://www.sam.gov).
Subrecipients may not receive SLFRF if they are suspended or debarred by the federal
government. Suspension and debarment are when a federal agency or official takes action to
exclude an individual or organization from participating in transactions involving certain federal
funds. Suspension is for a specific period, whereas debarment is a permanent ban.
When entering a covered transaction, as defined by 2 CFR § 180.200, the subrecipient must:
• Verify the non-federal entity is eligible to participate in this federal project by:
o Checking the excluded parties list system (EPLS), as maintained within the SAM,
to determine if a non-federal entity is excluded or disqualified, or
o Collecting a certification statement from the non-federal entity attesting the
subrecipient is not excluded or disqualified from participating, or
o Adding a clause or condition to covered transactions attesting the individual or
firm is not excluded or disqualified from participating
• Require prime contractors to comply with 2 CFR § 180.330 when entering lower-tier
transactions (e.g., subcontracts)
• Immediately disclose to the County whenever the subrecipient: (1) learns it has entered
a covered transaction with an ineligible entity or (2) suspends or debars a contractor,
person, or entity
4.9 Program Income (J)
Program income includes income under a specific SLFRF project from fees for services
performed, the use of rental of real or personal property acquired under federal awards, and
principal and interest on loans made with federal award funds.
Uniform Guidance outlines the requirements that pertain to program income at 2 CFR § 200.307
and can be found here: https://www.federalregister.gov/documents/2013/12/26/2013-
30465/uniform-administrative-requirements-cost-principles-and-audit-requirements-for-federal-
awards.
If you believe you have generated program income, please contact the Auditor’s Office.
Internal ARPA Projects Handbook 11
4.10 Reporting (L)
The SLFRF program identifies a single set of reporting requirements for Expenditure and
Performance data for the full amount of ARPA funds received by the County. The County is
responsible for gathering all necessary documentation from departments receiving a subaward
from the County.
4.10.1 Types of Required Reports
Project and Expenditure Reports
These reports are required on a quarterly basis and are due one month after the end of the
quarter. These reports include Expenditure and Programmatic data, including funding,
expenditures, project status, demographic information on the population receiving the benefit,
and required Programmatic Data in conjunction with the Expenditure Categories outlined in the
Final Rule. The reports also include specific reporting requirements for contractors and
subrecipients that received more than $50,000 from the Federal Funding Accountability and
Transparency Act (FFATA).
Table 1 below outlines the due dates of each project and expenditure report.
Table 1: Quarterly Project and Expenditure Report Timeline
Report Year Quarter Period Covered Due Date
1 2021 2 – 4 March 3 – December 31 January 31, 2022
2 2022 1 January 1 – March 31 April 30, 2022
3 2022 2 April 1 – June 30 July 31, 2022
4 2022 3 July 1 – September 30 October 31, 2022
5 2022 4 October 1 – December 31 January 31, 2023
6 2023 1 January 1 – March 31 April 30, 2023
7 2023 2 April 1 – June 30 July 31, 2023
8 2023 3 July 1 – September 30 October 31, 2023
9 2023 4 October 1 – December 31 January 31, 2024
10 2024 1 January 1 – March 31 April 30, 2024
11 2024 2 April 1 – June 30 July 31, 2024
12 2024 3 July 1 – September 30 October 31, 2024
13 2024 4 October 1 – December 31 January 31, 2025
14 2025 1 January 1 – March 31 April 30, 2025
15 2025 2 April 1 – June 30 July 31, 2025
16 2025 3 July 1 – September 30 October 31, 2025
17 2025 4 October 1 – December 31 January 31, 2026
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Report Year Quarter Period Covered Due Date
18 2026 1 January 1 – March 31 April 30, 2026
19 2026 2 April 1 – June 30 July 31, 2026
20 2026 3 July 1 – September 30 October 31, 2026
21 2026 4 October 1 – December 31 March 31, 2027
4.10.2 Submission of Required Reporting
The Budget Department requires all departments submit monthly reports that show life-to-date
obligations and life-to-date expenditures; the Budget Department will provide the template.
Monthly reporting will allow the County to monitor ongoing activities in a timely manner.
The County may also require subrecipients to submit quarterly programmatic information based
on the unique nature of each project and the related expenditure category, as defined by the
U.S. Treasury.
4.11 Subrecipient Monitoring (M)
As noted in Section 3.0, Roles and Responsibilities, the County is required, in accordance with
2 CFR 200.1, to manage and monitor the subrecipients to help ensure compliance with the
requirements of Uniform Guidance and the SLFRF.
Under the SLFRF program, some subrecipients will further subaward the funds to sub-
subrecipients. Please refer to your individual grant awards to further understand if your grant will
have or can give subawards. The use of subawards of the grant requires preapproval and
discussion with the County. See the required elements under Section 4.11.2 Monitoring.
Please check with the Auditor’s Office to see if your department has any subrecipients.
4.11.1 Risk Assessment
In accordance with 2 CFR Part 200.332(b), each subrecipient that subawards SLFRF to another
entity (a sub-subrecipient) is required to “evaluate each [sub-subrecipient’s] risk of
noncompliance with Federal statues, regulations, and the terms and conditions of the subaward
for the purposes of determining the appropriate subrecipient monitoring.”
Each subrecipient that subawards should develop a risk assessment process that clearly
documents the steps performed as well as how the outcomes of the preliminary risk assessment
subsequently impact the subrecipient’s plans to monitor its sub-subrecipients. This process
should include assigning risk ratings to each sub-subrecipient based on assessments
performed. Please refer to the Subrecipient Monitoring Handbook for more guidance. The
handbook contains a sample questionnaire that can be used to obtain the information necessary
to complete the preliminary risk assessment.
This risk assessment should be updated annually to incorporate relevant information, such as
results of monitoring activities, results of subrecipient audits, and other relevant factors.
Internal ARPA Projects Handbook 13
Risk assessments must be specific to the funding source. In the event a subrecipient receives
multiple subawards from the County, a separate risk assessment must be completed for each
funding source.
4.11.2 Monitoring
The purpose of monitoring, as defined by 2 CRF § 200.332, is to “monitor the activities of the
subrecipient as necessary to ensure that the subaward is used for authorized purposes, in
compliance with Federal statutes, regulations, and the terms and conditions of the subaward;
and that subaward performance goals are achieved.”
The subrecipients that subaward SLFRF must establish processes for monitoring their sub-
subrecipients using a risk-based approach, as required by 2 CFR § 200.332 (d). At minimum,
the monitoring should include the following activities:
• Reviewing financial and performance reports required by the County.
• Following up and helping to ensure the sub-subrecipient takes timely and appropriate
action on all deficiencies pertaining to the federal award provided to the sub-
subrecipient, detected through audits, on-site reviews, and written confirmation from the
sub-subrecipient, highlighting the status of actions planned or taken to address Single
Audit findings related to the particular subaward.
• Issuing a management decision for applicable audit findings pertaining only to the
federal award provided to the subrecipient from the pass-through entity, as required by 2
CFR § 200.521.
• Ensuring the subrecipients resolve audit findings specifically related to the subaward to
the sub-subrecipient and are not responsible for resolving cross-cutting findings (an
audit finding where the same underlying condition or issue affects federal awards of
more than one federal awarding agency or pass-through entity). If a sub-subrecipient
has a current Single Audit report posted in the Federal Audit Clearinghouse and has not
otherwise been excluded from receipt of federal funding (e.g., has been debarred or
suspended), the subrecipient may rely on the sub-subrecipient's cognizant audit agency
or cognizant oversight agency to perform audit follow-up and make management
decisions related to cross-cutting findings in accordance with 2 CFR § 200.513(a)(3)(vii).
Such reliance does not eliminate the responsibility of the subrecipient to issue sub-
subawards that conform to agency- and award-specific requirements, to manage risk
through ongoing monitoring of the sub-subaward to the sub-subrecipient, and to monitor
the status of the findings specifically related to the sub-subaward.
The subrecipients with subawards to sub-subrecipients are also responsible for developing a
process to:
• Verify that every sub-subrecipient is audited, as required by Subpart F, when it is
expected that the sub-subrecipient's federal awards expended during the respective
fiscal year equaled or exceeded the threshold set forth in 2 CFR § 200.501.
Internal ARPA Projects Handbook 14
• Consider whether the results of the sub-subrecipient's audits, on-site reviews, or other
monitoring indicate conditions that necessitate adjustments to the subrecipient’s own
records.
• Consider taking enforcement action against noncompliant sub-subrecipients, as
described in 2 CFR § 200.339.
Any subrecipient that intends on transferring funds to a beneficiary should consult the County
and obtain preapproval.
4.12 Special Tests and Provisions (N)
At the time of this report, no specific special tests or provisions exist. The U.S. Treasury may
issue sub regulatory guidance as well as FAQs.
Internal ARPA Projects Handbook 15
5.0 Other Grant Requirements
5.1 Maintenance of Records
The department should help ensure it maintains appropriate documentation to support all uses
of the SLFRF. The department is required to maintain records and financial documentation
sufficient to help ensure compliance with all applicable guidance and regulations.
The below list provides examples of documentation that should be maintained:
• Policies and procedures for the administration of federal funds
• Monitoring or audit reports
• General Ledger used to account for SLFRF activity
• Budget records
• Payroll, time records, and Human Resources records to support costs incurred for all
payroll expenses related to the SLFRF award
• Invoices for and receipts of purchases made related to the SLFRF award
• Contracts and subcontracts entered into using SLFRF payments and documents related
to such contracts
• Grant agreements
• All procurement-related materials, including RFPs, scoring materials, and records of
negotiations
• All internal and external emails related to use of SLFRF payments
These records are to be maintained in accordance with accounting procedures and practices,
which sufficiently and properly reflect all such costs and expenses and are acceptable to the
County to include, without limitation, all ledgers, books, records, and original evidence of costs
such as purchase requisitions and orders, vouchers, requisitions for materials, inventories,
valuations of in-kind contributions, labor timecards, payrolls, and other records requested or
required by the County.
Internal ARPA Projects Handbook 16
Financial records, supporting documents, statistical records, and all other non-federal entity
records pertinent to the federal award must be retained for a period of five years from the date
of submission of the final expenditure report.
5.2 Single Audit
The County and all its departments will be subject to an audit under the Single Audit Act and its
implementing regulation of 2 CFR § 200, Subpart F, regarding audit requirements.
The Office of Management and Budget (OMB) Compliance Supplement provides information on
existing important compliance requirements the federal government expects to be considered
as part of such audit.
SLFRF is considered to be high risk and will undergo an annual Single Audit.
5.3 Lobbying
State and local agencies are permitted to conduct lobbying work directly on policy-related
matters across the agencies’ equivalent branches of state or local government. This derives
from language in Section 503 permitting communications through a normal and recognized
executive-legislative relationship and permitting recipients to participate in policymaking and
administrative processes within the executive branch of their state or local government, if within
these boundaries. These types of lobbying activities would not require disclosure on a lobbying
disclosure form.
Per the U.S. Treasury’s website: “If any funds have been paid or will be paid to any person for
influencing or attempting to influence an officer or employee of any agency, a Member of
Congress, an officer or employee of Congress, or an employee of a Member of Congress in
connection with a Federal contract, grant, loan, or cooperative agreement, the undersigned shall
complete and submit Standard Form-LLL, “Disclosure of Lobbying Activities,” in accordance
with its instructions.”
Best Practices
•Develop a written document-retention policy
•Establish a central place to store documents
•Maintain documents for a minimum of five years after all SLFRF has been expended
Internal ARPA Projects Handbook 17
6.0 Closeout Phase
Closeout is the process by which the department determines that all applicable administrative
actions and all required work of its grant award have been completed. This is the completion of
the grant award life cycle. Closeout is a process that takes place prior to and after the expiration
or termination of the project or the grant period.
The County will close out grant awards when the department completes all applicable
administrative actions and all required work of the award. This includes submission of all
required reports under the SLFRF, reconciliation of cash balances, and final disposition of
property. The County will make every effort to complete the closeout process for each award no
later than 180 days after receipt and acceptance of all required federal reports.
The purpose of closeout is to help ensure:
• Final reports are received and evaluated
• Allowable costs are determined
• Amounts due to the County are determined, and payment arrangements are made
As a grant recipient, each department must meet several requirements before closing out a
grant in the final budget period of the project. Preparation for closeout should begin three
months prior to the end date of the grant in order to accurately forecast expenses and adjust
any entries that need to be made. Closeout reports must be submitted within 120 days of the
end of the project period.