To determine your jurisdiction’s status, please look in the US Treasury’s Compliance and Reporting Guidance, page 13.
If your organization is a Tier 1-3, GFOA strongly recommends filing by the deadline. Completing the report as early as possible will ensure your jurisdiction will not be considered late, which may lead to a finding of non-compliance. The best source of information on how to submit reports is the user guide, which contains detailed submissions instructions and includes answers to frequently asked questions (FAQs) for reporting.
Importantly, the United States Treasury has been clear that most submitted information is revisable in your subsequent quarterly report due in April 2022.
Several GFOA members have noted key questions about information required in the US Treasury’s State and Local Fiscal Recover Fund (SLFRF) portal. Please see below for the FAQs and Treasury’s suggestions on how to proceed.
If your organization has neither obligated nor expended any SLFRF funds:
If your jurisdiction has not yet identified any projects to report, please know that maintaining a project list is a core requirement of the SLFRF program. For the Project and Expenditure Report due January 31, 2022 Treasury will be offering an option to select “No Projects to Report” at this time. Selecting this option will require providing a written explanation and may result in additional compliance follow-up from Treasury.
If your organization has not decided whether or not to take the standard allowance:
First, the Project and Expenditure Report does not build on the information of recipient’s Interim Report, unless you choose to import that information. Second, if recipients have not decided whether or not to take the standard allowance, Treasury will not commit them to their reported choice in the January 31st report. Decisions made in the reporting around the standard allowance as part of the January 31 P&E may be changed in the April 2022 project and expenditure report when the Final Rule takes effect. More guidance on this will be released by Treasury as we approach April. If recipients have nothing to report in the Revenue Replacement section, they may enter zero in the required fields and use the description box to explain that they have not yet allocated funds under revenue loss and will update their response in future reporting cycles. Treasury may choose to follow up in these cases for further details.
Process recommendation for jurisdictions who have used or plan to use 6.1:
Revenue loss (6.1) – This is a required input but the US Treasury will not commit recipients to their reported choice in the January 31st report. Decisions made in the reporting around the standard allowance as part of the January 31 P&E may be changed in the April 2022 project and expenditure report when the Final Rule takes effect.
If your organization has projects with transactions >$50,000:
Treasury requires that all projects identify information for each subaward or direct payment of federal funding greater than $50,000. However, treasury is using the term subrecipient to include the contractor relationship (purchase orders, delivery orders, blanket purchase agreement, definitive contract) as well as any grants, loans, direct payments or transfers. Said plainly, Treasury goes beyond the definition of subrecipient in Uniform Guidance. See the below screen shot for a description of all transaction types considered “subaward types” for portal reporting purposes.
GFOA recommends recipients proceed with inputting financial information by project by selecting a category of subaward, which is a broad range of types of transactions, though not necessarily subawards as defined in Uniform Guidance 2 CFR 200.92
We hope that this additional information is helpful as you prepare to submit your first Project and Expenditure Report. Please do not hesitate to reach out to your Federal Liaison Center if you have any questions.