American Rescue Plan Act (ARPA) Technical Assistance

  • ARPA 360 Virtual Training Session Recordings

    ARPA 360 is a free, online training sessions designed to give North Carolina local governments specific instructions on the steps needed to obligate remaining American Rescue Plan Act (ARPA) State and Local Fiscal Recovery Funds (SLFRF) in a timely manner. To account for vast differences in compliance requirements, ARPA 360 was delivered in two separate sessions depending on the SLFRF allocation amount received by the local government ($10 million or less; and over $10 million). Each session recording will be available soon.

    The two full-day sessions were presented by the UNC School of Government, North Carolina League of Municipalities, and North Carolina Association of County Commissioners. *This training was part of a project that is being supported, in whole or in part, by federal award number SLFRP0129 awarded to the State of North Carolina by the U.S. Department of the Treasury. 

Overview of the American Rescue Plan Act, Coronavirus State and Local Fiscal Recovery Fund (SLFRF) Program

On March 11, 2021, U.S. Congress enacted the American Rescue Plan Act (ARPA), which included $350 billion in federal assistance for state, local and Tribal governments across the country to support their response to and recovery from the COVID-19 public health emergency. The federal Coronavirus State and Local Fiscal Recovery Funds program (SLFRF) provided direct allocations from U.S. Treasury to all 100 North Carolina counties using a methodology based on population. Additionally, Congress allocated $5.4 billion in federal SLFRF funds to North Carolina. North Carolina’s share of SLFRF funds were appropriated in the state budget, which was enacted on November 17, 2021. Some local governments received additional state-directed SLFRF funds for specific projects, which are administered through various state agencies.

All SLFRF-funded projects must meet the statutorily mandated deadlines. SLFRF funds must be obligated by December 31, 2024, and be fully expended by December 31, 2026. (Recipients using SLFRF funds for Surface Transportation and Title I projects under the expanded eligible uses outlined in 2023 Interim Final Rule must fully expend those project funds by September 30, 2026).

Counties are responsible for effective administration of federal ARPA funds. Since the inception of the SLFRF program, federal guidance has been constantly evolving. In response to public comments during the rule making process, and Congressional action to expand SLFRF eligible use categories, U.S. Treasury has issued various updates to its eligibility, reporting and compliance documents. Please ensure your county is using the most recent guidance as SLFRF funds are implemented locally.

Stay connected to the latest ARPA updates!

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  • View other resources and contact information
    • Click here to access U.S. Treasury’s webpage for the ARPA Coronavirus State and Local Fiscal Recovery Fund program.
    • Click here for county-by-county allocation amounts.
    • Click here for U.S. Treasury Self-Service resources.
    • For general questions about the SLFRF program, please email [email protected].
    • For IT technical support using the U.S. Treasury portal, email [email protected].
    • Click here to access the NC Office of State Budget and Management page for information on state-directed grants appropriated legislatively to non-state entities.
    • For the latest ARPA updates, subscribe to NCACC’s ARPA Resource Roundup digital newsletter.
    • Send ARPA questions to [email protected].

NCACC ARPA Resources

NCACC provides technical tools, resources, and educational opportunities to assist counties with ARPA-related issues. For specific inquiries about the ARPA SLFRF program or to learn more about upcoming NCACC offerings, email [email protected].

Technical Assistance

In 2021, the North Carolina General Assembly directed the North Carolina Association of County Commissioners (NCACC) to create a technical assistance program to help counties navigate new and complex administrative requirements related to the SLFRF program and national opioid settlement funds. NCACC offers a range of technical and capacity assistance to counties through a new service arm, NCACC Strategic Member Services, or “SMS.” SMS is staffed by a team of senior-level technical experts and a cohort of strategic project coordinators, who recently graduated from master’s-level programs in areas relevant to county administration. For more information on specific assistance offered by SMS, email Jason King, Director of Strategic Member Services, at [email protected].

  • Prohibited Uses

    U.S. Treasury outlines several prohibited uses. SLFRF funds MAY NOT be used for:

    • No rainy day funds/financial reserves.
    • No debt service payments.
    • No Medicaid or CHIP program cost share.
    • No activities that undermine CDC public health guidance.
    • No violations of the federal uniform guidance including conflict of interest rules.
    • No activities that violate state or other federal laws and regulations.
    • No litigation, settlements, or judgments.
    • No extraordinary pension contributions. *The prohibition does not apply to pension contributions that are part of regular payroll contributions for employees whose wages and salaries are an eligible use of Recovery Funds.
  • Using SLFRF Funds for Broadband Projects

    North Carolina counties have limited authority to provide grant funding for broadband projects. The North Carolina state budget, enacted on November 17, 2021 (S.L. 2021-180), included provisions that gave counties legal authority to use either their direct allocation of federal ARPA dollars, or unrestricted General Funds for “broadband” projects in “unserved” areas of North Carolina as strictly defined in state law. The legislation also created a new program, the Completing Access to Broadband program, which enables counties to partner with the state by providing ARPA recovery funds or unrestricted general funds a partner with the state to provide matching funds for broadband infrastructure projects in unserved and underserved areas.

    • Click here to access SLFRF and CPF Supplementary Broadband Guidance, which applies to SLFRF-funded broadband projects categorized in expenditure category 5.19-5.21.
    • Click here to access the NCACC Connecting Counties Playbook, which provides information, resources, maps and strategies to help counties expand access to broadband.
    • Click here to access information on the NC Department of Information Technology Division of Broadband and Digital Equity.
  • Eligibility

    Generally, eligible expenditures fall into seven broad categories summarized below. Each project must correspond to a more specific expenditure category listed in Appendix 1 of the SLFRF Compliance and Reporting Guidance.

    • U.S. Treasury provides specific guidance for the following eligible uses in the 2022 Final Rule, the 2022 Final Rule Overview; and the 2022 Final Rule FAQs. Additional guidance for projects categorized under Broadband Infrastructure is outlined in the SLFRF and CPF Supplementary Broadband Guidance.
      • Responding to the public health emergency or its negative economic impacts.
      • Expanding public sector capacity and providing premium pay to workers performing essential work during the COVID-19 public health emergency.
      • Investing in water, sewer, and broadband infrastructure.
      • Providing general government services to the extent of revenue loss due to the pandemic.
    • U.S. Treasury provides specific guidance for the following eligible uses in the 2023 Interim Final Rule and the Overview of the 2023 Interim Final Rule:
      • Emergency relief from natural disasters or their negative economic impacts.
      • Surface transportation projects.
      • Title I projects eligible under the CDBG and ICDBG programs.

    Counties must have statutory authority under North Carolina law to undertake a particular activity and use ARPA funds to finance the project. See details below:

    • North Carolina General Statutes Chapter on Counties § 153 A.
    • § 160A-17.1 authorizes the governing body of any city or county to make contracts for and to accept grants-in-aid and loans from the federal and state governments and their agencies for constructing, expanding, maintaining, and operating any project or facility, or performing any function, which such city or county may be authorized by general law or local act to provide or perform. 
    • § 160D-1311 outlines state authority for local governments to engage in certain community development programs and activities to provide for the “welfare needs of persons of low and moderate income.” 
    • § 160A-497 gives local governments broad authority to assist senior citizens.
    • The North Carolina Constitution states that “Beneficent provision for the poor, the unfortunate, and the orphan is one of the first duties of a civilized and a Christian state.” 
    • The North Carolina Constitution requires all expenditures of public funds to be “for public purposes only.” It also prohibits “emoluments or privileges” (gifts) unless a public service is provided in return.
  • Reporting and Compliance

    In addition to determining the eligibility of a project, counties must also assess whether they have state authority to complete projects, adhere to U.S. Treasury’s reporting requirements, and abide by all applicable federal uniform guidance requirements. Unlike previous federal recovery funds that counties received from the CARES Act, ARPA funds come to counties directly from U.S. Treasury. This means counties are responsible for their own reporting and compliance. The North Carolina Pandemic Recovery Office, also known as NCPRO, is not involved in administering the county’s ARPA funds. Therefore, it’s up to each county to understand and meet ARPA compliance and reporting requirements.

    To ensure accountability and transparency, counties must regularly submit reports to U.S. Treasury regarding their expenditures along with any necessary data that justify their eligibility determinations for projects. This rigorous reporting provides publicly available information about projects and expenditures. These reports are due to Treasury at regular intervals throughout the life of the program. Generally, the complexity of compliance is related to the amount of ARPA funds a county receives, its population, and the expenditure categories of each project a county chooses to fund.

    All SLFRF funds are subject to all the award terms and these expenditures must be tracked and managed separately from the county general fund account. Some of the provisions of 2 CFR Part 200 federal Uniform Guidance or “UG” requirements apply to SLFRF-funded projects (see 2022 Final Rule FAQ Section 13). The type of uniform guidance administrative requirements for ARPA projects are tied specifically to the expenditure category for the project. Funds expended under the “revenue replacement” category (Expenditure Category 6.1) have the least amount of reporting and uniform guidance compliance requirements. Depending on the details of the project, certain uniform guidance requirements may be triggered, so it’s important to become familiar with the specific uniform guidance compliance requirements for the SLFRF program.

    • Click here to access the U.S. Treasury webpage on compliance and reporting for the SLFRF program.
    • Click here to Compliance and Reporting Guidance for the SLFRF program.

UNC School of Government Office Hours

The UNC School of Government (SOG) hosts virtual ARPA Office Hours for local governments to discuss issues related to the American Rescue Plan Act Fiscal Recovery Fund program. NCACC participates in these sessions and provides timely updates for counties on ARPA-related matters. Click here for the UNC SOG ARPA Office Hours.

NCACC ARPA Technical Assistance Team