State and Local Fiscal Recovery Fund (SLFRF): Frequently Asked Questions
On May 10, the U.S. Department of Treasury released an interim final rule, FAQs and a fact sheet for a significant portion of the $362 billion Coronavirus State and Local Fiscal Recovery Fund, established under the American Rescue Plan Act (ARP) signed into law on March 11 by President Biden. This specific interim rule and related guidance covers the $65.1 billion in direct federal aid to America’s counties.
This FAQ page covers the basics of SLFRF allocation and reporting and addresses common questions about using SLFRF for prenatal-to-three investments. For more comprehensive analysis and the latest updates from the National Association of Counties, visit the COVID-19 Recovery Clearinghouse.
+ Allocation Information
Q. How much money will states, counties and cities receive from the State and Local Fiscal Recovery Fund (SLFRF) allocation?
A. The American Rescue Plan provides $350 billion in SLFRF. States received $195.3 billion, counties $65.1 billion, and cities $45.6 billion. Tribal governments, US territories, and non-entitlement units of local government that serve populations with fewer than 50,000 people also will receive funds. The U.S. Department of the Treasury's Coronavirus State and Local Fiscal Recovery Funds webpage offers additional information, including specific allocations for individual state, counties and cities.
Q. When will states, counties and cities receive their SLFRF allocations?
A. The Treasury Department will distribute SLFRF dollars in two tranches. Recipients became eligible to apply for funds beginning in May 2021, but will receive allocations only after they submit a request for funds through the Treasury Department’s ID.me portal. Second tranche funds will be released one year after the first disbursement. The U.S. Department of the Treasury’s Request Funding webpage2 is the best place to learn more about the submission process.
Q. What is the SLFRF spending deadline?
A. Recipients must obligate their SLFRF dollars by December 31, 2024, and expend them by December 31, 2026; however, recipients should monitor the Treasury Department's SLFRF website for updates.
Q. What is the difference between obligated and expended funds?
A. Obligated funds refer to the legal contracting of funds for a specific use by the government to spend on a later day. Expended funds refer to the actual spending of funds.
Q. How do ARPA spending guidelines differ from those of the Coronavirus Aid, Relief, and Economic Security (CARES) Act?
A. Both ARPA and the CARES Act are intended to aid state and local governments in their work of supporting their communities through pandemic recovery. Primary differences between the plans include limitations around using recovery funds to cover payroll expenses for public health and public safety employees and using recovery funds for the nonfederal match requirement. USAFacts published a helpful article comparing the spending-related focus areas between these two funding streams.
+ Eligible Uses: Prenatal-to-Three
Note: All page and question numbers in this section refer to this document from Treasury.
Q. How can my state, county, or city spend its SLFRF allocation?
A. According to the Treasury Department, recipients can use their SLFRF allocations to support programs and services that fall into one of four categories:
- Address negative economic impacts of the pandemic or respond to the public health emergency
- Replace lost revenue
- Provide premium pay
- Invest in water, sewer, or broadband infrastructure
Note that eligible uses highlighted in the Treasury’s guidance is a noninclusive list of programs and services. Recipients have a lot of flexibility to determine how to spend their SLFRF allocations.
Q. Are state and county governments able to subgrant funds to non-profit organizations?
Yes. Nonprofits are federal tax-exempt organizations which are described in section 501(c)(3) of the Internal Revenue Code. Although the Treasury cannot provide SLFRF funds directly to nonprofit or private organizations, state and local governments can (see question 1.8 on page 3). Nonprofits receiving funds from recipients will be considered subrecipients and are responsible for complying with all subrecipient reporting requirements. Refer to the Treasury’s Compliance and Reporting Guidance for more information.
Q. Can county governments provide direct assistance to families?
Yes. Recipients are authorized to offer services in the form of assistance to households to address the negative economic impacts of the pandemic. Assistance to households includes, but is not limited to, food assistance, housing or or utility assistance, cash assistance or job training. Please refer to the question 2.5 on page 5 of the FAQ for a non-inclusive list of eligible household assistance programs.
Q. Is modifying or expanding a building for child care purposes an eligible use of SLFRF?
A. Yes. The Treasury Department allows counties to upgrade publicly owned facilities as capital improvement projects, as responses to negative economic impacts (see question 2.5 on page 5), or as revenue replacements (see question 3.8 on page 15). The use of SLFRF funds focuses on equitable-recovery, so projects need to benefit those who were disproportionately affected by the pandemic (see 2.11 on page 7). An important point to highlight is that funds cannot be used to acquire or construct new facilities. The Center for Law and Social Policy has additional information about using federal relief funds to improve child care facilities.
Q. Can counties use SLFRF allocations to expand the child care sector workforce?
A. Yes. Guidance from the Treasury Department indicates that recipients may not use funds for general economic or workforce development unless the sector in question has experienced negative economic impacts as a result of the pandemic (see 2.8 on page 6). Because the child care sector was among the most impacted industries in the country, it can receive funds to expand the workforce. For example, the SLFRF allows recipients to fund public jobs programs so long as the services target unemployed and/or underemployed workers (see question 2.16 on page 9). Recipients also should explore the use of Child Care Stabilization Grant (CCSG), Higher Education Emergency Relief Fund III (HEERF III), and Elementary and Secondary School Emergency Relief Fund (ARPA ESSER) dollars to expand the child care sector workforce.
Q. Can counties use SLFRF allocations for outreach and marketing efforts for coordinated intake programs?
A. Yes. Counties may use funds to support outreach initiatives aiming to increase the uptake of federal assistance services and programs (see question 4.12 on page 26). Although the Treasury Department guidance specifically mentions the Child Tax Credit and Supplemental Nutrition Assistance Program (SNAP), recipients are allowed to use funds for a wide variety of federal programs.
Q. Can counties use SLFRF allocations to fund children’s mental health services and programs?
A. Yes. Mental and behavioral health services are allowable uses of SLFRF and can be implemented in school and community-based settings (see question 4.8 on pages 21-22).
Q. Can SLFRF be used for urban farming and community gardening initiatives?
A. Yes. Urban farming and community gardening initiatives can qualify as an eligible use of SLFRF, especially if they exist in a QCT (see question 2.18 on page 11). Recipients should consider two key points in regard to this initiative. First, recipients must be able to provide thorough impact assessments when reporting on the program and second, they must be cognizant of the obligation and expenditure dates.
+ Reporting and Compliance
Q: Is there additional guidance available from the Treasury Department on expectations for demonstrating how Qualified Census Tracts were disproportionately impacted?
A. Eligible uses provided in a Qualified Census Tract (QCT) are outlined in question 2.11 on page 7. Reporting and compliance guidelines pertaining to project demographic distribution and QCT status is available in Compliance and Reporting Guidance: State and Local Fiscal Recovery Funds (section 3d on page 17). The Treasury Department plans to release more guidance via compliance and reporting templates in the future that will most likely better highlight expectations for reporting on services focused on QCTs.
Q. What reports will counties need to submit?
A. The Treasury requires three types of reports for the SLFRF program (sections and pages below refer to this document):
- Interim Report: Requires recipients to outline intended uses of their funding allocations and should only be submitted (see Section A, page 13).
- Project and Expenditure Report: Documents funded projects, expenditure amounts, and existing contracts and takes the form of a quarterly and/or annual reports (see Section B, page 15).
- Recovery Plan Performance Report: Provides information on projects funded by large recipients and includes performance tracking requirements (see Section C, page 23).
Q. Where can counties get additional information on reporting requirements?
A. All information related to the Treasury’s reporting and compliance requirements can be found here. The Treasury Department plans to issue a User Guide and other materials before any reporting deadlines. To date, the Treasury has released a Recovery Plan Template to serve as a resource for recipients. Recipients will be responsible for submitting their reports through the Treasury Submission Portal.
This resource was created in partnership with the Children’s Funding Project. The Children’s Funding Project, a partner of the National Collaborative for Infants and Toddlers, helps communities and states expand equitable opportunities for children and youth through strategic public financing. Explore their COVID-19 recovery resources here.