If a city has made a determination and documented that a project fits within a specific eligibility category under ARP, can the eligibility determination later be changed if our compliance team determines the initial classification is no longer correct?

Municipalities will have an opportunity to reopen and provide edits to their submitted reports any time before the reporting deadline, with the exception of the Interim Report, which cannot be reopened and edited after submission. The U.S. Department of the Treasury’s (“Treasury”) Portal for Recipient Reporting State and Local Fiscal Recovery Funds User Guide (the “User Guide”) and the Project and Expenditure Report User Guide provide the following guidance on editing or updating previously submitted reports:

• Interim Report: No changes will be allowed after the initial submission. Any updates will be captured when the first Project and Expenditure Report is submitted.[1]
• Project and Expenditure Reports: Recipients will have an opportunity to reopen and provide edits to their submitted Project and Expenditure Reports any time before the reporting deadline. Recipients will then be required to re-certify and submit the report again to properly reflect any edits made.[2] Specific instructions for corrections and submissions can be found on page 7 of the Project and Expenditure Report User Guide.[3]
• Recovery Plan: Recipients will be allowed to reopen and update their submitted Recovery Plan report any time before the reporting deadline. Recipients should provide concurrent updates to the publicly posted version of any edited report.[4], [5]

The User Guide instructs recipients to follow the steps outlined above if a municipality deems a previously reported eligible expense to be ineligible. The User Guide states that “[r]ecipients can make corrections to reporting to adjust for ineligible uses, and must pay for that expense using non-SLFRF funding.”[6]

As a good practice, when amending information on a quarterly or annual report, municipalities should add a footnote, when the reporting template allows, indicating that the information has been amended from the previous report.