COVID-19 Federal Assistance e311


Compliance & Reporting

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 may edit or update information previously submitted to the U.S. Department of the Treasury (“Treasury”) with the next quarterly or annual report submission. Treasury’s Portal for Recipient Reporting State and Local Fiscal Recovery Funds User Guide (the “User Guide”) provides guidance on editing or updating reports already submitted. Specifically, it states:

  • 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.
  • Quarterly Project and Expenditure Reports: Updates should be provided in the next quarterly Project and Expenditure Report.
  • Annual Project and Expenditure Report: Recipients will have an opportunity to provide updates with the next quarterly submission date, when the portal opens for quarterly submitters. Additional information will be included in the forthcoming User Guide for the Project and Expenditure Report.
  • Recovery Plan: Recipients will be allowed to submit updates of their Recovery Plan reflecting any significant changes. They should also provide concurrent updates to the publicly posted version.[1], [2]

The User Guide also instructs recipients to follow the same steps outlined above if a municipality deems a previously reported eligible expense to be ineligible. Specifically, the User Guide states, “Recipients can make correction to reporting to adjust for ineligible uses, and must pay for that expense using non-SLFRF funding.”[3]

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.

Last Revised: November 17, 2021

[1] Department of the Treasury, “Treasury’s Portal for Recipient Reporting State and Local Fiscal Recovery Funds,” FAQ #1.11, at 29, available at:

[2] Id. See information regarding the deadlines for reporting under U.S. Department of the Treasury, “Compliance and Reporting Guidelines,” at 12.

[3] Id., at FAQ #3.1, at 31.