Program

COVID-19 Federal Assistance e311

Topics

Program Administration

Funding Source

American Rescue Plan Act

In the Project & Expenditure Report, where do cities report administrative costs, such as Finance Department costs? Should we create an administration project?

In short, administrative costs should typically be reported under the expenditure category of the associated project. General administrative costs that are not associated with a particular project should be reported under “Expenditure Category 7.1 - Administrative Expenses” as part of its baseline template.

Municipalities should track administrative obligations and expenditures for reporting purposes. In most cases, municipalities need not create a separate administrative project. Typically, municipalities should report administrative expenses that are tied to a specific project as part of the overall project under the appropriate expenditure category for that project.

On January 7, 2022, the U.S. Department of the Treasury (“Treasury”) released the Project and Expenditure Report User Guide (“User Guide”) for the Coronavirus State and Local Fiscal Recovery Funds (“CSLFRF”).[1] This document provides detailed instructions to help recipients provide the following information:

  • project data;
  • subrecipient data;
  • subaward data;
  • expenditure data; and
  • project and expenditure bulk upload templates.[2]

The Project and Expenditure Report provides information on projects funded, expenditures, contracts and sub-awards over $50,000, and other information required from recipients.[3] Treasury allows a bulk file upload process.[4] According to section (h) of the User Guide, recipients may use the Expenditure Reporting module to enter data manually or leverage the bulk file upload capability.[5] Recipients who do not use the bulk upload function must follow certain steps, including entering a narrative for administrative costs.[6] For further reference, there are six (6) bulk file upload templates that can be submitted to the CSLFRF Treasury Portal.[7]

Municipalities’ approaches will differ where administrative expenses are not affiliated with a specific project. The Project Baseline Template provided by Treasury applies Expenditure Category 7.1 to administrative costs for general expenditures (as opposed to those tied to specific projects).[8] In other words, municipalities must include administrative costs not associated with individual projects (and which are thus attributable to Expenditure Category 7.1) on the baseline template.

For reference, FAQ #3.2 from the CSLFRF Treasury Portal Recipient Reporting User Guide provides further information on using Expenditure Category 7.1 for a project’s administrative costs:

Administrative costs for a specific project should be reported under the appropriate expenditure category for that project. For example, administrative costs for a small business economic assistance program would be reported under EC 2.9- Small Business Economic Assistance (General). Only general SLFRF administrative costs which are not associated with a particular project and do not fall into another Expenditure Category should be reported under EC 7.1- Administrative Expenses. EC 7.1 may include both direct and indirect costs.[9]

Last Updated: February 3, 2022

[1] Coronavirus State and Local Fiscal Recovery Funds, Project and Expenditure Report User Guide (as of January 7, 2022), available at: https://home.treasury.gov/system/files/136/Project-and-Expenditure-Report-User-Guide.pdf.

[2] Id., at 1.

[3] Id., at 14.

[4] Id., at 4.

[5] Id., at 35.

[6] Id.

[7] Coronavirus State and Local Fiscal Recovery Fund: User Guide: Treasury’s Portal for Recipient Reporting, Appendix A – Bulk File Upload Overview, available at: https://home.treasury.gov/system/files/136/SLFRF_Treasury-Portal-Recipient-Reporting-User-Guide.pdf.

Coronavirus State and Local Fiscal Recovery Funds, Project and Expenditure Report User Guide (as of January 7, 2022), at 48, 53, available at: https://home.treasury.gov/system/files/136/Project-and-Expenditure-Report-User-Guide.pdf.

[8] Id., at 53.

[9] Treasury’s Portal for Recipient Reporting, State and Local Fiscal Recovery Funds, at 33, available at: https://home.treasury.gov/system/files/136/SLFRF_Treasury-Portal-Recipient-Reporting-User-Guide.pdf.