COVID-19 Federal Assistance e311


Federal Funding Streams, Fund Planning & Allocation

Funding Source

American Rescue Plan Act, CARES Act, FEMA, HUD, Infrastructure Investments and Jobs Act

What options are available to my municipality to secure matching funds if they are not currently available in our municipality’s existing budget?

Municipalities should first ensure that their budgeting capacity is sufficiently established. A robust budgeting system will allow for efficient resource allocation and accurate financial planning.

Given the importance of large-scale asset procurement and long-term projects, establishing a Capital Improvement Plan (“CIP”) to address all capital funding needs for a period of at least five years is imperative. Accurate planning allows a municipality to provide an organizational vision and establish targets during budget cycles. In addition to the CIP, a municipality should maintain an agreed-upon funding needs list and strategy to address programmatic and funding needs.

Advanced and documented planning efforts will help facilitate the creation of a detailed budget that considers potential matching fund needs. To the extent possible, any team members who work on grant funded projects and programs should be involved early in the process, as effectively harnessing the collective knowledge of the team will reduce gaps in identifying matching needs.  

Municipalities should develop and keep an inventory of potential funding streams that may be utilized alongside additional braided or blended funding sources to serve as potential matches.[1]

Within the realm of stakeholder engagement, municipalities may also look to external stakeholders in their jurisdictions for funding opportunities or partnerships. Leveraging existing external relationships can also help municipalities gain a deeper understanding of funding streams, community projects, and generalized grant funding pursuits in their regions.

Furthermore, municipal leadership and officials should stay engaged with the larger community of public administrators. Membership and involvement in organizations that represent governments and/or government officials, such as the National Association of Counties or the United States Conference of Mayors, can be a valuable resource for local leaders. These organizations often provide a host of resources to members, including education on new and emerging funding opportunities.

Finally, funding under the American Rescue Plan Act (“ARP”), insofar as it is available, should be evaluated for potential utilization as non-federal matching funds. Although ARP funding is federal, the U.S. Department of the Treasury’s (“Treasury”) Final Rule on the Coronavirus State and Local Fiscal Recovery Funds (“CSLFRF”) states that, for funding categorized as “revenue loss”:

the funds available under sections 602(c)(1)(C) and 603(c)(1)(C) of the Social Security Act for the provision of government services, up to the amount of the recipient’s reduction in revenue due to the public health emergency, generally may be used to meet the non-federal cost-share or matching requirements of other federal programs.[2]

Treasury has also enumerated ineligible uses of CSLFRF funds to serve as non-federal match:

[C]SLFRF funds may not be used as the non-federal share for purposes of a state’s Medicaid and CHIP programs because the Office of Management and Budget has approved a waiver as requested by the Centers for Medicare & Medicaid Services pursuant to 2 CFR 200.102 of the Uniform Guidance and related regulations.[3]

Municipalities should further evaluate the Final Rule for all inquiries regarding match eligibility, including inquiries related to blending and/or braiding funds.[4]

Finally, municipalities can evaluate in-kind resources such as undevelopable land or other capital structures that can be liquidated to use as match leverage to maximize awards. Municipalities may also consider developing an indirect cost rate or formal election of a de minimis rate, the waiver of which may serve as a match for other federal funding streams.

Last Updated: July 8, 2022

[1] AGA, “Blended and Braided Funding: A Guide for Policy Makers and Practitioners,” December 2014, at 17-18, available at:

[2] Treas. Reg. 31 CFR Part 35 at 368, available at:

[3] Id., at 369.

[4] Coronavirus State and Local Fiscal Recovery Funds, Frequently Asked Questions (as of April 27, 2022) – FAQ #4.8, at 30-31, available at: