What steps can municipalities that operate on a fiscal year take to accommodate current annual reporting benchmarks (based on the calendar year), and what is the possibility that regulations may change to allow for different year starts and ends?

Reports on the U.S. Department of the Treasury’s (“Treasury”) Coronavirus State and Local Fiscal Recovery Funds (“CSLFRF”) are due either annually or on calendar quarters. In particular, the Project and Expenditure Reports require key financial grant reporting information and are due either annually or quarterly based on calendar quarter ends, depending on recipient type.[1] Entities that submit annual Project and Expenditure reports are required to submit by April 30 of each year until 2027. Entities that submit quarterly Project and Expenditure reports are required to submit to Treasury within 30 calendar days after the end of each calendar quarter.

The following table summarizes all quarterly reporting timelines:[2]

Notably, Treasury’s Final Rule on CSLFRF allows recipients to calculate revenue loss based on a fiscal year or a calendar year as long as the recipient takes a consistent approach through the period of performance.[3]

A CSLFRF recipient should consider tracking its expenditures and obligations monthly to accommodate reporting benchmarks that differ from the recipient’s operating fiscal year. Monthly captures of financial and programmatic data allow recipients to generate reports for both their fiscal year and annual reports for Treasury more easily. Further, monthly tracking could provide the added benefit of providing more timely and useful financial information to management, who could use the information to produce financial statements that follow a calendar year or any other fiscal year-end and may prove helpful in completing CSLFRF reports for Treasury.