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Fund Planning & Allocation

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]

Report

Year

Quarter

Period Covered

Due Date

1

2021

2-4

March 3 – December 31

January 31, 2022

2

2022

1

January 1 – March 31

April 30, 2022

3

2022

2

April 1 – June 30

July 31, 2022

4

2022

3

July 1 – September 30

October 31, 2022

5

2022

4

October 1 – December 31

January 31, 2023

6

2023

1

January 1 – March 31

April 30, 2023

7

2023

2

April 1 – June 30

July 31, 2023

8

2023

3

July 1 – September 30

October 31, 2023

9

2023

4

October 1 – December 31

January 31, 2024

10

2024

1

January 1 – March 31

April 30, 2024

11

2024

2

April 1 – June 30

July 31, 2024

12

2024

3

July 1 – September 30

October 31, 2024

13

2024

4

October 1 – December 31

January 31, 2025

14

2025

1

January 1 – March 31

April 30, 2025

15

2025

2

April 1 – June 30

July 31, 2025

16

2025

3

July 1 – September 30

October 31, 2025

17

2025

4

October 1 – December 31

January 31, 2026

18

2026

1

January 1 – March 31

April 30, 2026

19

2026

2

April 1 – June 30

July 31, 2026

20

2026

3

July 1 – September 30

October 31, 2026

21

2026

4

October 1 – December 31

March 31, 2027

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.

Last Revised: March 31, 2022

[1] Department of Treasury, “Coronavirus State and Local Fiscal Recovery Funds—Compliance and Reporting Guidance,” Version, 3.0, February 28, 2022, at 14-19 available at: https://home.treasury.gov/system/files/136/SLFRF-Compliance-and-Reporting-Guidance.pdf.

[2] Id., at 18.

[3] Treas. Reg. 31 CFR 35 at 249, available at: https://home.treasury.gov/system/files/136/SLFRF-Final-Rule.pdf.