ProgramCOVID-19 Federal Assistance e311
TopicsProgram Administration, Timing of Funds
What is the timeframe between receiving CLERF funds and using them for staff and consultant expenses for ARP administration?
Technical assistance for mitigation of COVID-19-related threats is considered a general eligible use under the Final Rule for the American Rescue Plan Act of 2021 (“ARP”) Coronavirus State and Local Fiscal Recovery Funds (“CSLFRF”). CSLFRF funds may therefore be applied, on a backdated basis, to eligible staff time and technical assistance beginning March 3, 2021. Treasury has also issued Compliance and Reporting Guidance that states that “recipients may use funds for administering the [CSLFRF] program, including costs of consultants to support effective management and oversight, including consultation for ensuring compliance with legal, regulatory, and other requirements.” Consultant expenses for ARP administration, such as staff salaries and technical assistance, could be applied for the entire covered period. The covered period for the CSLFRF under ARP began on March 3, 2021, and funds will remain available for obligation through December 31, 2024. Treasury requires the return of funds not obligated by December 31, 2024 or expended by December 31, 2026.
Last Revised: March 31, 2022
 Department of Treasury, “Compliance and Reporting Guidance,” at 8, available at: https://home.treasury.gov/system/files/136/SLFRF-Compliance-and-Reporting-Guidance.pdf.
 Treas. Reg. 31 CFR 35 at 414, available at: https://home.treasury.gov/system/files/136/SLFRF-Final-Rule.pdf.