When reporting CSLFRF expenditures, how should municipalities approach small projects that do not meet the $10 million threshold?

The U.S. Department of the Treasury’s (“Treasury”) Portal for Recipient Reporting: State and Local Fiscal Recovery Funds^[1] does not distinguish between small or large Coronavirus State and Local Fiscal Recovery Funds (“CSLFRF”) projects. Rather, after project and subaward information is entered into the system, recipients report expenditures under two categories: “Expenditures Greater than $50,000” and “Expenditures Less than $50,000.”[2]

The $10 million threshold is specific to projects with capital expenditures or infrastructure projects greater than $10 million. If projects do not meet these criteria, recipients are not required to respond to those specific programmatic compliance questions as outlined in Treasury’s Compliance and Reporting Guidance.[3] However, project data are still required to be entered into the portal for the project and other programmatic requirements may exist depending on the expenditure category of the project.

In general, recipients of CSLFRF Funds must report quarterly on the use of the funds.[4] For small projects that do not exceed ten million dollars in cost, recipients can likely use a simplified reporting method. Regardless of whether the simplified reporting method is used, the municipality must still report the following information for each small project:

• The name of the project;
• Project identification number;
• Project expenditure category;
• A brief description of the project;
• The total cost of the project; and
• The project’s status.[5]

In addition, the municipality must also report any sub-recipient or contractor information for each small project that was used to expend the funds.[6]