ARPA Funds Must be Obligated by Year End

The deadline by which municipalities must obligate remaining funds provided under the Coronavirus State and Local Fiscal Recovery Funds (“SLFRP”) program authorized by the American Rescue Plan Act (“ARPA”) is quickly encroaching.  As explained in a previous article, ARPA funds must be obligated by December 31, 2024, and expended by December 31, 2026.  Otherwise, such funds are required to be returned to the United States Department of Treasury (the “Treasury”).  In 31 CFR Part 35, the Treasury defines “obligation” as “an order placed for property and services and entering into contracts, subawards, and similar transactions that require payment.”  Additional SLFRP guidance provided by the Treasury has clarified that “obligation” includes certain interagency agreements and, in specific circumstances, personnel costs.

If you have any questions regarding the obligation of remaining ARPA funds by the December 31, 2024 deadline, please do not hesitate to contact one of our municipal attorneys.