U.S. Treasury Releases ARPA Funding Guidance for Non-Entitlement Units of Local Government


  • Following recently released guidance for the American Rescue Plan Act’s (ARPA) Coronavirus State and Local Fiscal Recovery Fund, the U.S. Treasury releases allocation amounts for non-entitlement units of local governments (NEUs). 
  • $19.53 billion has been established to support more than 19,000 NEUs (cities with populations fewer than 50,000). 

City official standing at podium discussing American Rescue Plan Act (ARPA) funding for non-entitlement units of local government.

Earlier this week, the  U.S. Treasury Department released the American Rescue Plan Act (ARPA) allocation amounts for non-entitlement units of local governments (NEUs). More than 19,000 NEUs – cities and communities with a population fewer than 50,000 – will receive a total of $19.53 billion of funding.  

Funding Information

The U.S. Treasury established award amounts based on the size of the population of each NEU. ARPA payments for states, counties, metropolitan cities, and NEUs will be distributed in two tranches or segments. The first has already been set in motion, while the second is expected to be sent during the Spring/Summer of 2022.

According to the Treasury, here is the process for states to request, receive and distribute NEU funding:  

  1. Identify eligible NEUs following Treasury specified guidelines
  2. Request the funds directly from the federal government
  3. Calculate initial NEU allocation amounts
  4. Establish a process allowing NEUs to request funding
  5. Receive and process requests for NEU funding
  6. Determine if the “75 percent cap” applies (Interim Final Rule dictates that each NEU’s total amount cannot exceed 75 percent of its total operating budget for the year).
  7. Process any requests made by NEUs to decline the funds which will then be returned to the state. 

The state will then have 30 days to distribute the funds to NEUs after receiving them unless they apply for an extension. 

Non-Entitlement Unit of Local Government Checklist for Requesting Funds

While the above process mainly pertains to actions your state must take, the Treasury released a checklist to prepare NEUs to submit their request for the first tranche/payment. It includes information about preparing to request funding, requesting funding, and after submitting your funding request. 

  1. Preparing to Request Funding
    1. Obtain and confirm your local government’s DUNS number
    2. Gather and prepare payment information
    3. Confirm your annual total operating budget
    4. Review the Treasury provided award terms and conditions agreement
    5. Review the Treasury provided assurances of compliance with Title VI of the Civil Rights Act of 1964
  2. Requesting Funding
    1. Await instructions from your state, but have an authorized representative ready to sign the Treasury provided documents listed above
  3. After Submitting Your Funding Request
    1. Make sure to retain any documents and information you submitted with the request for your first report
    2. More information regarding reporting instructions and procedures are expected to follow

You can find the complete Nonentitlement Unit of Local Government Checklist for Requesting Initial Payment here

Additional Information and Links for States and NEUs

*Files and links above all sourced from U.S. Treasury Department


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