RECENT NEWS AND UPDATES
January 6, 2022
• U.S. Treasury releases the Final Rule for the State and Local Fiscal Recovery Funds (SLFRF) program. The Final Rule will take effect on April 1, 2022. View the Final Rule here and an Overview of the Final Rule here. To view more on the Coronavirus State and Local Fiscal Recovery Funds Final Rule, visit the U.S. Department of Treasury’s website.
October 1, 2021
• U.S. Treasury revises timeline for counties to submit their Project and Expenditure Reports for the Fiscal Recovery Fund (original deadline was October 31, 2021) to January 31, 2022. The Project and Expenditure Reports will now be due on January 31, 2022 and will cover the period between award date and December 31, 2021. This is a change from the previously communicated October 31, 2021 due date for the Project and Expenditure Report. Further instructions will be provided at a later date, including updates to existing guidance as well as a user guide to assist recipients to gather and submit the information through Treasury’s Portal. Please visit the Treasury’s website for the latest information.
September 20, 2021
• The U.S. Treasury released new guidance for the $10 billion Capital Projects Fund that was authorized under the American Rescue Plan. It is important to note that these are grants for states, which can then be awarded to subrecipients (I.e. counties). To view the Capital Projects Funds by State see here.
August 25, 2021
• The U.S. Treasury released a recorded presentation providing a walkthrough of the reporting portal covering both upcoming reports. This includes the one-time Interim Report, which all counties are required to submit to the U.S. Treasury AND the Recovery Plan Performance Report, which counties with populations above 250,000 residents are required to submit to the U.S. Treasury.
• The U.S. Treasury has released a number of other webinars covering targeted topics related to the Recovery Fund and have notified us that they will continue to offer such assistance in the future. The webinars can be found here.
• Counties must refer to the Compliance and Reporting Guidance as well as the User Guide for a complete understanding of the information they are required to submit.
A Message from FAC President Ralph Thomas
Welcome to the Florida Association of Counties' American Rescue Plan resource website. On March 11, 2021, the American Rescue Plan Act was signed into law. Within the package, the Coronavirus State and Local Fiscal Recovery Fund contains approximately $350 billion in federal assistance for our states, territories, tribes, counties, and municipalities. $65.1 billion is allocated for direct funding to all counties.
The Florida Association of Counties along with our partners, the National Association of Counties, advocated for this relief package by calling on Congressional Leadership and Florida’s Congressional Delegation to act swiftly in approving direct funding to counties to assist in the recovery efforts due to this pandemic. Please use this website as a resource for your county as you navigate the details and seek information regarding the American Rescue Plan.
I want to thank each of you for letting your voices be heard loud and clear – counties are on the frontlines every day within our communities fighting this pandemic and it is local governments that are leading the recovery efforts. United we stand as the county family and I am more optimistic than ever that together we will continue to rise to meet the challenges of this pandemic and that we will overcome it. I am humbled by your resilience and perseverance and it is my honor to serve alongside each of you.
The Florida Association of Counties along with our partners, the National Association of Counties, advocated for this relief package by calling on Congressional Leadership and Florida’s Congressional Delegation to act swiftly in approving direct funding to counties to assist in the recovery efforts due to this pandemic. Please use this website as a resource for your county as you navigate the details and seek information regarding the American Rescue Plan.
I want to thank each of you for letting your voices be heard loud and clear – counties are on the frontlines every day within our communities fighting this pandemic and it is local governments that are leading the recovery efforts. United we stand as the county family and I am more optimistic than ever that together we will continue to rise to meet the challenges of this pandemic and that we will overcome it. I am humbled by your resilience and perseverance and it is my honor to serve alongside each of you.
THE DETAILS OF THE CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUND
As outlined in the Coronavirus State and Local Fiscal Recovery Fund, a total of $350 billion will be split among states, territories, tribes, counties, and municipalities; $10 billion for coronavirus capital projects; and $1.5 billion over two years for revenue sharing counties, public lands counties.
Of the $350 billion, local governments would receive $130.2 billion, split evenly between counties and municipalities. Counties will receive a direct federal allocation of $65.1 billion based on county share of the U.S. population. Note that counties that are CDBG recipients would receive the larger share, based on population or calculated under the CBDG allocation method. Cities and municipalities will receive their own sum of money of $65.1 billion, these funds are separate from county funds.
WHAT TO EXPECT IN FLORIDA?
As passed, Florida counties will receive approximately $4.2 billion in direct federal aid. Below, is the complete list of allocations county-by-county. To view the allocation methodology for counties, click here.
COUNTIES: REQUEST FUNDS TODAY
Counties are now able to request funding through the US Treasury Portal. To access the portal and apply for funds, click here. Prior to requesting Recovery Funds, counties should complete the following:
Ensure your county has a DUNS number
Ensure your county has an active SAM registration
Gather necessary payment information*
*Entity Identification Number (EIN), name and contact information; Name and title of an authorized representative of the county (I.e., chief elected official); Financial institution information (e.g., routing and account number, financial institution name and contact information)
The funds will be distributed in two allocations. The U.S. Treasury will be required to pay counties the first allocation (50%) no later than 60 days after enactment. The second allocation (50%) will be distributed no earlier than 12 months after the first payment.
If you are having issues with the new U.S. Treasury portal, please email covidrelieffitsupport@treasury.gov.
The funds will be distributed in two allocations. The U.S. Treasury will be required to pay counties the first allocation (50%) no later than 60 days after enactment. The second allocation (50%) will be distributed no earlier than 12 months after the first payment.
If you are having issues with the new U.S. Treasury portal, please email covidrelieffitsupport@treasury.gov.
Uses of Funds
Support the Public Health Response
The funding may be used to meet and address emergent public health needs.
• COVID-19 Mitigation & Containment: A broad range of services and programming that are needed to contain COVID-19
• Medical Expenses: Provide care and services to address COVID-19 public health needs, risks presented by new variants, and long-term effects of the virus
• Behavioral Healthcare: New or enhanced state and local government services that may be needed to meet mental health, substance use, and other behavioral needs
• Public Health & Safety Staff: Responding to the public health and negative economic impacts of the pandemic requires a substantial commitment of human resources
Address Negative Economic Impacts
Recipients may use these funds to respond to the negative economic impacts of the COVID-19 public health emergency.
• Workers and Families: Assistance to unemployed workers and job training; Food, housing, cash and other assistance to households; Survivor’s benefits for family members of COVID-19 victims
• Small Businesses: Loans and grants to mitigate financial hardship; Loans, grants, and in-kind assistance to implement COVID-19 prevention or mitigation tactics; Technical Assistance
• Public Sector: Rehire Staff; Replenish state unemployment insurance funds; Administer economic relief programs
• Impacted Industries: Tourism, travel, and hospitality sectors; Other similarly affected sectors
Provide Equity-Focused Services
Treasury will presume the following additional activities are eligible uses when provided within disproportionally impacted communities.
• Addressing Health Disparities: Community health workers and public benefits navigators; Remediation of lead paint and other lead hazards; Community violence intervention programs
• Investing in Housing & Neighborhoods: Services to support individuals experiencing homelessness; Affordable housing development; Housing vouchers, residential counseling, navigation assistance
• Addressing Educational Disparities: New or expanded early learning services; Expanded resources for high-poverty school districts; Educational services like tutoring and afterschool programs, as well as supports for social, emotional, and mental health needs
• Promoting Healthy childhood Environments: New or expanded high quality childcare; Home visiting programs for families with young children; Services for child welfare-involved families and foster youth
Replace Public Sector Revenue Loss
Recipients may use this funding to provide government services to the extent of the reduction in revenue experienced due to the COVID-19 public health emergency.
• Provide continuity of vital government services by filling budget shortfalls
• Revenue loss is calculated relative to the expected trend, beginning with the last fiscal year pre-pandemic and adjusted annually for growth
• Recipients may re-calculate revenue loss at multiple points during the program, supporting those entities that experience revenue loss with a lag
• Once a reduction in revenue is identified recipients have broad latitude to use the funds to support government services, (with some exceptions, described later)
The Interim Final Rule establishes a clear and consistent methodology that each recipient can use to calculate its reduction in revenue.
Premium Pay for Essential Employees
Recipients may use this funding to provide premium pay to eligible workers performing essential work, either in public sector roles or through grants to third party employers.
• Essential work involves regular in-person interactions or physical handling of items that were also handled by others
• Recipients have discretion to designate additional sectors
• Examples of professions eligible for premium pay: Staff at nursing homes, hospitals, and home-care settings; Workers at farms, food production facilities, grocery stores, and restaurants; Janitors and sanitation workers; Truck Drivers, transit staff, and warehouse workers; Public health and safety staff; Childcare workers, educators, and school staff; Social service and human services staff
Premium pay should prioritize low- and moderate-income workers, who face the greatest mismatch between employment-related health risks and compensation.
Water, Sewer, and Broadband Infrastructure
Recipients may use these funds to make necessary investments in water, sewer, and broadband infrastructure.
• Water and Sewer infrastructure: Includes improvements to infrastructure, such as buildings or upgrading facilities and transmission, distribution, and storage systems; Eligible uses aligned to Environmental Protection Agency project categories across the Clean Water State Revolving Fund and Drinking Water State Revolving Fund
For project eligibility please view the CWSRF and DWSRF webpages: Clean Water State Revolving Fund Drinking Water State Revolving Fund
• Broadband Infrastructure: Focus on households and businesses without a wireline connection capable of reliably delivering 25 Mbps download/ 3 Mbps upload; Fund projects that deliver reliable service (minimum 100 Mbps download/100 Mbps upload speeds unless impracticable); Complement broadband investments made through the separate Capital Projects Fund
Ineligible Use of Funds
While recipients have considerable flexibility to use this funding to address the diverse needs of their communities, restrictions on use apply.
• Net Reduction in Tax Revenue: The American Rescue Plan may not be used to fund reductions in the net tax revenue; If a state or territory has a reduction in net tax revenue, they must demonstrate how they paid for the tax cuts from sources other than Coronavirus State Fiscal Recovery Funds – by enacting policies to raise other sources of revenue, by cutting spending, or through higher revenue due to economic growth
• Deposits into Pension Funds: This funding may not be used for deposits into pension funds; A “deposit” is defined as an extraordinary contribution to a pension fund for the purposes of reducing an accrued, unfunded liability; Recipients may use funds for routine payroll contributions to pensions of employees whose wages and salaries are an eligible use
• Other Restrictions on Use: Funding debt service, legal settlements or judgements; Deposits to rainy day funds or financial reserves; Additional restrictions may apply
US TREASURY TIMELINE AND KEY DATES
All funds will be distributed to local governments through the U.S. Department of Treasury. Please note, counties can use the Recovery Funds to cover costs incurred beginning on March 3, 2021. The deadline to oblige funds allocated through the Act will be on December 31, 2024. Lastly, all funds must be spent and projects completed by December 31, 2026.
INTERIM FINAL RULE REPORT
Funding will be subject to requirements under the Interim Final Rule. Please note, Treasury is seeking comments on the Interim Final Rule by July 16, 2021. We are encouraging counties to submit comments electronically via the Federal eRulemaking Portal at Regulations.gov by clicking the “comment” button on the upper left side of the website. All comments are public records and can be viewed by clicking “browse comments.”
Public Comments
Hillsborough County
June 14, 2021
The Interim Final Rule states the following:
Under 602( c )(1)(C) or 603( c )(1)( c ), a general infrastructure project typically would not be considered a response to the public health emergency and its negative economic impacts unless the project responds to a specific pandemic-related public health need(e.g., investment in facilities for the delivery of vaccines) or a specific negative economic impact of the pandemic (e.g., affordable housing in a Qualified Census Tract).
Hillsborough County, Florida requests that Community Centers and Parks Facilities in Qualified Census Tracts be included as allowable infrastructure uses in Category A. Specifically, page 41 of the Interim Final Rule states “Treasury encourages recipients to consider funding uses that foster a strong, inclusive, and equitable recovery, especially uses with long-term benefits for health and economic outcomes.” Services provided at these facilities are clearly aligned with this objective.
The Interim Final Rule states the following:
Under 602( c )(1)(C) or 603( c )(1)( c ), a general infrastructure project typically would not be considered a response to the public health emergency and its negative economic impacts unless the project responds to a specific pandemic-related public health need(e.g., investment in facilities for the delivery of vaccines) or a specific negative economic impact of the pandemic (e.g., affordable housing in a Qualified Census Tract).
Hillsborough County, Florida requests that Community Centers and Parks Facilities in Qualified Census Tracts be included as allowable infrastructure uses in Category A. Specifically, page 41 of the Interim Final Rule states “Treasury encourages recipients to consider funding uses that foster a strong, inclusive, and equitable recovery, especially uses with long-term benefits for health and economic outcomes.” Services provided at these facilities are clearly aligned with this objective.
Lake County
July 9, 2021
The additional FAQs released from Treasury on June 24th explained under Question 2.18 that investments in improving outdoor spaces (e.g. parks) is an eligible use if provided in a Qualified Census Tracts (QCTs) or populations, households, or geographic areas disproportionately impacted by the pandemic.
How will a disproportionately affected community or area be defined? Would a LMI Census Tract or a Community Redevelopment Area (CRA) qualify?
The additional FAQs released from Treasury on June 24th explained under Question 2.18 that investments in improving outdoor spaces (e.g. parks) is an eligible use if provided in a Qualified Census Tracts (QCTs) or populations, households, or geographic areas disproportionately impacted by the pandemic.
How will a disproportionately affected community or area be defined? Would a LMI Census Tract or a Community Redevelopment Area (CRA) qualify?
Polk County
Sarasota County
St. Lucie County
Sumter County
Sumter County would like to submit the following questions regarding the American Rescue Plan:
1. Would the enhancement/expansion of a public safety communications system qualify as an eligible project for technology infrastructure investment? This is a first responder/911 system.
2. Are renewable energy projects that are not water, sewer or broadband eligible for funding? The design and installation of a solar array field to power the courthouse.
1. Would the enhancement/expansion of a public safety communications system qualify as an eligible project for technology infrastructure investment? This is a first responder/911 system.
2. Are renewable energy projects that are not water, sewer or broadband eligible for funding? The design and installation of a solar array field to power the courthouse.
Volusia County
Walton County
June 16, 2021
In the calculation of revenue loss, it would be more accurate if cities and counties were allowed to exclude revenues included in calendar year 2020 that are not in base year 2019. Also, comparing fiscal year 2019 to calendar year 2020 creates inaccuracies in reporting. A portion of the calendar year 2020 revenues are for fiscal year 2021, making the counterfactual revenue calculation inaccurate since the calculation in effect skips 1/4 to 1/2 of the 2020 fiscal year for cities and counties.
In the calculation of revenue loss, it would be more accurate if cities and counties were allowed to exclude revenues included in calendar year 2020 that are not in base year 2019. Also, comparing fiscal year 2019 to calendar year 2020 creates inaccuracies in reporting. A portion of the calendar year 2020 revenues are for fiscal year 2021, making the counterfactual revenue calculation inaccurate since the calculation in effect skips 1/4 to 1/2 of the 2020 fiscal year for cities and counties.
REPORTING REQUIREMENTS
Recovery Fund recipients will be required to submit an interim report, quarterly report, quarterly project and expenditure reports and annual recovery plan:
Interim Reports: Counties are required to submit one interim report, including the county’s expenditures by category at the summary level. The report will cover spending from the date the county receives Recovery Funds to July 31, 2021. Interim Reports are due by August 31, 2021.
Quarterly project and expenditure reports: Counties will be required to submit quarterly project and expenditure reports, including financial data, information on contracts and subawards over $50,000 and other information regarding utilization of funds. These reports will be similar to CARES Act Coronavirus Relief Fund. The first report will cover spending from the date the county receives Recovery Funds to September 30, 2021. First report is due by October 31, 2021.
Recovery plan performance reports: Counties will be required to submit an annual recovery plan performance report, including descriptions of projects funded and information on performance indicators and objectives of each award. Initial recovery plan will cover activity from the date the county receives Recovery Funds to July 31, 2021. Local governments with less than 250,000 residents are not required to develop Recovery Plan Performance Report. However, local governments greater than 250,000 residents are required to develop a Recovery Plan Performance Report. Recovery plan is due by August 31, 2021.
SOME ADDITIONAL FUNDS OF INTERESTS
Local Assistance and Tribal Consistency Fund
$2 billion fund that will give $750 million to eligible revenue sharing counties and $250 million to eligible Tribes for any government purpose other than lobbying, to be obligated in 2022 and 2023.
Vaccine Distribution
$20 billion to establish a National COVID-19 Vaccination Program, $7.5 billion will be allocated to the CDC to support state and local public health departments and community health centers. An additional $7.5 billion will be given to FEMA to establish vaccination sites.
COVID-19 Testing and Contact Tracing
$47.8 billion to the Department of Health and Human Services (HHS) to support state and local departments with COVID-19 testing, PPE, contact tracing, and expanding the public health workforce.
Coronavirus Capital Projects Fund
$10 billion fund that will give $100 million to each state to fund “critical capital projects directly enabling work, education, and health monitoring, including remote options, in response to the public health emergency with respect to the Coronavirus Disease.” Note, this funding includes broadband infrastructure. Treasury will begin to accept applications for review in the summer of 2021 and will issue guidance before that date for eligible applicants.
Medicaid Support
Enhances state Federal Medical Assistance Percentages (FMAP), the federal contribution to Medicaid, such as: 100% FMAP for states that opt to provide coverage to the uninsured COVID-19 vaccines and treatment without cost sharing; Enhancing FMAP for states that want to expand Medicaid program for mental health and substance abuse disorders; Increasing that state’s base FMAP by 5% points for 2 years if they expand Medicaid.
Emergency Rental Assistance
$21.6 billion of direct federal funding will be allocated to counties with a population greater than 200,000. Counties below 200,000 are eligible to receive funds through their state government. This Emergency Rental Assistance is additional funding, separate from the Emergency Rental Assistance Program under the Consolidated Appropriations Act passed in December. Provides $100 million for rural housing through the U.S. Department of Agriculture.
Other funds include, but are not limited to, funding for mental health, affordable housing, food and nutrition assistance, unemployment benefits, education and childcare assistance, small businesses, public transportation, and individual assistance. To see the full list of funding and programs, please visit NACo’s Recovery Clearinghouse and the U.S. Treasury’s Main Landing Page.
ADDITIONAL RESOURCES
All Interim Rule resources superseded by the final rule released on January 6, 2022.
Share Your Story
Tell us how your county is responding the COVID-19 pandemic and driving recovery in your community! Use the given form to share how your county is using federal relief funds.