The U.S. Department of Treasury last week released new guidance on pre-award requirements, outlining immediate steps counties need to take to receive future direct payments from the U.S. Department of Treasury under the Coronavirus State and Local Fiscal Funds, part of the American Rescue Plan Act. By following these guidelines, counties will be better positioned to receive payments quickly and efficiently.

Update: According to the National Association of Counties (NACo), all Maryland counties have completed the U.S. Department of Treasury’s pre-award requirements.

As previously reported on Conduit Street, the State and Local Coronavirus Fiscal Recovery Funds legislation, part of the American Rescue Plan Act, was signed into law by President Biden on March 11. The bill includes $65.1 billion in direct, flexible aid to every county in America, as well as other crucial investments in local communities, including $1.5 billion over two years for public lands counties.

The U.S. Department of the Treasury will oversee and administer these payments to state and local governments, and every county is eligible to receive a direct allocation from Treasury. Municipalities and counties are slated to receive funds in two tranches – with 50 percent this year and the remaining 50 percent no earlier than 12 months from the first payment. The U.S. Treasury is required to pay the first tranche to counties not later than 60-days after enactment, and the second payment no earlier than 12 months after the first payment.

According to the U.S. Department of Treasury, state and local governments should take the following steps as soon as possible:

1. Ensure the entity has a valid DUNS number. A DUNS number is a unique nine-character number used to identify an organization and is issued by Dun & Bradstreet. The federal government uses the DUNS number to track how federal money is allocated. A DUNS number is required prior to registering with the SAM database, which is outlined below. Registering for a DUNS number is free of charge. If an entity does not have a valid DUNS number, please visit https://fedgov.dnb.com/webform/ or call 1-866-705-5711 to begin the registration process.
2. Ensure the entity has an active SAM registration. SAM is the official government-wide database to register with in order to do business with the U.S. government. All Federal financial assistance recipients must register on SAM.gov and renew their SAM registration annually to maintain an active status to be eligible to receive Federal financial assistance. There is no charge to register or maintain your entity SAM registration. If an entity does not have an active SAM registration, please visit, SAM.gov to begin the entity registration or renewal process. Please note that SAM registration can take up to three weeks; a delay in registering in SAM could impact the timely payment of funds.
   Click here for a quick overview of SAM registration
3. Gather the entity’s payment information, including:
   • Entity Identification Number (EIN), name, and contact information
   • Name and title of an authorized representative of the entity
   • Financial institution information (e.g., routing and account number, financial institution name, and contact information)

Program guidance for the Coronavirus State and Local Fiscal Recovery Fund will be released in the coming weeks.

Stay tuned to Conduit Street for more information.

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Previous Conduit Street Coverage: Details, Timetables Emerging on the American Rescue Plan