Large Counties’ Next ARPA Reporting is July 31: Here’s the Bottom Line

Larger counties need to report to the federal government by July 31 on their latest efforts with funds made available through the American Rescue Plan Act (ARPA) – NACo has assembled guidance for counties to stay in compliance.

The following materials were assembled by the National Association of Counties (NACo), who have been tirelessly working to guide and assist counties with all facets of federal fund deployment.

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Here is guidance for the third quarterly Project and Expenditure (P&E) Report, which is due July 31, 2022 for counties with population over 250,000.

Treasury released updated compliance and reporting guidance for counties ahead of the deadline that includes additional information that will be required as part of the reporting process and other clarifying items. Included below, you can find a comprehensive overview of updated compliance and reporting requirements, helpful information on specific sections of the reporting portal and an explanation of the difference between a subrecipient and beneficiary, and how counties can ensure they are complying with reporting requirements for these entities.

As a reminder, counties that are required to submit reports to Treasury by July 31, 2022, are those with populations above 250,000 residents and/or received $10 million or more in total ARPA Recovery Funds.

P&E Report Updates & Other Helpful Information

  • Revenue replacement: Counties had the option to make a one-time election to either calculate revenue loss according to Treasury’s formula outlined in the Final Rule OR elect a “Standard Allowance” of up to $10 million, not to exceed the award allocation. Treasury has decided to keep this portion of the reporting portal open for recipients in the upcoming P&E reporting cycle, which will allow counties to update their prior revenue loss election.
    • Once update, the prior revenue loss election will be replaced. Treasury expects to keep this portion of the reporting portal open through the April 2023 reporting period in order to provide an opportunity for annual reporters to take advantage of this flexibility.
  • Interested/principal received from loans: Any interest received on loans made with Recovery Funds should be tracked as program income in the P&E Report.
    • If a county uses revenue loss funds to fund a loan, repayments to loans are not subject to program income rules.
  • DUNS and UEI Numbers: As of April 2022, the federal government switched service providers and stopped using the DUNS number and began using the Unique Entity ID (UEI) – All counties are required to switch from a DUNS number to a UEI moving forward.
    • If your registration/DUNS number expired prior to April 2022, the county will be required to obtain a UEI before receiving its second tranche payment.
  • Population threshold: A county’s population threshold is determined by Treasury at the award date and will NOT change during the reporting period. You can find your county’s reporting tier here.
  • Edit and/or update previous report submissions: Counties can reopen and provide edits to submitted P&E Reports any time before the reporting deadline and will be required to re-certify the report to reflect any edits. After the reporting deadline, counties will be able to reflect changes in the next P&E Report.
  • Additional programmatic data for capital expenditures: When using Recovery Funds for capital expenditures projects, counties need to report the type of expenditure based on a list of enumerated uses. Examples of enumerated uses are COVID-19 vaccination sites, job and workforce training centers, and public health data systems. A full list of enumerated uses is available on pages 27 to 28 of the updated guidance.
  • Written justification for capital expenditures: Counties are required to provide a written justification for capital projects of any category that cost at least $10 million and for projects in the “other” (i.e., project not explicitly enumerated by Treasury) category that cost at least $1 million. Previously, counties needed to create a written justification for these projects but were not required to submit them as part of regular reporting.
  • Description of labor requirements for capital expenditures: Counties are required to provide additional labor reporting. For projects that cost at least $10 million, counties will need to report on the strength of the project’s labor standards, including information on the presence of a project labor agreement, community benefits agreement, prevailing wage requirement, or local hiring. This new required information is outlined under Infrastructure Project on pages 30-31 of the updated guidance.
  • Project information for broadband projects: The updated guidance requires counties to provide detailed project information for broadband infrastructure investments. Counties need to report what kind of technology is involved in the project (i.e., fiber optic cables, coaxial cables, etc.), the total miles of fiber deployed over the project, and the total number of funded locations served broken out by both speed of connection and type of location (i.e., residential, business, or community). This new required information is outlined under Broadband Projects on pages 32-33 of the updated guidance.
  • Moving of Recovery Plan Performance Report data into P&E Report: Under the updated guidance, some of the data that was previously only required for the Recovery Plan Performance Report (Recovery Plan) is now required for large counties (i.e., populations above 250,000 and/or above $10 million in awards) on their quarterly P&E Report. For example, large counties investing in housing security programs must now report the number of households receiving eviction prevention services. A full list of changes to programmatic data requirements for large counties is available on page 33 of the compliance and reporting guidance.
  • Updated template for Recovery Plan: The updated guidance also provides a template for the Recovery Plan due for large counties on July 31, 2022, reflecting the expenditure categories and other changes made by the Final Rule.

Overview of Subrecipients vs. Beneficiaries – Definitions and Reporting Requirements

The distinction between a subrecipient and beneficiary is contingent upon the rationale for why a recipient is providing funds to the individual or entity.


  • Subrecipient: An entity that receives a subaward to carry out a project funded by Recovery Funds on behalf of the recipient (i.e. county).
    • If a county is providing funds to the individual or entity for the purpose of carrying out an SLFRF-funded program or project on behalf of the county, the individual or entity is acting as a subrecipient.
  • Beneficiary: If a county is providing funds to the individual or entity for the purpose of directly benefitting the individual or entity as a result of experiencing a public health impact or negative economic impact of the pandemic, the individual or entity is acting as a beneficiary.
    • Individuals or entities that experienced the negative economic impact and are the recipients of a project funded by Recovery Funds. In other words, the households, small businesses, nonprofits, or impacted industries that experienced the negative economic impact.

Reporting requirements

  • Subrecipients: All subrecipients are required to comply with all requirements of recipients such as treatment of eligible uses of funds, procurement and reporting requirements.
    • Subrecipients are required to have an active registration and UEI number OR Taxpayer Identification Number (TIN), if unable to obtain a UEI
  • Beneficiary: A beneficiary are not subject to subrecipient monitoring and reporting requirements.
    • Beneficiaries are NOT required to register in and are not required to provide a UEI


NACo contact for more details:

Eryn Hurley
Director of Government Affairs
National Association of Counties

Michael Sanderson

Executive Director Maryland Association of Counties