Centralina Learns: Managing ARPA Allocations Under $10 Million

Centralina Regional Council held a Centralina Learns session on Wednesday, August 17 about American Rescue Plan Act (ARPA) spending for allocations under $10 million. We had a great turnout and participation as our session provided an overview of the updated guidance the U.S. Treasury released on July 27 as well as considerations for spending approaches and following good governance. If you missed the session, here are six points that you need to know:

  1. The updated guidance released from the U.S. Treasury on July 27 is only relevant if your community elected “Revenue Loss” as your ARPA spending category. This includes if you are spending the funds on salaries and benefits and/or other general government services. This guidance is also relevant if your community is planning on spending the funds on equipment/infrastructure under the revenue loss category.
  2. Under this new guidance recipients may update their Revenue Loss election, in future reporting cycles through the April 2023 reporting period (US Treasury Final Rule FAQ 3.1)
  3. If you’re considering changing your spending within the Revenue Loss category, you should keep in mind your jurisdiction’s staff capacity as you would need to amend your grant project ordinance and follow procurement protocols for this change. This could be strategic if for some reason your community needs funds quicker however, you should always have a backup plan for various scenarios (i.e., if your equipment is backlogged, if the infrastructure project fails or if someone quits)
  4. There are no subawards required under the Revenue Loss category (FAQ 13.15) and excluded from some requirements in Uniform Guidance – Procurement (FAQ 13.15)
  5. If you chose Revenue Loss: Salaries and Benefits, Centralina still recommends this category as it has the least number of requirements.
  6. Regardless of how your community chose to spend the funds it’s important to practice good governance by following all state and federal procurement protocols, increasing transparency, communication and engagement with your citizens

Remember, Centralina is here to help! We provide services for all members including but not limited to: strategic planning, community engagement and outreach, document review and monitoring and reporting.

You can watch the entire Centralina Learns session for more information on this topic. Look under the COVID section of our Member Portal.

Federal funds are commonly passed through state agencies in North Carolina before being awarded to local governments, which can make the original funding source less obvious. Before proceeding with a procurement, local governments should verify whether an award originates from a federal source. This determination affects compliance obligations, including procurement standards, reporting, and audit requirements.

When a construction or repair contract over $300,000 involves a building, the procurement and contract are subject to additional requirements under N.C.G.S. 143-128. Therefore, this question must be answered to determine whether the additional statutory requirements apply to this procurement scenario.

The micro-purchase threshold is a federal procurement threshold under which competitive procurement is not required. The default micro-purchase threshold is $15,000, but local governments may increase the micro-purchase threshold up to $50,000. An explanation of increasing the micro-purchase threshold and a template for the required annual self-certification is available here.