American Rescue Plan reporting deadline for many state and local governments is Jan. 31

The American Rescue Plan Act of 2021 (ARP) Final Rule establishes a staggered reporting schedule based on entity type. If your state or local government entity falls into one of the following categories, your first Project and Expenditure (P&E) report is due by Jan. 31, 2022.

• States and U.S. territories
• Tribal governments that received more than $30 million in Coronavirus State and Local Fiscal Recovery Funds (SLFRF) funding
• Metropolitan cities and counties with a population that exceeds 250,000 residents
• Metropolitan cities and counties with a population below 250,000 residents that were allocated more than $10 million in SLFRF funding

NOTE: lesser populated cities and counties have until April 30, 2022 to submit their first P&E report.

This report will address obligations and expenditures that occurred from March 3, 2021 to Dec. 31, 2021. Subsequent P&E reports will cover one calendar quarter and be submitted within 30 calendar days of the end of each calendar quarter. The final P&E report will be due on March 31, 2027.

Governmental entities not described above are required to submit the first P&E report by April 30, 2022, with additional reports due annually through April 30, 2027. For many reporting in April, this will be the first occasion to use the U.S. Treasury’s (Treasury) reporting portal. It is wise to begin the process now, as it typically takes significant time to complete the registration process. Instructions for registration were sent to non-entitlement units in mid-December 2021. Information regarding registration can be found at the Treasury’s Coronavirus State and Local Fiscal Recovery Funds website.

Like the interim report submitted in August 2021, the P&E report will be conveyed to the Treasury through its electronic portal. On Jan. 7, 2022, the Treasury released the