Fiscal Recovery Fund guidance for Indiana nonentitlement units

The first half of the American Rescue Plan Act of 2021 (ARP) funds are ready to be distributed to the nonentitlement units of local government (NEU’s) in Indiana. Now, the question is, “how does my NEU go about requesting our allocated funds?” This article provides some additional guidance and clarification on the application process. The Indiana Finance Authority (IFA) has a section on their website titled, “American Rescue Plan – Non-entitlement Units.” This webpage includes links to all documents that are needed to apply for funding as well as additional information regarding the program and distribution of funds.

Once your NEU has become familiar with the program, the next step is to apply for funding. The application (CLFRF Request for Payment) can be found in PDF on the IFA webpage provided above. Once the application has been downloaded, you will see a one-page application with three blank sheets of paper following it, which is where you will eventually attach your exhibits. The application can be broken down into four sections:

1. General Information section – this section of the application is used to provide basic information to the IFA about the NEU applying for funding. This information should either be common knowledge or easy to find. It should be noted that all applicants should be registered on SAM.gov in order to receive timely funding. This website will be used for tracking of allocations as well as a submission portal for reporting and compliance requirements.
2. Verification of Allocation section – this section of the application will be the most difficult section to complete for most NEU’s. The Top Line 2020 Budget is intended to come from the “Adopted Budget” column in the 2020 Budget Form 4 that was submitted to the DLGF as part of the 2020 budget process. However, in most cases, there will be a difference between many NEU’s Form 4 budget amounts and the Top Line 2020 Budget shown on the Indiana NEU Estimated Allocations Table that can be found at the webpage linked above. We have found that the amount shown in the Allocations Table typically matches what is shown on the NEU’s Final 2020 Budget Order. Because of this, we recommend that the total certified budget from the 2020 Budget Order be used on this line if it matches the number on the Indiana NEU Estimated Allocations Table. Once the applicant completes the Top Line 2020 Budget box on the application, the applicant can take 75% of that amount and enter it into box 2b. Box 2c will also be pulled from the Allocations Table, using the total “Estimated Total Allocation” column. In the event that either the 75% of Top Line 2020 Budget in box 2b is lower than the U.S. Department of Treasury allocation in box 2c or the 2020 Budget Order does not match the number shown in the Indiana NEU Estimated Allocations Table, we recommend that the applicant reach out to your financial advisor to discuss possible adjustments to the application.
3. Certification/Signature section – this section of the application is simple. Once you have signed and attached Exhibit B and Exhibit C (See #4), the applicant will check “Yes” in boxes 3a and 3b and “No” in 3c.
4. Exhibits

• Exhibit A – this is where the NEU will attach the 2020 Budget Form 4 that was submitted to the DLGF. We also recommend attaching the Final 2020 Budget Order if it was used to fill out box 2a in the Verification of Allocation Section of the application.
• Exhibit B – this exhibit can be found on the IFA webpage titled, “Award Terms and Conditions for Non-entitlement Units of Local Government.” The applicant will need to fill out the top section with basic information and have the authorized representative sign and date the exhibit.
• Exhibit C – this exhibit can be found on the IFA webpage titled, “Assurances of Compliance with Title VI of the Civil Rights Act of 1964.” The applicant will need to have the authorized representative sign and date the exhibit.

Once the application has been completed with all exhibits attached and signed by the appropriate parties, the NEU will send the packet to COVID-19@ifa.in.gov for approval. As always, we are more than willing to review applications and answer any questions that may arise while filling out the application.

For more information or to learn more about how Baker Tilly can help your NEU, contact our team.