Treasury issues guidance on pre-award requirements for State and Local Fiscal Recovery Funds

The U.S. Treasury (Treasury) has issued information on the pre-award requirements for State and Local Fiscal Recovery Funds (FRF). While the focus in preparation for these funds should continue to be on strategy development, the following is important information for preparing entities to receive the FRF deposits, as well as apply for additional funding provisions in the American Rescue Plan Act of 2021.

Please review the following and take action as it relates to establishing methods to receive deposits of the funding. As the FRF program guidance is released in the coming weeks, our team will share insights and provide a detailed review.

Guidance from Treasury regarding pre-award requirements for State and Local FRF

Per Treasury guidance, prior to receipt of a direct payment of funds from Treasury, entities should prepare certain information in advance as listed below. Taking these steps will allow eligible entities to be better positioned to receive payments from Treasury once the program is launched. As outlined by Treasury, direct payments will be made to the following eligible entities: states, including the District of Columbia, territories, tribal governments, counties and metropolitan cities.

The following steps should be taken as soon as possible to prepare to receive funding:

• 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 call 1-866-705-5711 to begin the registration process.
• 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’s 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; delay in registering in SAM could impact timely payment of funds. Click here for a quick overview for SAM registration
• 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)

Non-entitlement units of local government will receive a distribution of funds from their respective state government. (“Non-entitlement units of local government” are defined in 42 U.S.C. 5302(a)(5) that are not metropolitan cities.)

Remember! Non-entitlement units must have a valid DUNS number to meet reporting the requirements under the program. If an entity does not have a valid DUNS number, please call 1-866-705-5711 to begin the registration process.

For more information, or to learn how Baker Tilly’s government specialists can help your entity prepare and strategize for ARP funding, contact our team.