LFRF Allowable Uses and Reporting Requirements FAQs

This document provides answers to frequently asked questions by New Hampshire local government stakeholders regarding the Local Fiscal Recovery Funds established by the American Rescue Plan Act. This document is subject to revision as guidance evolves.

1. What is ARPA? What are the Coronavirus Local Fiscal Recovery Funds?

The American Rescue Plan Act (“ARPA”) was signed in to law by President Biden on March 11, 2021 to support coronavirus pandemic recovery.  Among its many provisions, ARPA establishes the Coronavirus Local Fiscal Recovery Funds (“LFRFs”), which provide emergency funding for local governments to support their response to the impacts of the pandemic. ARPA authorizes the U.S. Department of the Treasury (“Treasury”) to administer the LFRFs.

ARPA provides $112.2 million specifically for New Hampshire local governments.

ARPA refers to local governments as “non-entitlement units of local government” (“NEUs”).

2. What is an NEU?

Non-entitlement units of local government (NEUs) are defined in ARPA as local governments typically serving populations of less than 50,000. NEUs include cities, villages, towns, townships, or other types of local governments.

Treasury identifies 229 NEUs in New Hampshire.

3. What are the big picture objectives of the LFRF?

Broadly, ARPA established the LFRFs for local governments to accomplish four key objectives:

  1. Support urgent pandemic response efforts
  2. Replace lost state and local government revenue
  3. Support economic stabilization
  4. Address public health and economic inequities that exacerbated the impacts of the pandemic for some.
4. Where will the LFRF funds come from, and when will funds be distributed to NEUs?

Treasury will distribute funds to the states, who will then distribute them to their NEUs. Treasury expects to make payments to states for distribution to NEUs in two equal tranches approximately twelve months apart. Following receipt of funding from Treasury, ARPA requires each state to distribute funds to its NEUs within 30 days unless granted an extension by Treasury.

The invoice date of the first NEU tranche to New Hampshire was May 28, 2021. New Hampshire shows receipt of the funds on June 1, 2021.

5. What determines an NEU’s funding allocation through the LFRF?

Funding allocations to NEUs are based on their population.

Additionally, the total amount to be distributed to an NEU may not exceed the amount equal to 75 percent of its most recent budget as of January 27, 2020.

6.   Does an NEU need to do anything in order to receive funds?

Yes. An NEU must take action in order to receive funds.  New Hampshire’s application portal is on the GOFERR website (beginning June 17, 2021).

To submit an application, an NEU must have available and/or provide:

  • Local government name, Taxpayer Identification Number, DUNS number, State Vendor Number, and address  
  • Authorized representative name, title, and email  
  • Contact person name, title, phone, and email
  • Financial institution information (e.g., routing and account number, financial institution name and contact information)
  • Total NEU budget (defined as the annual total operating budget, including general fund and other funds, in effect as of January 27, 2020) or top-line expenditure total (in exceptional cases in which the NEU does not adopt a formal budget)
  • Agreement to certain terms and conditions of the funding

Treasury has prepared a checklist to assist NEUs in this process.

7.  Are there eligibility criteria that an NEU must meet in order to receive funds?

As noted above, an NEU’s allocation is based on its population. Additionally, ARPA specifies that an NEU’s allocation may not exceed the amount equal to 75 percent of its most recent budget as of January 27, 2020.

Broadly, an NEU must accept award terms and conditions and assure compliance with Title VI of the Civil Rights Act of 1964.

A state may not impose additional requirements on an NEU in order to receive its allocation of funds.

8.  What if an NEU does not adopt a formal annual budget?

If an NEU does not adopt a formal budget, it may instead certify its most recent annual total expenditures as of January 27, 2020. Note: these numbers may be verified against a copy of the appropriate budget documents submitted in the NEU’s first report to Treasury.

9.  What happens if an NEU’s funding allocation exceeds 75 percent of its budget?

If an NEU’s total allocation is found to be more than 75 percent of its budget, the State must return the amount of the allocation in excess of the NEU’s reference budget to Treasury.

10.  Can an NEU decline funding?

Yes. An NEU may decline its funding allocation and transfer funds to the State by providing a signed notice to the State.

Importantly, per Treasury guidance: “If the NEU does not provide such notice, it will remain legally obligated under the award with respect to accounting for the uses of the funds and the reporting on such uses. Treasury will provide a standard notice form that will be required for this use.”