Sneak Preview: Associations Urge Clear, Timely SLFRF Guidance

(The following was excerpted from a recent Thompson Grants Compliance Expert article.) Several associations representing state and local governments recently sent a letter to the Department of the Treasury seeking clearer guidance on various issues pertaining to State and Local Fiscal Recovery Fund (SLFRF) administration, including how Treasury defines “obligation” for payroll costs for monitoring, reporting and auditing following SLFRF’s Dec. 31, 2024, obligation deadline.

The letter was submitted jointly by the National Association of State Auditors, Comptrollers and Treasurers (NASACT); Government Finance Officers Association; National Association of State Budget Officers; and the National League of Cities. Treasury recently issued an SLFRF interim final rule (see “Treasury Issues 2023 SLFRF Interim Final Rule,” October 2023), effective Sept. 20, which incorporated statutory amendments to the program and expanded on the agency’s 2022 SLFRF final rule. Prior to the issuance of the interim final rule, Treasury had assisted program recipients through a continuously updated SLFRF 2022 Final Rule Frequently Asked Questions document.

A NASACT official told Thompson Grants editors that the organizations had hoped that previous concerns they had brought to the agency related to obligations would be addressed in the interim rule, but they were not. She added that “further clarification is needed immediately because of the varying times legislatures meet and the way the budget process works.”

SLFRF was established under the American Rescue Plan Act (Pub. L. 117-2) to provide more emergency relief funding to state and local governments first initiated through the Coronavirus Relief Fund (CRF), which was developed under the Coronavirus Aid, Relief, and Economic Security (CARES) Act (Pub. L. 116-260). The organizations told Treasury that they are “increasingly concerned that existing guidance is subject to varying interpretations, and previous guidance given for [CRF] does not apply to SLFRF.”

(The full version of this story has now been made available to all for a limited time here.)

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