American Rescue Plan Act for Local Governments: Pre-Award Guidance from Treasury
April 26, 2021
The American Rescue Plan Act will provide $350 billion in emergency funding for state, local, territorial, and Tribal governments. The U.S. Treasury recently released its guidance on pre-award requirements that includes immediate steps recipients need to take to receive Recovery Funds. This information may be especially important to smaller governments or those that have not previously received federal funding.
Eligible recipients (including Eligible Non-entitlement Units of Local Government as defined below) should take the following step:
- 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, visit https://fedgov.dnb.com/webform/ or call 1-866-705-5711 to begin the registration process.
Direct recipients should as take the following steps:
- 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 SAM registration. If an entity does not have an active SAM registration, please visit, www.SAM.gov to begin the entity registration or renewal process. Note that SAM registration can take up to three weeks; delay in registering in SAM could impact timely payment of funds. An overview for SAM registration can be found at https://home.treasury.gov/system/files/136/New-to-SAM.gov-for-Financial-Assistance-April-2021.pdf.
- 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)
Eligible Non-entitlement Units of Local Government will receive a distribution of funds from their respective state government. “Non-entitlement units of local government are non-metropolitan cities, townships, villages, and small municipalities that generally have fewer than 50,000 inhabitants.” For these Non-entitlement units of local government, the Treasury will allocate and pay funds to state governments, and the state will distribute funds to non-entitlement units of local government in proportion to population. Non-entitlement units must have a valid DUNS number to meet reporting requirements under the program (see Step #1 above).
Submission instructions for the U.S. Treasury will very likely follow soon, but as of now those instructions are not yet available. It is recommended that as part of this preparation process, your executive or authorized officer is prepared to certify the submission.
The Governmental Services Team at SEK is here for you. Use the form below to contact us with any questions or if your organization needs help preparing to receive your federal award.