ARPA Final Rule and Procurement Requirements for Audit Services
*REVISED January 28, 2022*
As many of you already know, the US Treasury last week issued the Final Rule on the funds granted to state and local governments by the American Rescue Plan Act. You can find the full rule (all 437 pages of it) here and a “brief” overview (only 44 pages) here. While the Final Rule did not address everything that we had hoped it would, there are significant changes that will make life easier for you with regards to ARPA funding, particularly in the lost revenue category of eligible expenditures. Two significant areas that did not change are the applicability of Uniform Grant Guidance to ARPA funds and the federal audit requirements over these funds.
Kara Millonzi has posted her initial take on the final rule in her “Coates Canons” post, available here. (Please note the email notification for new blog posts from the SOG is not functioning correctly at this time.)
In addition to Kara’s post, there is another new post on Procuring Single Audit services for ARPA funds. You can access that post here.
*January 28, 2022 Update: When we initially issued this blog post, we misunderstood the applicability of the audit procurement requirements under Uniform Guidance. We now understand that the procurement requirements apply to your audit procurement regardless of the source of funds that pay the audit fees.
Finally, Kara hosted SOG Office Hours on Jan. 13, 2022, and the primary topic was the Final Rule and the change in lost revenue calculations. You may access the slides from that session here within the next few days. Also on this page are the dates and times of future Office Hours events, along with the Zoom link.
Please let us know if you have any questions!