American Rescue Plan Act of 2021 Information Page

New CONTENT ON this page IS highlighted. Last Update: NOVEMBER 22, 2021 

The American Rescue Plan Act (ARPA) of 2021 is a $1.9 trillion economic stimulus bill. Within the ARPA, the Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) provides $350 billion for states, municipalities, counties, tribes, and territories, including $130 billion for local governments split evenly between municipalities and counties. This webpage provides important information for cities and towns in New Hampshire on ARPA and the CSLFRF.

NEUs: FIRST REPORT DUE APRIL 30, 2022


Quick Links


ARPA Funds & The Broadband Planning Network

The New Hampshire Municipal Association (NHMA) has partnered with the National Collaborative for Digital Equity (NCDE), founded and based in New Hampshire, to help communities that are interested in using Local and Fiscal Recovery Funds (LFRF) to improve broadband.  NHMA and NCDE are working together to bring interested members the opportunity to join an NHMA/NCDE broadband planning network and to undertake broadband investment planning together.  

Overview of the Broadband Planning Network
NCDE proposes that interested members allocate to NCDE a portion of their municipality’s ARPA Local Relief Funds (based on population, see below) to join the broadband investment planning network, whose priorities will be to: (1) assist the participating municipalities to develop one or more joint broadband investment funding proposals, (2) design investment plans to support for-profit and nonprofit business models that incorporate affordable pricing (<$15/month) for low- and moderate-income households; (3) assist participating municipalities to become “Broadband Ready” communities while developing NHMA’s capability to provide this support as an ongoing support to members generally; and (4) other broadband projects as deemed fundable.   

Broadband planning network cost schedule, based on population

25-4,999: $5,000

5,000-9,999: $7,500

10,000 and greater: $10,000

Please note that NHMA receives a fee for each municipality that joins the broadband planning network with NCDE. 

Please complete this form if you are interested in learning more about the NCDE broadband opportunity.  


                                          nlc logo                                                    NHMA logo                                                            US Treasury seal                         

 

                                                                                                              governors recovery group

 


IMPORTANT NOTICES for NEUs

  • Do you have your SAM.gov registration yet? NEUs were not required to have their SAM registration before applying, but it is still required and make take several weeks to be processed. If your entity has not yet applied, do so as soon as possible. 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. Any website seeking a fee is fraudulent. 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.
  • NHMA encourages NEUs to move slowly on making decisions about expenditure of their funds. There is no rush to spend funds (funds may be spent or obligated through December 31, 2024; funds obligated by that date may be spent through December 31, 2026). NHMA encourages NEUs to take time to learn about the eligible uses and reporting requirements and assess and determine the highest and best use of funds through careful vetting and after receiving public comment on proposed uses. 

U.S. Treasury Guidance and Resources on Coronavirus State and Local Fiscal Recovery Funds ("CSLFRF") from ARPA (applicable to all municipalities):


GOFERR Guidance and Information Specific to Nonentitlement Units of Government ("NEUs")

Except for the 5 "metropolitan cities" in NH (Nashua, Manchester, Dover, Rochester & Portsmouth) all municipalities are NEUs under ARPA/Treasury guidance.

Visit the GOFERR website.


US Treasury Guidance Specific to "NEUs"

The above FAQ is a live document link that is updated regularly. We recommended checking back regularly or bookmarking the link for easy access.


Compliance & Reporting Requirements


Eligible Uses of CSLFRF monies 

The eligible uses are explained in Treasury's Interim Final Rule (IFR).
In brief, the basic purposes for which the funds can be used are as follows:

1. Public Health
2. Negative Economic Impacts
3. Services to Disproportionality Impacted Communities
4. Premium Pay*
5. Infrastructure (Water, Sewer, Broadband)
6. Revenue replacement^
7. Administrative expenses (relative to administering/spending/reporting on use of LFRF money)

^Guidance on calculating "reduction in revenue" under the IFR (Extent of Revenue Loss Post-Pandemic:  after January 27, 2020)

The extent of the reduction in revenue is the difference between post-pandemic actual revenue and post-pandemic projected revenue.  Post pandemic projected revenue is calculated based on a “counterfactual trend” representing what could have been expected to occur in the absence of the pandemic. The counterfactual trend begins with the base year (your fiscal year ending June 30, 2019 or December 31, 2019) and using a pre-pandemic “revenue growth rate,” which is assumed to remain constant, allows you to project revenue for subsequent years through the ARPA eligible spending period.  The pre-pandemic “revenue growth rate” can be either your actual revenue growth rate or 4.1 percent as allowed by Treasury.

The “extent of revenue loss” is calculated as of four points in time:  December 31, 2020; December 31, 2021; December 31, 2022; and December 31, 2022. Use the GFOA Revenue Loss Calculator to complete these calculations. 

Calculate Projected Revenue:

  • First, determine your pre-pandemic “revenue growth rate.”  This will be the larger of:  1) the percentage of your average annual revenue growth over the three full fiscal years prior to the pandemic; or 2) the growth rate allowed by U.S. Treasury:  4.1%.
  • Then, using your pre-pandemic “revenue growth rate,” project what your post-pandemic revenue amount would have been if the pandemic had not occurred.

Calculate Actual Revenue:

  • Determine your post-pandemic actual revenue for the first time period ending December 31, 2020.

Calculate “Extent of Lost Revenue”:

  • Calculate the dollar amount difference between:  1) post-pandemic projected revenue and 2) post-pandemic actual revenue. 

Example – Town with December FYE

  • Revenue Growth Rate:  Pre-pandemic revenue growth rate was calculated to be 2.1 percent; Town opts to use the Treasury’s greater growth rate amount of 4.1 percent
  • Base year - fiscal year ending prior to pandemic:  December 31, 2019
  • Base year annual revenue$500,000

First Reporting Period:  December 31, 2020

  • Projected revenue for the first reporting period using 4.1 percent growth rate:  $500,000 * 1.041 = $520,500
  • Actual revenue for the first reporting period:  $505,000
  • Extent of lost revenue for first reporting period:  $520,500 - $505,000 = $15,500

*Guidance on Treatment of ‘Premium Pay’ Under ARPA 

In a press release dated May 19, 2021, The New Hampshire Retirement System (NHRS, the retirement system) has determined that “Premium Pay” under the American Rescue Plan Act (ARPA) is earnable compensation for retirement calculation purposes and subject to member and employer contributions.

Premium Pay is optional additional compensation funded by federal money provided to state and local governments under ARPA for eligible workers performing essential work during the COVID-19 public health emergency. Premium Pay is not mandated under ARPA, but the law gives employers the option to grant this additional pay, up to $13 per hour, and not to exceed $25,000.00 per eligible worker, to employees deemed eligible under US Treasury rules.  NHRS views this as a temporary increase in the member’s base rate of compensation.  If a participating employer authorizes Premium Pay to an NHRS member, the compensation should be reported to the retirement system as base compensation, and member and employer contributions should be remitted.

Other key provisions
  • States are not allowed to use the funds to either directly or indirectly offset a reduction in the net tax revenue that results from a change in law, regulation or administrative interpretation during the covered period that reduces any tax
  • No funds shall be deposited into any pension fund
  • State and local governments are allowed to transfer to a private nonprofit organization, a public benefit corporation involved in the transportation of passengers or cargo, or a special-purpose unit of state or local government.

 NLC Fact Sheets & Tools


Other Resources Relative to Treasury's Guidance:


 NLC Presentations on Treasury Guidance

 NLC ARPA Video

                      Duration:  1:05:20


Distributions to Local Government

Amount of Distributions to Local Government

The U.S. Department of Treasury has released the direct payments to NH's five metropolitan communities. For all other municipalities (towns and cities that are NEUs), the state has calculated the municipal distributions and the portal for requesting funds is open on the GOFERR website. (Please refer to NEU specific information near the top of this page.) 
  • For comparison/informational purposes only, you can view the original Estimated Allocation Amounts to state & local governments (Date: 3/08/2021; Source: NLC)
  • Also for comparison/informational purposes only, you can use this NLC allocation tool to view the estimated amount your community is eligible for. (These are estimates from the House Committee on Oversight, not final allocations. )

Nonentitlement – Additional Distribution Information:

  • “Nonentitlement” is short for “nonentitlement unit of local government,” which is the term used in the ARPA for cities, townships, villages, and small municipalities that generally have fewer than 50,000 inhabitants. Those allocations are proportionate to population and are subject to a cap of 75% of the locality’s most recent budget as of January 27, 2020.
  • Are village districts eligible to receive ARPA funds? Per US Treasury, village districts will not receive a portion of the state's allocations to NEUs. Instead, the US Treasury FAQ states that village districts are eligible to access ARPA funds in the following manner as "special-purpose units of government":
    • 1.3. Are special-purpose units of government eligible to receive funds?
      Special-purpose units of local government will not receive funding allocations; however, a state, territory, local, or Tribal government may transfer funds to a special-purpose unit of government. Special-purpose districts perform specific functions in the community, such as fire, water, sewer or mosquito abatement districts.
  • Cap on Distribution: The American Rescue Act includes a provision stating no city with less than 50,000 residents can receive a grant that is larger than an amount equal to 75% of their pre-pandemic budget, regardless of whether the estimates indicate an amount greater than that figure.  This is not accounted for in the “estimated allocation amounts” because data on small city budgets is not systematically collected by any federal entity.  US Treasury has released an update on the interpretation of the 75% budget cap.
  • Reference Guide: Understanding further allocations between CDBG communities and nonentitlement communities (NLC)

Timing of Distributions

  • First "Tranche" Amount – 50%:  The ARPA requires that, to the extent practical, the state distribute the first installment of the SLFRF monies to NEUs not later than 60 days from the date of enactment.
    • Nonentitlement Distributions - NEUs must submit their request to receive  their funds by August 18, 2021, using GOFERR's online portal, which can be accessed through the GOFERR webpage

  • Second "Tranche" Amount – 50%:  Per the ARPA, the second installment of money must be provided by the state to the NEUs not earlier than 12 months after the date of the first installment.
  • The metropolitan communities receive their funding directly from US Treasury. 

 


Members are encouraged to contact Guidehouse with questions about ARPA CSLFRF. Watch this brief video on how to contact Guidehouse!