As the League has previously shared, the U.S. Treasury Interim Final Rule for the American Rescue Plan and State and Local Fiscal Recovery Funds (SLFRF) includes compliance rules and guidelines.
Below is guidance provided by the U.S. Treasury and best practices from the Office of the State Comptroller (OSC). The full U.S. Treasury Compliance and Reporting Guidance is a helpful tool. It is important to remember that reporting is required, even if funds have yet to be distributed.
Metropolitan Cities (municipalities with a population above 50,000 residents who received funding directly from the federal government) that received more than $5 million in funding must file an interim report at the end of this month (August 31) and a project and expenditure report at the end of October and quarterly thereafter.
Metropolitan Cities (municipalities with a population above 50,000 residents who received funding directly from the federal government) that received less than $5 million in funding must file an interim report at the end of this month (August 31) and a project and expenditure report at the end of October and annually at the end of July thereafter.
Non-Entitlement Units of government (municipalities with a population under 50,000 residents and received funding from the state as a pass-through from the federal government) must file a project and expenditure report at the end of October and annually thereafter. Please note that, Non-Entitlement Units of government are also referred to as NEUs in federal and state guidance.
Metropolitan cities with a population above 250,000 residents must file an interim report at the end of this month (August 31) and a project and expenditure report at the end of October and quarterly thereafter. In addition, they must file a Recovery Plan and Performance Report by the end of August and then annually at the end of July.
The chart below is a helpful guide:

The Office of the State Comptroller has created a Covid-19 Compliance and Tracking website as well as Risk Assessment Template. We encourage municipal officials to utilize the resources provided by the OSC.
Please be sure to periodically check the League’s Federal Page of Municipal Interest.
Contact: Paul Penna, Legislative Analyst, ppenna@njlm.org or 609-695-3481, x110.